Privacy Notice

Last Updated: September 15, 2024

This Privacy Notice describes how Otti, Inc. ("we", "us", "our") collects, uses and discloses information about you when you use our website (otti.com), services, tools, and features, or otherwise interact with us (collectively, the "Services"). For the purposes of this Privacy Notice, "you" and "your" means you as the user of the Services.

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services.

1. CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the "Last Updated" date at the top of this Privacy Notice. If we make material changes to how we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

2. COLLECTION AND USE OF INFORMATION

When you use or access the Services, we collect certain categories of information about you from a variety of sources. The types of personal information we collect and how we use your personal information depends on whether you are an Otti Customer (for example, an employer that uses Otti's Services) or an employee of an Otti Customer.

Otti Customers:

Some features of the Services may require you to directly provide certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

• Basic contact details, such as name and email address. We use this information to create and maintain your account and provide the Services and communicate with you (including to tell you about products or services that may be of interest to you.
• Account information, such as username, password, security questions that you select and the answers you provide. We use this information to provide the Services and to maintain and secure your account with us. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately.
• Payment information, such as bank account, credit or debit card information, and billing address, which we collect using a third party payment processor. We use this information to process your payment and provide the Services.
• Any other information you choose to include in communications with us, for example, when sending a message through the Services.
• Other information, such as your photograph if you should choose to provide it. We use this information to create your profile and provide the Services.

We may use cookies or other tracking technologies to automatically collect certain information about your interactions with the Services. We collect and use this information to tailor your experience with the Services, run analytics, better understand user interactions with the Services, etc.. Such information includes:

• Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.
• Location information, such as approximate location / precise geolocation, if you choose to provide it.
• Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, clickstream data, etc..

We may also use DataDog to 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 the Services with user feedback.

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of cookies. If you so choose, you may block or delete certain of our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly. Your browser settings may also allow you to transmit a "Do Not Track" signal when you visit various websites. Like many websites, our website is not designed to respond to "Do Not Track" signals received from browsers. To learn more about "Do Not Track" signals, you can visit http://www.allaboutdnt.com/.

Employees of Otti Customers:

Otti Customers are organizations that use the Services to help them manage and engage with their employees. If you are an employee of an Otti Customer, we may process your personal information such as basic contact details, employment-related information, and information collected through cookies and other tracking technologies, on behalf of the relevant Otti Customer and according to that Otti Customer's instructions. If you have questions about the personal information we process on behalf of an Otti Customer, or want to exercise any privacy rights that may be applicable, we recommend that you reach out to that Otti Customer. We are not responsible for the privacy or security practices of Otti Customers, which may differ from those set out in this Privacy Notice. Please review the relevant Otti Customer's privacy notice to understand more about their data processing activities.

In addition to the specific uses described above, we may use any of the above information (including information about Otti Customers and employees of Otti Customers) to provide you with the Services and to maintain our business relationship, including by enhancing the safety and security of our Services, providing customer support, improving the Services, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting our rights and the rights of our employees, users or other individuals.

Finally, we may deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you, and we may use such deidentified/anonymized information for any purpose, including training artificial intelligence, content relevancy scoring, product improvement, and benchmarking.

3. DISCLOSURE OF YOUR INFORMATION

We may disclose your information for purposes subject to this Privacy Notice, including the following categories of third parties:

• Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, customer relationship management, marketing communications, web analytics, payment networks, and payment processing.
• Third parties to whom you request or direct us to disclose information.
• Professional advisors, such as auditors, law firms, or accounting firms.
• Third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.

4. THIRD PARTY WEBSITES AND LINKS

We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

5. CHILDREN'S PRIVACY

Our Services are not intended for children, and we do not seek or knowingly collect any personal information about children. If we become aware that we have unknowingly collected information about a child, in particular any child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

6. DATA SECURITY AND RETENTION

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee "perfect security." Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use insecure channels to send us sensitive or confidential information.

We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.

7. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Notice, please email us at support@otti.com.