OTAcademy takes your privacy seriously. The following privacy notice is intended to provide you (meaning any of our actual or potential students, suppliers, individuals that browse our websites and individuals outside our organisation with whom we interact) detailed information about the privacy of your information and how it's secured on Otacademy.com and our community site at otacademy.com and our App (the "Site(s) and the Service") and any other websites owned and operated by OTA Franchise Corporation (together "We" and "Us") and sets out how we collect and process your personal information. This privacy notice also provides certain information that is legally required and lists your rights in relation to your personal information. Personal information is information that identifies an individual. This Privacy Notice is not intended to apply to personal information collected during the recruitment of employees, for which there is a separate privacy notice.
If you are in the UK then your data controller under relevant data protection legislation is Redahead Ltd trading as OTAcademy UK (company number 05932913) whose registered address is at Ver House Park, Industrial Estate, Frogmor, St. Albans, Hertfordshire, England, AL2 2WH and references to we and us in this Privacy Notice includes Redahead Ltd (as applicable). If you are in the UK then we are processing your personal information for and on behalf of Redahead Ltd as Redahead Ltd’s processor. If you are outside the UK but elsewhere in the EU then your data controller will be OTA Franchise Corporation 17780 Fitch, Suite 200 Irvine, CA 92614. See below for how to contact us.
We reserve the right to change this Privacy Notice at any time. Such changes, modifications, additions or deletions shall be effectively immediately upon notice thereof, which may be given by means including, but not limited to, issuing an email to the email address listed by registered users and posting the revised Notice on this page. You acknowledge and agree that it is your responsibility to maintain a valid email address as a registered user, review this site and this Notice periodically and to be aware of any modifications.
Further, each time you use our Site(s) and/or the Service you acknowledge our processing of your information as set forth in this Privacy Notice now and as amended by us. "Processing" means using cookies on a computer or using information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States.
The OTA Franchise Corporation and our service providers may be, located in the United States. You acknowledge that if you reside outside the U.S., your personally identifiable information will be transferred to the U.S., and processed and stored there under U.S. privacy standards. If you reside in the UK then in connection with such transfers the relevant safeguard in place is the standard data protection contractual clauses between us and Redahead Ltd a copy can be obtained by contacting us using the contact details set out in below. Each time you utilize the Site(s) and /or the Service and are providing information to us, you acknowledge such transfer to, and processing in, the U.S. and you acknowledge that the governments, courts or law enforcement or regulatory agencies in the U.S. may be able to obtain disclosure of that personal information through U.S. laws.
If you have any questions or comments about this Privacy Notice or our use of your personally identifiable information, please contact our privacy officer at email@example.com or by calling us toll-free at (866) 939-4958 or outside the U.S. at 011-949-608-7424 Or you can contact our representative in the UK, Redahead Ltd as follows:01727 871860.
Why do we gather information?
We gather, use and disclose information that allows us to: provide and administer the products and services that you request and enrolling you in programs you request and communicating with you about your use of our products and services; provide you the optimal experience with the Site(s) and the Service and to help us better understand what products and services you're most interested in.
We also collect your personal information to communicate with you and to manage your User account if you have one. To do this, we collect information that helps us understand your needs and preferences.
We will only use or disclose your personal information for the purposes set out in this notice and as otherwise authorized or required by law.
What type of information do we collect and how is it used?
The contact information we collect comes directly from you.
- A first and last name.
- A home or other physical address, including, street name and name of a city or town.
- An e-mail address.
- A telephone or cellphone/mobile number.
- Information collected via "cookies." See below concerning your use of our web site and online services.
We may collect this information when you register in our community at otacademy.com, complete an OTAcademy Membership registration form, sign-up for a Free Half-Day Class, purchase audio or video content from us, or fill out any other form on any of the Site(s) or through the Service or provide such information to one of our Educational Counselors or Instructors. We may also collect information that you provide about others, such as through a refer-a-friend program or on a friend/spouse who may be attending a class or workshop with you.
If you provide information to us about someone else you must ensure that you are entitled to disclose that information to us and that, without our taking any further steps, we may collect, use and disclose that information as described in this notice. You must also ensure the individual concerned is aware of the various matters detailed in this privacy notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal information and our personal information disclosure practices, that individual's right to obtain access to the personal information and make complaints about the handling of the personal information and the consequences if the personal information is not provided.
If you provide us with your postal address, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by sending us an email at firstname.lastname@example.org or by calling us toll-free at (866) 939-4958 or outside the U.S. at 011-949-608-7424 or if in the UK at 01727 871860.
Except as specified for the efficiency of use of the community site at otacademy.com, when you initially provide your contact information to us you will be given the choice of receiving periodic email communications from us or opting out of email communications. If you initially consented to receiving emails from us but would now like to change your preference, please let us know by sending us an email at email@example.com or by calling us toll-free at (866) 939-4958 or outside the U.S. at 011-949-608-7424 or if in the UK at 01727 871860.
Persons who supply us with their telephone numbers may receive telephone contact from us with information regarding new products and services or upcoming events. If you do not wish to receive phone calls from us in the future, please let us know by sending us an email at firstname.lastname@example.org or by calling us toll-free at (866) 939-4958 or outside the U.S. at 011-949-608-7424 or if in the UK at 01727 871860.
Community. Users who register for our community website at otacademy.com may receive announcements and administrative messages via email and other types of direct messages as part of this service. These communications are part of the community service and you may not be able to opt-out of receiving them. If you register for membership at the community website, by default your full user name and your profile image (if you elect to provide one) will be visible to other visitors and members of the community site. You may edit your privacy setting to make this information available only with other members you choose to connect with ("Friends").
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you and we have a legitimate interest in the providing (or in the case of the UK, assisting Redahead Ltd to provide) goods and services to you.
We also have a legitimate interest in promoting our business and to use your personal information in such a way to ensure that we provide the very best customer service we can to you.
Fulfillment of services.
We collect and maintain personal information that is voluntarily submitted to us during the use of the Sites and/or our Services. We use the contact details which are provided to us so that we can fulfil the supply of services which have been ordered from our Sites. We will use contact information to send you service related communications relating to these orders. This includes your purchase of services, your attendance at events hosted by us (including Redahead Ltd if you are in the UK) and the processing of returns and refunds. We do not store your payment details and all payments you make to us are done via our suppliers of payment processing services.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.
Business administration and legal compliance.
We use your personal information for the following business administration and legal compliance purposes:
- to comply with our legal obligations;
- to protect our business and your accounts from fraud and other illegal activities
- to enforce our legal rights;
- protect rights of third parties; and
- in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.
We will only use your location data for customer insight purposes where we have your consent to do so.
Do we share information collected with other third parties?
Again, we take your privacy very seriously and are committed to keeping your information safe and secure. We do not sell, license, lease or otherwise disclose your personal information to any third party for any reason except as noted earlier and as described below:
Your personal information may be disclosed to:
- our group companies, and affiliates or third-party processors, agents or contractors who assist in providing support for our internal operations and who may process data on our behalf to enable us to carry out our usual business practices. We will take reasonable steps to ensure that agents or contractors adhere to privacy procedures and will keep your personal information confidential;
- Redahead Ltd (if you are in the UK) as your data controller;
- our PR agency and provider of our customer feedback;
- providers of payment services (such as Authorize.net and Nop Commerce);
- relevant tax authorities in either the US or the UK (as applicable), legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
- external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
- law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
- third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
- third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation);
- third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website which you choose to interact with;
- Information that you give us and information about your participation in the Site(s) and the Service may be combined with other personally identifiable information (such as demographic information and past purchase history) available from our records and other sources.
This information will be used to make our future marketing efforts more efficient. This information may also be shared with other marketers to bring you offers of interest subject to your consent.
- We subscribe to Google Analytics which is a web analysis service provided by Google Inc. (“Google”). This subscription allows Google to use Information about your participation in the Site(s) and the Service. Google utilizes the information collected to track and examine the use of the Site(s), to prepare reports on its activities and share them with other Google services (such as Google Remarketing and Demographics and Interest Reporting) and to contextualize and personalize the ads of its own advertising network. The aim of the tracking is to provide customized advertising that reflects your online preferences. You can opt-out of Google Analytics for Display Advertising using Google's Ads Settings or to opt-out of Google Analytics using the Opt-out Browser Add-on. Third-party vendors, including Google, may show our ads on sites across the Internet and use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to the Site(s).
The information we collect may be disclosed when we are legally required to do so, at the request of governmental authorities conducting an investigation, to verify or enforce compliance with the policies governing our website and applicable laws, or to protect against misuse or unauthorized use of our website.
You should also be aware that when personal information is voluntarily disclosed (i.e. your name, e-mail address, etc.) in the discussion forums or other public areas on the Site(s) or Service, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this privacy notice does not apply to such information. Any submissions to chat rooms or other public areas on the Site(s) are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you're online.
How do we protect and secure the information you provide to us?
This site has security measures in place to protect the loss, misuse and alteration of the information under our control. The transfer of confidential information such as credit card numbers and financial data are communicated via state of-the-art encryption. Our Web server and database reside behind a firewall in a secure datacenter with offsite backup and fire protection.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
Does this privacy notice apply to other websites that I can link to from the Trading Academy and Community websites?
Our Site(s) contains links to other websites that we do not control. This privacy notice does not apply to these linked websites. Therefore, you should review the privacy notice on each linked website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites.
Accuracy of your personal information
It is important that the personal information we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal information provided by you. Please keep us informed if your personal information changes during your relationship with us either by logging onto your account on the website or by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that you provide to us.
How long we will store your personal information for
We will store your personal information for the time period which is appropriate in accordance with our data retention policy.
Requirements on you to provide personal information
In certain circumstances the provision of personal information by you is a requirement to comply with the law or a contract, or necessary to enter into a contract.
is your choice as to whether you provide us with your personal information necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal information then the consequences of failing to do so are that we may not be able to perform to the level you expect under our contract with you e.g where we are unable to provide you with certain products or services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal information you provide in order to do so.
If changes are made to this privacy notice, these changes will be promptly posted on our Site(s) and a notice will be posted onto the OTAcademy and community homepages at otacademy.com informing you of such a change. We will also attempt to email notice of the change, but we are not responsible for you receiving the email. You agree to accept posting of a revised privacy notice electronically on the website as notice to you. The effective date of this privacy notice can be found at the bottom of this document.
Our Notice Towards Children
Neither the Site(s) nor the Service are directed to persons under 18. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at email@example.com. We do not knowingly collect personally identifiable information from children under 18 without parental consent. If we become aware that a child under 18 has provided us with personal identifiable information without parental consent, we will delete such information from our files and terminate that individual's use of the Service.
Your rights in relation to your personal information
Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal information, you may have a number of rights in connection with the processing of your personal information, including:
- the right to request access to your personal information that we process or control;
- the right to request rectification of any inaccuracies in your personal information or, taking into account the purposes of our processing, to request that incomplete data is completed;
- the right to request, on legitimate grounds as specified in law: (i) erasure of your personal information that we process or control or (ii) restriction of processing of your personal information that we process or control;
- the right to object, on legitimate grounds as specified in law, to the processing of your personal information;
- the right to receive your personal information in a structured, commonly used and machine-readable format and to have your personal information transferred to another controller, to the extent applicable in law; and
- the right to lodge complaints regarding the processing of your personal information with the Information Commissioner’s Office (if in the UK) or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.
Any inquiries or questions regarding this privacy notice should be directed in writing to our privacy officer at firstname.lastname@example.org.Last updated 24th May 2018