Privacy Policy
A legal disclaimer
The OTTO Connection takes your privacy seriously
Information Collection and Use
Privacy Policy – The Otto Connection
https://app.theottoconnection.com/ (our website) is provided by The Otto Connection Limited (trading as ‘The Otto Connection’) a company registered in England and Wales under company number 13205133 whose registered office is at 7 Bell Yard, London, WC2A 2JR (‘OTTO’, ‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).
Given the nature of our website, we do not allow it to be accessed by anyone under the age of 18 and as a result we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with our website please let us know so that we can delete that data.
This privacy policy is divided into the following sections:
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What this policy applies to
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Personal data we collect about you
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How your personal data is collected
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How and why we use your personal data
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Marketing
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Who we share your personal data with
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How long your personal data will be kept
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Transferring your personal data out of the UK and EEA
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Cookies
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Your rights
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Keeping your personal data secure
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How to complain
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Changes to this privacy policy
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How to contact us
What this policy applies to
This privacy policy relates to your use of our website only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
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your name, address and contact information, including email address and telephone number;
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information to check and verify your identity, e.g. date of birth;
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your gender;
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location data;
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your billing information, transaction and payment card or other payment method information;
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bank account and payment details;
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details of any information, feedback or other matters you give us by phone, email, post or via social media;
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your account details, such as username and login details;
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your activities on, and use of, our website;
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your personal interests;
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information about the services we provide to you;
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your contact history, purchase history and saved items;
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information about how you use our website and technology systems;
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your responses to surveys, competitions and promotions.
If you do not provide personal data we ask for where it is indicated to be ‘required’, it may delay or prevent us from providing services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
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directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase services via our website, post material to our website and complete customer surveys or participate in competitions via our website, and
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indirectly, such as your browsing activity while on our website; we do not usually collect information indirectly.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, for example:
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where you have given consent;
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to comply with our legal and regulatory obligations;
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for the performance of a contract with you or to take steps at your request before entering into a contract; or
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for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
What we use your personal data for
Create and manage your account with us
Providing services to you
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us
To enforce legal rights or defend or undertake legal proceedings
Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website so that we can make it more intuitive or to check our website is working as intended
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices
Protecting the security of systems and data
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures
Updating and enhancing customer records
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant
Marketing our services to existing and former customers
External audits and quality checks, e.g. for the audit of our accounts
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary
Our reasons
To perform our contract with you or to take steps at your request before entering into a contract.
To perform our contract with you or to take steps at your request before entering into a contract.
For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us.
Depending on the circumstances:
—to comply with our legal and regulatory obligations;
—in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others.
Depending on the circumstances:
—your consent as gathered;
—where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.
Depending on the circumstances:
—your consent as gathered —see ‘Cookies’ below;
—where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.
Depending on the circumstances:
—to comply with our legal and regulatory obligations;
—in other cases, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.
To comply with our legal and regulatory obligations. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price.
Depending on the circumstances:
—to perform our contract with you or to take steps at your request before entering into a contract;
—to comply with our legal and regulatory obligations;
—where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products.
To comply with our legal and regulatory obligations.
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers.
See ‘Marketing’ below for further information.
For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards.
Depending on the circumstances:
—to comply with our legal and regulatory obligations;
—in other cases, for our legitimate interests or those of a third party, i.e. to protect, realise or grow the value in our business and assets.
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
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personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership;
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data concerning health, sex life or sexual orientation.
Where we process such special category personal data, we will also ensure we are permitted to do so under data protection laws.
We will use such data for the reasons outlined in the table above as relevant in the circumstances but in addition are required by law to meet a further condition to have the right to use such data. Where we use the special categories of data set out above the additional conditions we rely upon are that the processing relates to personal data which is manifestly made public by you (the data subject) and you have given your explicit consent.
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
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contacting us at support@theottoconnection.com; or
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using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with:
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third parties we use to help deliver our services to you, e.g. payment service providers;
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other third parties we use to help us run our business, e.g. marketing agencies or website hosts and website analytics providers;
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our bank.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above may occasionally also need to share personal data with:
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external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
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professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
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law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; and
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other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
Different retention periods apply for different types of personal data. Further details on this are available on request – please email support@theottoconnection.com.
If you stop using your account we will delete or anonymise your account data after seven years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK and EEA
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes or it may be necessary for us to share your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
For example we may transfer your personal data to service providers located outside the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
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in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here;
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in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. In addition, EEA data protection laws provide that transfers of personal data to the UK are lawful under an interim arrangement (UK interim bridge) while the European Commission seeks to determine if the UK can be granted a longer-term adequacy decision;
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there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
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a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where such is not available) standard data protections clauses (the Model Clauses) adopted by the Information Commissioner in the UK. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law.
Where we transfer your personal data outside the EEA we do so on the basis of the UK interim bridge or an adequacy decision or (where such is not available) standard data protections clauses (the Model Clauses) adopted by the Information Commissioner in the UK. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we use to transfer personal data internationally will be notified to you in accordance with the section on ‘Change to this privacy policy’ below.
For further information about such transfers and the safeguards we employ, please contact us (see ‘How to contact us’ below).
Cookies
A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We do not use cookies on our website but some of our third-party service providers (e.g. Stripe) do. For further information on these cookies please refer to the third-party providers website.
Your rights
You generally have the following rights, which you can usually exercise free of charge:
Access to a copy of your personal data
Correction (also known as rectification)
Erasure (also known as the right to be forgotten)
Restriction of use
Data portability
To object to use
Not to be subject to decisions without human involvement
The right to be provided with a copy of your personal data.
The right to require us to correct any mistakes in your personal data.
The right to require us to delete your personal data—in certain situations.
The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
The right to object:
—at any time to your personal data being used for direct marketing (including profiling)
—in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by our website.
A more detailed explanation of these rights under UK law is available here from the UK’s Information Commissioner.
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).
If you would like to exercise any of those rights, please email to us—see below: ‘How to contact us’. When contacting us please:
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provide enough information to identify yourself (e.g. your full name and address) and any additional identity information we may reasonably request from you; and
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let us know which right(s) you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner in the UK. The UK’s Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via email or a prominent link on our website.
How to contact us
You can contact us by email (support@theottoconnection.com), or via instant messaging on our website if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
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