Privacy Policy
Introduction
We, at OT App (the “Company”, “us”
or “we”) understand that you wish to keep your
personal information private and that you value our emphasis on
keeping your information safe and discrete. We respect your privacy
and are committed to protecting the privacy of our users
(“user” or “you”). This Privacy
Policy outlines our practices with respect to collecting, using, and
disclosing your information through your use of our websites,
applications, and other online platforms we use to provide our
services (collectively, “the Services”).
This Privacy Policy is a part of our Service Agreement and is
incorporated therein by references.
We encourage you to read the Privacy Policy carefully and use it to
make informed decisions. By using our Services, you agree to the
terms of this Privacy Policy and your continued use of the Services
constitutes your ongoing agreement to this Privacy Policy including
its updates.
Data usage
We may collect, use, store and transfer different kinds of personal
data about you and for different purposes. For your use, we made the
table with data categories, purposes of their use, and lawful bases
for processing.
|
Data type
|
Examples of information we may collect
|
Purposes of processing
|
Lawful bases for processing
|
|
Identity Data
|
First name, last name, and patronymic (if available), date
of birth, gender, passport, ID, driver’s license number, or
photo.
|
Account management, fraud prevention, security, compliance
with AML, CTF, and other applicable laws and regulations,
advertising, and personalization of user experience.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (to provide
effective and personalized customer services to you and to
update you in relation to our services that are available to
you, to perform web analytics and direct marketing).
|
|
Contact Data
|
Billing address, email address, and telephone numbers. |
Account management, application functionality, fraud
prevention, security, compliance with AML, CTF, and other
applicable laws and regulations, developer communications,
advertising, and personalization of user experience.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (to provide
effective and personalized customer services to you and to
update you in relation to our services that are available to
you, to maintain application functionality).
|
| Profile Data |
Your account details, User ID, username, and password, account
photo, your country’s national flag icon, your number in the
leaderboard, text showing your own position in the
leaderboard, status, which shows that you are online now, your
experience points and winning amount your interests,
preferences, feedback, and/or information received through
your interaction with us within the course of providing our
services and survey responses, e.g. in-app messages.
|
Account management, application functionality, analytics,
developer communications, advertising, including promotional
activities, and internal events; personalization of user
experience, fraud prevention, security, compliance with AML,
CTF, and other applicable laws and regulations.
|
1. Necessary to perform our contract with you, to provide
additional services to you, e.g. Social Signals Service.
2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (take reasonable
steps to confirm that you do not use any ways to manipulate
our platform & for running our business, provision of
administration and IT services, network security, to prevent
fraud; to provide effective and personalized customer
services to you and to update you in relation to our
services that are available to you, to perform web analytics
and direct marketing, to maintain application
functionality).
|
| Technical Data |
Internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in
type and versions, operating system and platform, and other
technologies on the devices you use to access the Website or
application and use of cookies stored on your device, other
identifiers that relate to your device (IMEI, MAC address,
advertising identifier, etc.).
|
Fraud prevention, security, compliance with AML, CTF, and
other applicable laws and regulations, app functionality and
development, advertising, analytics, and personalization of
our services.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (take reasonable
steps to confirm that you do not use any ways to manipulate
our platform & for running our business, provision of
administration and IT services, network security, to prevent
fraud; to provide effective and personalized customer services
to you and to update you in relation to our services that are
available to you, to perform web analytics and direct
marketing, to maintain application functionality).
|
| Usage Data |
Information about how you use the Website, applications,
products, and services, registration date, account category,
trading cluster, number of complaints, number of requests
files, and IP history, your application activity (app
interactions, your installed apps), application information
and performance (crash logs, diagnostics, other app
performance data),
|
Fraud prevention, security, compliance with AML, CTF, and
other applicable laws and regulations, mobile apps and website
functionality and development, personalization of our
services, analytics, and advertising.
|
1. Necessary to perform our contract with you.
2. Necessary for our legitimate interests (to provide
effective and personalized customer services to you and to
update you in relation to our services that are available to
you, to perform web analytics and direct marketing, and to
maintain application functionality).
|
|
Financial Data
|
Bank account and tax identification number (including but not
limited to social security number, income tax identification
number, and national insurance number).
|
Account management, provision of services, fraud prevention,
security, compliance with AML, CTF, and other applicable
laws, and regulation, and provision of services.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (reasonable steps to
confirm that you do not use any ways to manipulate our
platform & for running our business, provision of
administration and IT services, network security, to prevent
fraud).
|
|
Usage Data
|
Information about how you use the Website, products, and
services, registration date, account category, trading
cluster, number of complaints, number of request files, and
IP history.
|
Fraud prevention, security, compliance with AML, CTF, and
other applicable laws and regulations, mobile Apps and
website functionality and development, and personalization
of our services.
|
1. Necessary to perform our contract with you.
2. Necessary for our legitimate interests (to provide
effective and personalized customer services to you and to
update you in relation to our services that are available to
you.
|
|
Transaction Data & Purchase history
|
Details about the transactions performed by you, details about
payments, withdrawals, exchanges, trading and purchase
history, profit, balance, deposited and withdrawal amount
methods, and any other details in relation to the services you
have made use of through our Website and applications; ROI
metric (percentage of successful trades calculated for the
last 7 days); asset, direction, and duration of the trade for
users to copy it.
|
Account management, fraud prevention, security, compliance
with AML, CTF, and other applicable laws and regulations, and
personalization of user experience.
|
1. Necessary to perform our contract with you, to provide
additional services to you, e.g. Social Signals Service.
2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (take reasonable
steps to confirm that you do not use any ways to manipulate
our platform & for running our business, provision of
administration and IT services, network security, to prevent
fraud).
|
| Payment Data |
Details of the number of payment wallets and/or information of
your bank card, including information of the issuing bank,
card number, cardholder name, card expiration date, payment
system, card validation code (CVV2 / CVC2), and photos of both
sides of the bank card.
|
Fraud prevention, security, and compliance with AML, CTF, and
other applicable laws and regulations, provision of services,
account management, and personalization of user experience.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (to provide
effective and personalized customer services to you and to
update you in relation to our services that are available to
you).
|
| Economic Profile Data |
Details on occupation, the purpose of investment, annual
income, net wealth, the expected annual amount of
investment, and sources of funds.
|
Fraud prevention, security, and compliance with AML, CTF,
and other applicable laws and regulations, account
management.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
|
| KYC Data |
“Know your customer” data: identity document information,
including copies of recently dated utility bills, identity
card, passport, and/or driver’s license.
|
Fraud prevention, security, and compliance with AML, CTF, and
other applicable laws and regulations, account management.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
|
|
Special Categories of Data/ ‘Sensitive’ Data
|
Details about your annual income, biometric data, and/or
criminal convictions, and offenses.
|
Fraud prevention, security, and compliance with AML, CTF,
and other applicable laws and regulations.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
3. Consent.
|
| Conformity Data |
Details about your education, employment status, trading
experience, and self-assessment test.
|
Fraud prevention, security, and compliance with AML, CTF,
and other applicable laws and regulations, account
management.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
|
| Marketing and Communication Data |
Your preferences in receiving marketing from us and your
communication preferences.
|
Fraud prevention, security, compliance with AML, CTF, and
other applicable laws and regulations, marketing and product
analytics, personalization of our services, promotional
activities and internal events, and provision of services.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
3. Necessary for our legitimate interests (to provide
effective and personalized customer services to you and to
update you in relation to our services that are available to
you).
|
| Location Data |
Details on your actual location when interacting with our
Website (for example, a set of parameters that determine the
regional settings of your interface, namely residency
country, time zone, and the interface language).
NB: It is not relevant for iOS and Android applications.
|
Account management, fraud prevention, security, compliance
with AML, CTF, and other applicable laws and regulations,
developer communications, and personalization of our services.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligations.
|
|
Audio and Video Data
|
Full audio or video recordings of calls that you receive
from us or make to us.
NB: It is not relevant for iOS and Android applications.
|
Account management, fraud prevention, security, and compliance
with AML, CTF, and other applicable laws and regulations,
developer communications, promotional activities and events,
and provision of client support services.
|
1. Necessary to perform our contract with you.
2. Necessary to comply with our legal obligation.
|
We process the aforementioned data in compliance with the applicable
laws and regulations as amended from time to time in order to:
(i) Be able to perform our contractual obligations towards
the Clients and offer them the best possible service.
(ii) Provide our Services efficiently.
(iii) Comply with our legal obligations, including, inter
alia, fraud prevention, anti-money laundering, and terrorist financing
laws, regulations, and recommendations of FATF.
(iv) Protect our legitimate interests and your vital
interests.
Personal data is processed based on the following legal bases:
1. Compliance with applicable laws and regulations.
2. Performance of contractual obligations towards the
Clients.
3. Safeguarding our legitimate interests and your interests
and fundamental rights do not override those interests.
4. On the basis of the Client’s consent.
Please note that applicable laws and regulations require us to store
some categories of data after termination of the Service Agreement or
deletion of your account. More details are provided in the account
deletion section hereof.
Leaderboards
You hereby acknowledge and agree to become part of the network and
share your trading strategies and results. You authorise us to
disclose your personal data (your name, experience points and winning
amount, etc.) for the leaderboards on the platform. You authorize us
to produce signals resulting from your trades, disclose generalised
information about them, and you agree that other users will be able to
copy your successful trades if you are included in the leaderboard on
the platform.
In accordance with the principles of data minimisation and purpose
limitation the processing of personal data for this purpose is limited
only to the following:
• Profile data: name (User ID, if there is
no name), your country’s national flag icon, photo (optional), your
number in the leaderboard, text showing your own position in the
leaderboard (you); status, which shows that you are online now, your
experience points and winning amount;
• Transaction data: ROI metric (percentage
of successful trades calculated for the last 7 days); asset, direction
and duration of your trade for users to copy it.
Please note that the amount of your trades is never publicly
disclosed. Only the ROI metric, which is based on the total percentage
of trades (successful and unsuccessful) from which the percentage of
successful trades is deducted, is crucial for inclusion in the
leaderboard.
The processing covers the following activities: collection, recording,
organisation, structuring, storage, adaptation or alteration,
retrieval, use, disclosure, transfer (including cross-border transfer,
where necessary), alignment or combination, restriction, erasure and
destruction.
You have the right to change your privacy settings at any time and
make your trading activity fully private by clicking "Settings" >
"Privacy".
Cookies and other tracking technologies
We and our trusted partners use cookies and other technologies in our
related services, including when you visit our site or access our
Services. A "cookie" is a small piece of information that a website
assigns to your device while you are viewing a website. Cookies are
very helpful and can be used for various different purposes. These
purposes include allowing you to navigate between pages efficiently,
enable automatic activation of certain features, remembering your
preferences, and making the interaction between you and our Services
quicker and easier. Cookies are also used to help ensure that the
advertisements you see are relevant to you and your interests and to
compile statistical data on your use of our Services.
Our website uses the following types of cookies:
a) "Session cookies" are stored only temporarily during a
browsing session in order to allow normal use of the system and are
deleted from your device when the browser is closed.
b) "Persistent cookies" are read-only by our website, saved
on your computer for a fixed period, and are not deleted when the
browser is closed. Such cookies are used where we need to know who you
are for repeat visits, for example, to allow us to store your
preferences for the next sign-in.
c) "Third-party cookies" are set by other online services who
run content on the page you are viewing, for example by third-party
analytics companies who monitor and analyze our web access.
Cookies do not contain any information that personally identifies you,
but Personal Information that we store about you may be linked, by us,
to the information stored in and obtained from cookies. You may remove
the cookies by following the instructions of your device preferences;
however, if you choose to disable cookies, some features of our
Service may not operate properly and your online experience may be
limited.
With whom we share the information we collect
We do not rent, sell, or share your Personal and/or Corporate
Information with third parties except as described in this Privacy
Policy.
We may transfer or disclose Personal Information to our
subsidiaries, and other
affiliated companies. In addition, your Personal
Information may be disclosed to other trusted
third-party service providers or
partners for the purpose of:
(i) Authenticating your identity and verifying your account
details.
(ii) Storing or processing Personal Information on our behalf
(e.g. cloud computing service providers).
(iii) Assisting us with our business operations, providing
our Services, and improving them.
(iv) Performing research, technical diagnostics, and
analytics with regard to the Services.
(v) Communicating promotional and informational materials, in
accordance with our marketing policy (see below under
“Marketing”).
We may disclose personal information or any information you submitted
via the Services if we have a good faith belief that disclosure of
such information is helpful or reasonably necessary to:
(i) Comply with any applicable law, regulation, legal
process, or governmental request.
(ii) Enforce our policies (including our Agreement),
including investigations of potential violations thereof.
(iii) Investigate, detect, prevent, or take action regarding
illegal activities or other wrongdoing, suspected fraud, or security
issues.
(iv) Establish or exercise our rights to defend against legal
claims.
(v) Prevent harm to the rights, property, or safety of us,
our users, yourself, or any third party.
(vi) For the legitimate purposes below:
- To serve your advertisements when you use our Services.
- To perform research or conduct anonymous analytics in order
to improve and customize our Services to your needs and interests.
- To support and troubleshoot our Services and respond to
your queries.
- To investigate violations and enforce our policies, as
required by law, regulation, or other governmental authority, or to
comply with a subpoena or similar legal process, or respond to a
government request.
- To monitor transactions for the purposes of preventing
fraud, money laundering, and cheating.
- For enforcement agencies and/or in case we find it
necessary in order to enforce intellectual property or other legal
rights.
Any third party with whom we may share user data will provide the same
or equal protection of user data as stated in this privacy policy.
Third-party collection of information
Our policy only addresses the use and disclosure of information we
collect from you. To the extent that you disclose your information to
other parties via our Services (e.g. by clicking on a link to another
website or application) or via other sites or applications, different
rules may apply to their use or disclosure of the information you
disclose to them.
It is important to note that such third-party services may have their
own privacy policies and we advise you to read them carefully. The
inclusion of a link to a third-party website, application, or service
is not a recommendation of such a website or service. Third-party
sites may contain information or service that is illegal,
unreasonable, or that some people may find inappropriate or offensive.
Before using third-party sites, applications or services, we recommend
you to read and understand those sites' and services' terms and
conditions, warranty, and privacy policies and to ensure you agree to
their terms. You acknowledge that we are not responsible for the
products, services, or descriptions of those products or services that
you receive from third-party sites or applications or to the content
or privacy practices of those sites and that this Privacy Policy does
not apply to any such third party products and services. You are
knowingly and voluntarily assuming all risks of using third-party
sites or applications to purchase products and services. You agree
that we shall have no liability whatsoever with respect to such
third-party sites, applications, or services and your usage of them.
We also use a tool called “Google Analytics” to collect information
about your use of the Services. Google Analytics collects information
such as how often users access the Services, what pages they visit
when they do so, etc. We use the information we get from Google
Analytics only to improve our Services. Google Analytics collects the
IP address assigned to you on the date you visit sites, rather than
your name or other identifying information. We do not combine the
information collected through the use of Google Analytics with
personally identifiable information. Google’s ability to use and share
information collected by Google Analytics about your visits to this
site is restricted by the Google Analytics Terms of Use and the Google
Privacy Policy.
Advertisements
We may use advertising technology to serve advertisements (including
targeted ads) when you use our Services. We may also use third parties
and share with them Non-personal Information to assist us in
evaluating the success of our advertising campaigns and help us
retarget our users.
You may opt-out of many third-party ad networks, including those
operated by members of the Network Advertising Initiative
(“NAI”) and the Digital Advertising Alliance
(“DAA”). For more information regarding this practice
by NAI members and DAA members, and your choices regarding having this
information used by these companies, including how to opt-out of
third-party ad networks operated by NAI and DAA members, please visit
their respective websites:
www.networkadvertising.org/optout_nonppii.asp and
www.aboutads.info/choices.
Personal data deletion and rectification requests
You have the right to obtain from us the rectification of inaccurate
personal data, and therefore you may, at any time, request to change
and update your personal data by emailing us at
privacy-asia@otapp.site.
You can also request that we will correct errors or that we will
delete your personal data (except for your transaction history and
other data that we are required to keep under applicable laws) by
emailing us at privacy-asia@otapp.site.
The deletion or rectification requests can be sent to us in a free
form (in the body of a letter, scan, etc.) to privacy-asia@otapp.site
with your full name and contact information for a quicker processing
of your request. If we are not satisfied you are who you claim to be,
we reserve the right to refuse to grant your requests.
Please note that personal data is deleted by default when we no longer
have a legitimate purpose for the continued processing or storage of
personal data, or when personal data is no longer required to be
stored in accordance with applicable legal requirements.
Unless you instruct us otherwise, we retain the information we collect
for as long as needed to provide the Services and to comply with our
legal obligations, resolve disputes and enforce our agreements. We may
rectify, replenish or remove incomplete or inaccurate information, at
any time and at our own discretion.
Safeguarding and transferring your information
We take great care in implementing and maintaining the security of the
Services we offer, and your information. We employ industry-standard
procedures and policies to ensure the safety of our users' information
and prevent unauthorized use of any such information. Although we take
all reasonable steps to safeguard information, we cannot be
responsible for the acts of those who gain unauthorized access or
abuse our Services, and we make no warranty, express, implied, or
otherwise, that we will prevent such access.
If you feel that your privacy was treated not in accordance with our
policy, or if any person attempted to abuse our Services or acted in
an inappropriate manner, please contact us directly at
privacy-asia@otapp.site.
Marketing
We may use your Personal Information, such as your name, email
address, telephone number, etc. ourselves or
by using our third-party subcontractors for the
purpose of providing you
with promotional materials, concerning our Services, as well as
products, services, websites, and applications
which relate to
our business partners and affiliates (collectively:
“Marketing Affiliates”), which we believe may
interest you.
We may also share and disclose Personal Information with our
Marketing Affiliates for the purpose of providing you
with different marketing offers we or our
Marketing Affiliates believe are relevant for you.
Out of respect to your right to privacy, we provide you with such
marketing materials with the means to decline receiving further
marketing offers from us or from our Marketing Affiliates. In
addition, at any time, you may request to
unsubscribe and discontinue receiving marketing offers
by sending a blank message with the word "remove" to
privacy-asia@otapp.site.
If you unsubscribe we will remove your email address from our
marketing distribution lists and from any future lists we may share
with our Marketing Affiliates. However, you may need to separately
unsubscribe from marketing offers sent by our Marketing Affiliates.
Please note that even if you unsubscribe from our marketing mailing
list, we may continue to send you service-related updates and
notifications.
You hereby acknowledge and agree that by downloading, installing,
or accessing our Services, we may share your Personal Information
with our trusted partners and Marketing Affiliates for the purpose
of direct marketing.
Corporate transaction
We may share Information, including Personal Information, in the event
of a corporate transaction (e.g. sale of a substantial part of our
business, merger, database migration, consolidation, or asset sale of
an asset or transfer in the operation thereof) of the Company. In the
event of the above, the acquiring company or transferee will assume
the rights and obligations as described in this Privacy Policy.
Account deletion
Any Client may delete its Client account by means of the user
interface within the mobile Apps on Android and iOS or by means of
making a client support request. Provided that applicable laws and
regulations prohibit us from deletion of personal data, the Client
hereby acknowledges that in case of the account deletion the Company
will store necessary personal data, as specified in the data usage
part hereof, in order to comply with applicable laws and regulations
and prevent fraudulent actions and platform manipulations and other
dishonest actions for the term specified in the applicable laws,
regulations, and recommendations. The Company will take all reasonable
actions in order to secure data minimization and anonymization. The
Company will cease using the Client’s personal data for any other
purposes that are not specified in the present abstract, including
advertising and marketing purposes, upon account deletion.
Updates or amendments to the Privacy Policy
We may revise this Privacy Policy from time to time, at our sole
discretion, and the most current version will always be posted on the
website. We encourage you to review this Privacy Policy regularly for
any changes.
Registration and Authorisation
Information about the company:
Aollikus Limited.
Registered number: 40131
Address: 1276, Govant Building, Kumul Highway, Port Vila, Republic of
Vanuatu
How to Contact Us
If you have any general questions about the Services or the
information that we collect about you and how we use them, please
contact us at privacy-asia@otapp.site.