Oto Privacy Policy

PRIVACY POLICY

Last updated [31/03/2023]

Thank you for choosing to be part of Our community at Oto Health Ltd, doing business as Oto ("Oto", "We", "Us", "Our") – registered company number 12231154.  We are committed to protecting Your personal information and Your right to privacy.  If You have any questions or concerns about this Privacy Policy, or Our practices with regards to Your personal information, please contact Us at hello@joinoto.com.

When You visit Our website https://www.joinoto.com (the "Website"), use Our mobile application, as the case may be (the "App") and more generally, use any of Our services (the "Services", which may be via the Website or the App), We appreciate that You are trusting Us with Your personal information.  We take Your privacy very seriously.  In this Privacy Policy, We seek to explain to You in the clearest way possible what information We collect, how We use it and what rights You have in relation to it.  We hope You take some time to read through it carefully, as it is important.  If there are any terms in this Privacy Policy that You do not agree with, please discontinue use of Our Services immediately.

This Privacy Policy applies to all information collected through Our Services (which, as described above, includes Our Website and App), as well as, any related services, sales, marketing or events.

Please read this Privacy Policy carefully as it will help You understand what We do with the information that We collect.

You give Your express consent to Us using Your personal data as set out in this Privacy Policy.

TABLE OF CONTENTS

1.  WHAT INFORMATION DO WE COLLECT?

2.  HOW DO WE USE YOUR INFORMATION?

3.  WHAT ARE THE REASONS FOR PROCESSING YOUR INFORMATION?

4.  WHO WILL YOUR INFORMATION BE SHARED WITH?

5.  DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6.  HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7.  HOW LONG DO WE KEEP YOUR INFORMATION?

8.  HOW DO WE KEEP YOUR INFORMATION SAFE?

9.  DO WE COLLECT INFORMATION FROM MINORS?

10.  WHAT ARE YOUR PRIVACY RIGHTS?

11.  CONTROLS FOR DO-NOT-TRACK FEATURES

12.  DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

13.  HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

14.  HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

In this privacy policy, what We collect under sections 1.1 to 1.4 is described as ‘Personal Information’ under section 1.5 as ‘Special Data’, and under sections 1.1 to 1.5 collectively as ‘Information’.

1.1 Personal information 

In Short:  We collect personal information that You provide to us.

We collect personal information that You voluntarily provide to Us when You register on the Services, express an interest in obtaining information about Us or Our products and Services, when You participate in activities on the Services or otherwise when You contact Us.

The personal information that We collect depends on the context of Your interactions with Us and the Services, the choices You make and the products and features You use.  The personal information We collect may include the following:

1.2 Personal Information Provided by You

We collect names; email addresses; usernames; passwords; contact preferences; contact or authentication data; and other similar information.

• Payment Data.  We may collect data necessary to process Your payment if You make purchases, such as Your payment instrument number (such as a credit card number), and the security code associated with Your payment instrument.  All payment data is stored by Apple, Google and Stripe. You may find their privacy notice link(s) here: https://www.apple.com/legal/privacy/e… and https://policies.google.com/privacy?hl=en-US.
• Single Sign on Login Data.  We may provide You with the option to register with Us using Your existing social media account details, like Your Facebook, Twitter or other social media account or Google.  If You choose to register in this way, We will collect the information described in the section called "HOW DO WE HANDLE YOUR LOGINS?" below.

All personal information that You provide to Us must be true, complete and accurate, and You must notify Us of any changes to such personal information.

1.3 Information automatically collected

In Short:  Some information — such as Your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when You visit Our Services.

We automatically collect certain information when You visit, use or navigate the Services.  This information does not reveal Your specific identity (like Your name or contact information) but may include device and usage information, such as Your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when You use Our Services and other technical information.  This information is primarily needed to maintain the security and operation of Our Services, and for Our internal analytics and reporting purposes.

Like many businesses, We also collect information through cookies and similar technologies.

The information We collect includes:

• Log and Usage Data.  Log and usage data is service-related, diagnostic, usage and performance information Our servers automatically collect when You access or use Our Services and which We record in log files.  Depending on how You interact with us, this log data may include Your IP address, device information, browser type and settings and information about Your activity in the Services (such as the date/time stamps associated with Your usage, pages and files viewed, searches and other actions You take such as which features You use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
• Device Data.  We collect device data such as information about Your computer, phone, tablet or other device You use to access the Services.  Depending on the device used, this device data may include information such as Your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
• Location Data.  We collect location data such as information about Your device's location, which can be either precise or imprecise.  How much information We collect depends on the type and settings of the device You use to access the Services.  For example, We may use GPS and other technologies to collect geolocation data that tells Us Your current location (based on Your IP address).  You can opt out of allowing Us to collect this information either by refusing access to the information or by disabling Your Location setting on Your device.  Note however, if You choose to opt out, You may not be able to use certain aspects of the Services.

1.4 Information collected through Our App

In Short:  We collect information regarding Your geolocation, mobile device, push notifications, when You use Our App.

If You use Our App, We also collect the following information:

• Geolocation Information.  We may request access or permission to and track location-based information from Your mobile device, either continuously or while You are using Our App, to provide certain location-based services.  If You wish to change Our access or permissions, You may do so in Your device's settings.
• Mobile Device Access.  We may request access or permission to certain features from Your mobile device, including Your mobile device's storage, and other features.  If You wish to change Our access or permissions, You may do so in Your device's settings.
• Mobile Device Data.  We automatically collect device information (such as Your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model and Internet Protocol (IP) address (or proxy server).  If You are using Our App, We may also collect information about the phone network associated with Your mobile device, Your mobile device’s operating system or platform, the type of mobile device You use, Your mobile device’s unique device ID and information about the features of Our App You accessed.
• Push Notifications.  We may request to send You push notifications regarding Your account or certain features of the App.  If You wish to opt-out from receiving these types of communications, You may turn them off in Your device's settings.

This information is primarily needed to maintain the security and operation of Our App, for troubleshooting and for Our internal analytics and reporting purposes.

1.5 Special Data

In short:  We collect information regarding Your personal health to enable You to benefit from the Services.

We may collect the following Special Data to understand how tinnitus is affecting Your life and to provide You with personalised Services:

• The intensity of how Your tinnitus is affecting Your (i) sleep, (ii) ability to focus Your attention or to concentrate (iii) ability to think clearly, (iv) hearing (v) ability to relax, enjoy social life or to perform at work, 
• tinnitus frequency 
• perceived tinnitus volume
• the effectiveness of different sounds on management of Your condition
• consideration of your requirements and applicability for Our 1-1 Therapy Package
• How You are coping with tinnitus and whether You believe it has caused You anxiety or depression.

We may process this personal information as follows:

• to create, track and display Your tinnitus profile
• to suggest information that may help manage Your tinnitus recommended sessions
• to suggest sounds that may help manage Your tinnitus recommended sounds
• to track and display Your habituation progress
• to share it with therapists in relation to their provision of appointments through Our 1-1 Therapy Program

2. HOW DO WE USE YOUR INFORMATION?

In Short:  We process Your information for purposes based on legitimate business interests, the fulfilment of Our contract with You, compliance with Our legal obligations, and/or Your consent.

We use Information collected via Our Services for a variety of business purposes described below.  We process Your Information for these purposes in reliance on Our legitimate business interests, in order to enter into or perform a contract with You, with Your consent, and/or for compliance with Our legal obligations.  We indicate the specific processing grounds We rely on next to each purpose listed below.

We use the Information We collect or receive:

• To facilitate account creation and logon process.  If You choose to link Your account with Us to a third-party account (such as Your Google or Facebook account), We use the information You allowed Us to collect from those third parties to facilitate account creation and logon process for the performance of the Services.  See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" for further information.
• To facilitate the 1-1 Therapy Program services.  We use Your information to book appointments with Our audiologists as part of the 1-1 Therapy Package.  Our audiologists will normally be external consultants under a contract with Us.
• To post testimonials.  We post testimonials on Our Services that may contain personal information.  Prior to posting a testimonial, We will obtain Your consent to use Your name and the content of the testimonial.  If You wish to update, or delete Your testimonial, please contact Us at george@joinoto.com and be sure to include Your name, testimonial location, and contact information.
• Request feedback.  We may use Your information to request feedback and to contact You about Your use of Our Services.
• To enable user-to-user communications.  We may use Your information in order to enable user-to-user communications with each user's consent.
• To manage user accounts.  We may use Your information for the purposes of managing Our account and keeping it in working order.
• To send administrative information to You.  We may use Your personal information to send You product, service and new feature information and/or information about changes to Our terms, conditions, and policies.
• To protect Our Services.  We may use Your information as part of Our efforts to keep Our Services safe and secure (for example, for fraud monitoring and prevention).
• To enforce Our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with Our contract.
• To respond to legal requests and prevent harm.  If We receive a subpoena or other legal request, We may need to inspect the data We hold to determine how to respond.
• Fulfil and manage Your orders.  We may use Your information to fulfil and manage Your orders, payments, returns, and exchanges made through the Services.
• To deliver and facilitate delivery of Services to the user.  We may use Your information to provide You with the requested service.
• To respond to user inquiries/offer support to users.  We may use Your information to respond to Your inquiries and solve any potential issues You might have with the use of Our Services.
• To send You marketing and promotional communications.  We and/or Our third-party marketing partners may use the personal information You send to Us for Our marketing purposes, if this is in accordance with Your marketing preferences.  For example, when expressing an interest in obtaining information about Us or Our Services, subscribing to marketing or otherwise contacting us, We will collect personal information from You.  You can opt-out of Our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS?" below).
• Deliver targeted advertising to You. We may use Your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to Your interests and/or location and to measure its effectiveness.
• For research purposes and to improve the Services offered to You.  These research activities may include gathering information You are sharing with Us such as Your daily therapies, time of listening the therapies, sleep sound, therapy sessions, masking volume, pitch, sleeping routine, therapy background, Your progress, etc.  

3. WHAT ARE THE REASONS FOR PROCESSING YOUR INFORMATION?

In Short:  We only process information with Your consent, to comply with laws, to provide You with Services, to protect Your rights, or to fulfil business obligations.

We may process or share Your data that We hold based on the following legal basis:

• Consent: We may process Your data if You have given Us specific consent to use Your personal information and explicit consent to use Your Special Data for the purposes mentioned at section 2 above.
• Legitimate Interests: We may process Your data when it is reasonably necessary to achieve Our legitimate business interests.
• Performance of a Contract: Where We have entered into a contract with You, We may process Your personal information to fulfil the terms of Our contract and provide You the Services.
• Legal Obligations: We may disclose Your information where We are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose Your information where We believe it is necessary to investigate, prevent, or take action regarding potential violations of Our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which We are involved.

More specifically, We may need to process Your data or share Your personal information in the following situations:

• Business Transfers.  We may share or transfer Your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of Our business to another company.
• Vendors, Consultants and Other Third-Party Service Providers.  We may share Your data with third-party vendors, service providers, audiologists, contractors or agents who perform services for Us or on Our behalf and require access to such information to do that work.  Examples include: payment processing, data analysis, email delivery, hosting services, provide therapy sessions, customer service and marketing efforts.  We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on Our behalf about how You interact with Our Services over time.  This information may be used to, among other things, analyse and track data, determine the popularity of certain content, pages or features, and better understand online activity.  Unless described in this Privacy Policy, We do not share, sell, rent or trade any of Your information with third parties for their promotional purposes.  We have contracts in place with Our data processors, which are designed to help safeguard Your personal information.  This means that they cannot do anything with Your personal information unless We have instructed them to do it.  They will also not share Your personal information with any organization apart from us.  They also commit to protect the data they hold on Our behalf and to retain it for the period We instruct.
• Business Partners.  We may share Your information with Our business partners to offer You certain products, services or promotions.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?     

In Short:  We only share information with the following third parties.

We only share and disclose Your information with the following third parties.  If We have processed Your data based on Your consent and You wish to revoke Your consent, please contact Us using the contact details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?".

• Advertising, Direct Marketing, and Lead Generation

Intercom

• Communicate and Chat with Users

Intercom

• Content Optimization

Typeform embed

• Functionality and Infrastructure Optimization

Cloud Functions for Firebase, Cloud Storage for Firebase, Firebase Hosting, Termly.io, Google Cloud Storage and Google App Engine

• Subscription Management

RevenueCat,

• Invoice and Billing

Apple;  Google and Stripe

• Retargeting Platforms

Google Analytics Remarketing, Google Ads Remarketing, Twitter Tailored Audiences and Twitter Remarketing

• Therapy Sessions as part of the 1-1 Therapy Package

Our accredited audiologists.  Our audiologists will normally be external consultants under a contract with Us.

• User Account Registration and Authentication

Facebook Login, Firebase Authentication, Google Sign-In and Apple ID

• Web and Mobile Analytics

Google Ads, Google Analytics, Google Analytics for Firebase, TestFlight and Twitter Ads conversion tracking

• Website Hosting

Webflow

• Website Performance Monitoring

Firebase Crash Reporting and Firebase Performance Monitoring

• Website Testing

Google Play Console, Google Website Optimizer, Firebase Remote Config and TestFlight

• Automation

Zapier

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:  We may use cookies and other tracking technologies to collect and store Your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.  Specific information about how We use such technologies and how You can refuse certain cookies is set out in Our Cookie Policy which can be found at: [please insert link].

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?     

In Short:  If You choose to register or log in to Our services using a social media account, We may have access to certain information about You.

Our Services offers You the ability to register and login using Your third-party social media account details (like Your Facebook or Google logins).  Where You choose to do this, We will receive certain profile information about You from Your social media provider.  The profile information We receive may vary depending on the social media provider concerned, but will often include Your name, email address, friends list, profile picture as well as other information You choose to make public on such social media platform.

We will use the information We receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to You on the relevant Services.  Please note that We do not control, and are not responsible for, other uses of Your personal information by Your third-party social media provider.  We recommend that You review their privacy policies to understand how they collect, use and share Your personal information, and how You can set Your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep Your information for as long as necessary to fulfil the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep Your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, regulatory or other legal requirements).  No purpose in this Policy will require Us keeping Your personal information for longer than the period of time in which users have an account with us.

When We have no ongoing legitimate business need to process Your personal information, We will either delete or anonymise such information, or, if this is not possible (for example, because Your personal information has been stored in backup archives), then We will securely store Your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:  We aim to protect Your personal information through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information We process.  However, despite Our safeguards and efforts to secure Your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat Our security, and improperly collect, access, steal, or modify Your information.  Although We will do Our best to protect Your personal information, transmission of personal information to and from Our Services is at Your own risk.  You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

The Site is intended for users who are at least 18 years old.  If You are under the age of 18, You are not permitted to register in Your own name for the Site or use the Services.  Only Your parent or guardian is allowed to register and create an account.  You can only use Our Services with Your parent/guardian permission and through their guided use.

If it comes to Our attention that personal information from users under 18 years has been collected, We will deactivate the account and take reasonable measures to promptly delete such data from Our records.  If You become aware of any data We may have collected from children under age 18, please contact Us at support@joinoto.com.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), You have rights that allow You greater access to and control over Your personal information.  You may review, change, or terminate Your account at any time.

In some regions (like the EEA and UK), You have certain rights under applicable data protection laws.  These may include the right (i) to request access and obtain a copy of Your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of Your personal information; and (iv) if applicable, to data portability.  In certain circumstances, You may also have the right to object to the processing of Your personal information.  To make such a request, please use the contact details provided below.  We will consider and act upon any request in accordance with applicable data protection laws.

If We are relying on Your consent to process Your personal information, You have the right to withdraw Your consent at any time by sending an e-mail at support@joinoto.com.  Your request should clearly state the information for which withdrawal is requested.  Please note that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of Your personal information conducted in reliance on lawful processing grounds other than consent.  If Your withdrawal refers to Your Special Data, please note that We will not be able to provide the Services to You and this may lead to the termination of Your account.  

If You have questions or comments about Your privacy rights, You may email Us at support@joinoto.com.

Account Information

If You would at any time like to review or change the information in Your account or terminate Your account, You can:

• Log in to Your account settings and (i) update Your user account or (ii) delete Your account.
• Contact Us using the contact information provided.

Upon Your request to terminate Your account, We will deactivate or delete Your account and information from Our active databases.  

Cookies and similar technologies: Most Web browsers are set to accept cookies by default.  If You prefer, You can usually choose to set Your browser to remove cookies and to reject cookies.  If You choose to remove cookies or reject cookies, this could affect certain features or services of Our Services.  To opt-out of interest-based advertising by advertisers on Our Services visit http://www.aboutads.info/choices/.

Opting out of email marketing:  You can unsubscribe from Our marketing email list at any time by clicking on the unsubscribe link in the emails that We send or by contacting Us using the details provided below.  You will then be removed from the marketing email list — however, We  may still communicate with You, for example to send You service-related emails that are necessary for the administration and use of Your account, to respond to service requests, or for other non-marketing purposes.  To otherwise opt-out, You may:

• Access Your account settings and update Your preferences.
• Contact Us using the contact information provided.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting You can activate to signal Your privacy preference not to have data about Your online browsing activities monitored and collected.  At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalised.  As such, We do not currently respond to DNT browser signals or any other mechanism that automatically communicates Your choice not to be tracked online.  If a standard for online tracking is adopted that We must follow in the future, We will inform You about that practice in a revised version of this Privacy Policy.  

12. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?     

In Short:  Yes, We will update this Privacy Policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time.  The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible.  If We make material changes to this Privacy Policy, We may notify You either by prominently posting a notice of such changes or by directly sending You a notification.  We encourage You to review this Privacy Policy frequently to be informed of how We are protecting Your Information.

13. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?     

If You have questions or comments about this Privacy Policy, You may contact Our Data Protection Officer (DPO), George Leidig, by email at george@joinoto.com, by phone at 07411359486, or by post to:

Oto Health Ltd

George Leidig

4th Floor Silverstream House

45 Fitzroy Street

London, England W1T 6EB

United Kingdom

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?     

You may have the right to request access to the personal information We collect from You, change that information, or delete it in some circumstances.  Please revisit Part 10 ‘WHAT ARE YOUR RIGHTS?’ for more details.  To request to review, update, or delete Your personal information, please visit: support@joinoto.com.