OTORIO LTD. - PRIVACY POLICY

This Privacy Policy governs how OTORIO Ltd. (“OTORIO” “we”, “our” or “us”) use, collect, and store Personal Data that we collect or receive from or about you, in the following use cases:

1. When you make use of, or interact with, our website, https://otorio.com (“Website”)
   • When you subscribe to our distribution list(s) / newsletter(s) / blog(s)
   • When we process your job application 
   • When you contact us (e.g. customer support, need help, submit a request)
     When you make use of, or interact with, our Ram², spOT and/or remOT platforms, and any other software, that we license (each individually, and collectively, the “Platform”).
   • When you create an account and when you log in.
2. When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data
   • When we acquire your Personal Data from third-party sources (such as lead-generation companies)
   • When we use the Personal Data of our customers (e.g. contact details)
   • When we use the Personal Data of our service providers (e.g. contact details)
   • When you interact with us on our social media profiles (e.g., Facebook, LinkedIn)
   • When you apply for a job with OTORIO as a candidate for a position at the company

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by applicable privacy laws. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant to GDPR-protected individuals. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement. 

Table of contents:

1. What information we collect, why we collect it, and how it is used
2. How we protect and retain your Personal Data
3. How we share your Personal Data
4. Additional information regarding transfers of Personal Data
5. Your privacy rights
6. Use by children
7. Interaction with third party products
8. Log files 
9. Analytic Tools
10. Specific Provisions Applicable under California Privacy Law 
11. Contact us

This Privacy Policy can be updated from time to time. Therefore, we ask you to check for the latest version of this Privacy Policy periodically. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. What Information We Collect, Why We Collect It, and How It Is Used
   

   Specific personal data we collect	Why is the personal data collected and for what purposes?	Legal basis	Third parties with whom we share your personal data	Consequences of not providing the personal data
   When you make use of, or interact with, our Website
   - Full name - Email address - Phone Number - Job title - Company Name - Company size - Industry - Country - State/Providence	- To send you marketing communications - To send you OTORIO updates about our blog	- Consent - Legitimate interest (e.g. send you more information about us in a B2B context)	- Hubspot - Salesforce - Insycle - Klenty - AWS - Rollworks - Salesloft	- Cannot send you marketing communications - Cannot send you updates about OTORIO´s blog
   When we process your job application
   - Full name - Email address - Telephone number  - CV – resume  - Cover letter - Any other information that you decide to provide/supply us with	- To assess you as a candidate - To communicate with you in connection with your job application	Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g., to analyze your application)	Comeet AWS	- Cannot assess you as a candidate - Cannot communicate with you in connection with your job application
   When you contact us (e.g. support, help, chat, general inquiries, request a demo)
   - Full Name - Email address - Phone Number - Job Position - Industry - Country - Any other information that you decide to provide/supply us with	- To answer your query - To respond to your requests - To provide support and customer service - To customize your experience	Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract  Legitimate interest (e.g. provide support and answer your questions)	Hubspot Salesforce Insycle Klenty AWS Rollworks Salesloft	- Cannot answer your query - Cannot respond to your requests - Cannot provide support and customer service - Cannot customize your experience
   - Full name - Email address	- To send you marketing communications	Consent	Hubspot Salesforce Insycle Klenty AWS Rollworks Salesloft	- Cannot send marketing communication
   When you make use of, or interact with, our Platform
   When you create an account and when you log in to our Platform
   - Full name - Email address - User ID and Password	- To create your account and allow you to create the admin and operator users - To allow you to log in to the Platform - To expose you only to the data you are allowed to see - To grant you access to the services (our Platform)	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. to allow you to sign up to the Platform)	Azure	- Cannot create your account and allow you to create the admin and operator users - Cannot allow you to log in to the Platform - Cannot exclude you from seeing data that you are not allowed to see.  - Cannot grant you access to the services (our Platform)
   When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data
   - Full Name - Email Address - Company name - Job title - Phone number - Address - Company Name - Company size - Industry - Any other data you decide to provide/supply us with	- To establish a first business connection/discussion - To send you marketing communications	Consent  Legitimate interest (e.g. to establish a business connection)	Hubspot Salesforce Insycle Klenty AWS Rollworks Salesloft	- Cannot establish a first business connection/discussion - Cannot send you marketing communications
   When we acquire your Personal Data from third-party sources (such as lead-generation companies)
   - Full Name - Job Title - Telephone Number - Address - Company Name - Industry - Any other data you decide to provide/supply us with	- To establish a first business connection/discussion - To send you marketing communications	Depending on the context, legitimate interest (B2B marketing), pre-contractual discussions or consent	Hubspot Salesforce Insycle Klenty AWS Rollworks Salesloft	- Cannot establish a first business connection/discussion - Cannot send you marketing communications
   When we use the personal data of our customers (e.g. contact details)
   - Full name - Company name - Email address  - Phone number - Any data available on LinkedIn profiles  - Any other data you decide to provide/supply us with	- To provide our products and services - To perform the applicable agreement - To communicate with our Customers/clients (e.g., to send you contract-related communications) - To provide to our wider sales team	Processing is necessary for the performance of a contract to which our customer is a party.   Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).               Legitimate interest (e.g. send you contract-related communications)	Hubspot Salesforce Insycle Klenty AWS Salesloft	- Cannot provide our products and services - Cannot perform the applicable agreement - Cannot communicate with our Customers/clients
   - Full name - Email address	- To send you marketing communications and other communications about our products and services	Depending on the context, legitimate interest (B2B marketing or soft-opt in) or consent	Hubspot Salesloft Insycle	- Cannot establish a first business connection/discussion - Cannot send you marketing communications
   When we use the personal data of our service providers (e.g. contact details)
   - Full name - Company name - Job title - Email address  - Phone number - Any other data you decide to provide/supply us with	- To contact our service providers/vendors - To perform the applicable agreement	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract   Legitimate interest (e.g.to contact our service providers)	AWS	- Cannot contact our service providers/vendors - Cannot perform the applicable agreement
   When you interact with us or provide us with your information via our social media profiles (e.g., Facebook, LinkedIn)
   - Full name - Company name - Address - Email address  - Phone number - Job Title - Any other data that you decide to supply/provide us and/or publicly available on your social media account	- To reply and/or respond to your request or question - To provide you with content and information that you have requested.	Consent  Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract Legitimate interest (e.g. send you more information about OTORIO) Processing is necessary for compliance with a legal obligation to which the controller is subject	Hubspot Salesforce Insycle Klenty Rollworks Salesloft	- Cannot reply and/or respond to your request or question - Cannot provide you with content and information that you have requested.
   When you apply for a job with OTORIO as a candidate for a position at the company
   - Full name - Address - Email address. - Curriculum Vitae (resume) - Information regarding your skills, work experience, education - Your LinkedIn URL and URLs for your other online profiles - The position for which you are applying - The source of who submitted your application (for example, recruitment agency or referral) - Email correspondence between you and OTORIO and OTORIO and other third parties (for example, recruitment agencies) about your candidacy and the application - Information from references - Information about events in the lifecycle of your candidacy - Your responses to any questionnaires sent to you by OTORIO - Information about your candidacy and employment options (such as availability to be hired and salary expectations) - Evaluations of your candidacy - Internal discussions within OTORIO about your candidacy - Materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy - Any other data that you decide to supply/provide us and/or publicly available on your social media account	- To to evaluate and consider you as a candidate for positions at OTORIO - To to contact you for your candidacy status and interviews - To schedule meetings and interviews with you - To communicate with you in order to provide you updates and other correspondence about your application.	Consent  Legitimate interest (e.g. send you more information about OTORIO)	Comeet   Azure	- Cannot evaluate and consider you as a candidate for positions at OTORIO. - Cannot contact you for your candidacy status and interviews with you. - Cannot schedule meetings and interviews. - Cannot communicate with you in order to provide you updates and other correspondence about your application.

   Please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data will also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

2. How We Protect and Retain Your Information
   • Security
     We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
   • Retention of your Personal Data
     Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.
3. How We Share Your Personal Data

   In addition to the recipients described above, we may share your Personal Data as follows:
   
   

   • With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies;
   • To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
   • If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
   • In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company;
   • Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality);
   • With our service providers and vendors who assist us to collect, process and store your personal data, including, Comeet (who provide us with the Platform) in the context of your candidacy. These companies are authorized to use your personal data as necessary to provide these services or as otherwise authorized by us. Comeet’s privacy policy is available here;
   • We share your general recruitment status with third parties who submitted your candidacy to us;
   • If your details are submitted to OTORIO by a third-party (such as an employee of OTORIO or a recruiting agency), OTORIO can give the third-party access to your name, photo and some of the general recruitment status;
   • If you apply to a job opening using a unique referral link that was provided to you by an employee of OTORIO to which you are applying, OTORIO share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link; and/or
   • For the purpose of sharing the above information is to operate OTORIO’s incentive programs (i.e. employee referral bonus programs) and to provide feedback to third-parties who submit candidates to OTORIO regarding their submission.
4. Additional Information Regarding Transfers of Personal Data
   • Storage
     Personal Data is stored in the systems of the relevant vendors specified in the table above.
   • Internal transfers
     If relevant, transfers within the OTORIO group will be covered by an internal processing agreement entered into by members of the OTORIO group (an intra-group data processing agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.
   • External transfers
     Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data. When Otorio engages in such transfer of Personal Data, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission.
5. Your Privacy Rights
   • Rights
     The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
     • You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
     • You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
     • You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
     • You have the right to object, to or to request restriction, of the processing;
     • You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
     • You have the right to object to profiling;
     • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
     • You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
     • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
       You can exercise your rights by contacting us at [email protected] You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
   • Deleting your account
     Should you ever decide to delete your account, you may do so by emailing [email protected]. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
6. Use by Children
   We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].
7. Interaction with Third Party Products
   We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
8. Log Files
   We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.
9. Analytic Tools
   • Google Analytics.
     The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
   • YouTube API.
     Our website uses YouTube API to help visitors who go to YouTube to have an easier search for videos relevant for them. For further details please see the YouTube API terms of service at https://developers.google.com/youtube/terms/api-services-terms-of-service and the Google privacy policy at https://policies.google.com/privacy.
   • Hotjar.
     The Website uses Hotjar to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.
   • Advertising Partners
     Through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, website identifiers, page(s) visited, location, time of day). We also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Data with third party advertising partners, you may let us know.
10. Specific Provisions Applicable under California Privacy Law
    • Other California Privacy Rights
      California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.
    • Our California Do Not Track Notice (Shine the Light)
      Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
11. Contact Us
    If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at  [email protected].