Privacy policy.
1. Important information and who we are
Purpose of this privacy policy
Welcome to Otta’s privacy policy. We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we process your personal data when you visit our website or app or use our services and tells you about your privacy rights and how the law protects you.
This website and the Otta app are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
If you are a California resident, please see our California Resident Privacy Notice for supplemental information and disclosures regarding your rights.
Controller
Otta Technology Ltd, trading as Otta is the data controller and is responsible for your personal data (collectively referred to as "Otta", "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
Full name of legal entity: Otta Technology Ltd, trading as Otta.
E-mail address: notifications@otta.com
Postal address: Otta, First Floor, Mindspace, 142-146 Old St, London EC1V 9BW.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Individuals and data protection supervisory authorities in the EU may contact our data protection representative in accordance with Article 27 GDPR: Maetzler Rechtsanwalts GmbH & Co KG, Schellinggasse 3/10, 1010 Vienna, Austria.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review and may update this policy from time to time without notice. If we materially change the ways in which we use or share personal data previously collected from you through the website, app and services, we will notify you through the website, app and services, by email, or other communication.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website and the Otta app may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or app, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. How your personal data is collected
We use different methods to collect data from and about you including through:
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Purposes for which we will use your personal data
We have set out below a description of the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose / Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer and allow you to access our website, app, and services, including our job matching service.
To manage our relationship with you which may include contacting you with updates or information about our service (but excluding marketing).
To operate, administer and protect our business, this website and the app (including dealing with our customers, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
To deliver relevant website and app content and advertisements to you, and measure or understand the effectiveness of the information we serve to you.
To use data analytics to improve our website, app, products/services, marketing, customer relationships and experiences.
To make suggestions and recommendations to you about roles and companies that may be of interest to you, and to allow companies to reach out to you about roles that may be of interest.
Tailored Content and Marketing
We may use your Identity, Engagement, Profile, Technical, Usage and Special Categories of Data to form a view on jobs or services that you may be interested in, or that may be suitable for you and may display relevant content on our website or app, or send it to you by email. You may also receive marketing communications from us if you have opted in to receive marketing, or if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Opting out
You can ask us to stop sending you marketing or job notification messages at any time by following the opt-out links on any marketing message sent to you.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy .
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
When processing your personal data as described above, we may share your personal data with the parties set out below:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Some of the suppliers that we use to operate our services, and some of the employers that use our website are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have internal procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long we will use your personal data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are to:
If you wish to exercise any of the rights set out above, please contact us or our representative using the contact details set out above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Version v.102.
Last updated: 22nd February 2023