We respect the privacy of people who visit https://oton.education (“Website”). We are devoted to the protection of your personal data. In particular, we are committed to processing your personal data responsibly in compliance with applicable data protection laws and only for defined below purposes.
What is personal data/processing of personal data?
Personal data is any information relating to you and that alone or in combination with other pieces of information gives the opportunity to the person that collects and processes such information to identify you as an individual. This can be your name, your identification number, your location data, information related to your physical, physiological, genetic, mental, economic, cultural or social life or any other information that may identify you.
Processing of the data means any action performed with your personal data, for example, collection, recording, organization, structuring, storage, use, disclosure by any means etc.
Legal bases for processing.
Please note that we may process your personal data not only based on your consent, but also when one of the following is applicable:
processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
processing is necessary for the compliance with our legal obligations;
processing is necessary to protect your vital interests or vital interests of another natural person;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
In all cases, we will notify you about applied legal basis for processing and other relevant details per your request.
What personal data do we collect?
When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:
Information you give us: you may give us information about yourself if you sign up for an account on our Website, complete any online forms (such as registration forms, competitions, and surveys), opt in to receive our newsletters and special offers, enter a competition or promotion, participate in social media functions with our Website, or correspond with us (by email, telephone, instant chat, social media or otherwise).
Depending on what you provide, this information can include your name, address or location, phone number and email address, date of birth, gender, purchase information, images and financial information (including your credit or debit card details, although we do not hold them, our payment processors do).
Information we receive from other accounts or sources: we can receive information about you from other sources, such as from your other accounts or other websites, including data brokers, our Partners, social media providers like Facebook, advertising networks and analytics partners, and payment and delivery service providers. By logging in to our mobile applications via Facebook, or linking your account on our Website to your Facebook accounts, you are giving us permission to obtain certain information and content from these accounts, such as your name, location, email address and profile picture. The specific types of information that we may obtain depends on your settings for that account or website, and will be subject to their privacy policies. We may combine such personal data with the personal data you provided to us to register your user account and communicate purchase information.
Information our IT systems collect about you: each time you visit the Website, certain information will be created and automatically recorded by our IT systems. That information includes: cookies and device information.
Server log files. Some data are collected automatically to run the Website, including browser type and browser version, operating system, referrer URL, host name of the accessing computer, and the time of the server request. We presume that these data cannot be personal, because the combination of these data is impossible. However, we reserve the right to check these data in retrospect in the case of proved illegal use.
Please, note that we in no case sell your data. We also do not make any decisions based solely on automated processing, which produce legal effects concerning you or similarly significantly affect you.
Please, note that we may compile and publish some statistic information showing the number of registration, visits, purchases, requests or complaints we receive or other information. Such statistics will be totally anonymous.
Who will access your personal data?
In order to provide high-quality services, we hire people also cooperates with other services providers, companies and organizations. For these reasons, some of your personal data can be passed on to the persons mentioned above.
You also have to be aware of the fact that we may disclose your personal data to enforce and comply with the law. In other words, we may disclose information necessary for the investigation or legal process on official request or the official bodies acting within their powers.
There are three reasons where we may share your data with third-parties that we have not listed here:
Professional Advisers and Investors: We may also share your data with professional advisers such as our lawyers and insurers to manage risks and legal claims, and/or as part of our relationship and obligations to our investor organizations. This is in our legitimate interests.
Group: It is possible we could sell our business to a third party or re-organize our business or become insolvent. In that scenario, our database of customers is one of the biggest parts of that business and so we would need to share it with the third-party buyer and their advisers. This is in the legitimate interests of selling our business.
How we may use your data for marketing purposes and additional data we may request permission for.
Part of the role of the COMPANY is to market the Services to enable more people to purchase items listed on the Website. To do so we use a number of different third-parties to help us with these initiatives. We see these anonymized transfers of data as critical to the running and future success of our business and you cannot opt-out of them if you use our Services.
In addition to the anonymized data we send to the third-parties, we may ask permission from you to use extended data to help give you a better service. A better service may include (but is not limited to):
the ability for us to personalize our email communication to you based on identifiable information;
the ability for us to place advertisements (including product listings) on the third-party websites based on your browsing or purchasing history with us;
whilst browsing the Website, having us push relevant deals and information to you based on your specific interactions with the website.
For this we will ask you to opt-in to our marketing initiatives; you will automatically be opted-out of these services when you join the Website. If at any stage, you would like to opt in or out you can do so in your account settings.
What do you use my information for?
To provide you the Service, the Website and to optimize your experience we need to use the information that we collect in a number of different ways.
We also use the information for marketing and advertising purposes. Where you have told us you would like to receive marketing communications or when you have made a purchase using our Services to occasionally send you updates, news, and offers via email, post, or other forms of media. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below), to tailor these messages to you. You may unsubscribe from our email marketing communications by modifying your preferences in your account’s profile management section, or by following the opt out instructions in the promotional emails that are sent to you.
Please scroll down to find out the detailed purposes for which we collect your information, what specific information is collected and the legal basis for which we purpose that data.
To register and manage your account in our Website, we collect your name, email, password and other additional details you may wish to add in your account, like phone number, addresses and gender. The legal basis is the performance of a Contract with you.
To administer, maintain and optimize our Website and our services, we collect your device information (such as your device IP address and device type), Cookie identifiers and browsing information. The legal basis is the legitimate interests in running our business.
Carry on research, analysis, enquiries and surveys on your use of our website, we collect your Name; Addresses; Email; Device information, legal basis is our legitimate interests in running our business and improve our Website and your experience.
Advertising and retarget advertising of our and our partners’ products and services, we collect your email, cookie identifiers and device information. The legal basis is our legitimate interests in running our business.
To produce aggregated statistical reports, we use your order history, provided that the result of such reports do not identify you. The legal basis is our legitimate interests in running our business and improve our Website.
To manage requests and complaints. When we receive a request or complaint (‘enquiries’) from a person, we create a file containing the details of the enquiry. This normally contains the identity of the requestor or complainant and any other individuals involved in the enquiry. We will use the personal data from your enquiry only in order to process the request or complaint, check on the level of our services and provide you with the comprehensive response. Such data will be processed on the contractual basis as we will use it to provide you with information you have intentionally requested. Without this data we will not be able to consider your issue and give you a response regarding it.
How long will the personal data be processed and stored by us?
We store personal data in case we consider you to be potentially interested in our services or you are already our client. Your personal data will be stored by us no longer than is necessary for the purposes for which the personal data are processed. Thus, retention period depends on the purpose of processing and may be specified per your request.
We also store the personal data of subjects who agreed to the subscription to our newsletters. The data is stored until a subscriber asks to be unsubscribed in the respective email form.
After the expiration of retention period, we shall terminate the processing of your personal data or pseudonymize such data, unless stated otherwise under applicable laws.
Transfers of your personal data.
To provide our Website and our Services, in accordance with the purposes set out above, we may transfer and store the personal information that we collect from you to a destination outside of the European Economic Area (“EEA”).
When transferring personal information to one of our third-party services’ providers set out above, we rely on different adequacy measures, as set out below:
Model Clauses: We rely in the Commission’s model contracts for the transfer of personal data to third countries (i.e. the standard contractual clauses) pursuant to Decision 2010/87/EU when transferring your information to our US service providers who do not adhere to the US Department of Commerce's EU-US Privacy Shield.
Your rights regarding your personal data we processed
Under the data protection laws, you have rights we need to make you aware of. The rights available to you depend on the legal basis for processing of your personal data:
1. Right to access to your personal data and right to data portability
You have the right to request us an access to your personal data and to know the source of these personal data. You may request to be provided with your personal data in a structured, commonly used, and machine-readable format. You also have the right to transmit those data to another controller, if the processing is based on your consent or on contract and the processing is carried out by automated means. You can also ask for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information.
2. Right to request a rectification of your personal data
You have the right to request rectification of inaccurate personal data or request that incomplete data be completed.
3. Right to request an erasure of personal data
You have the right to request us an erasure of your personal data if its processing is no longer needed in relation to the purposes for which they were collected, and also if there are no legitimate grounds for the processing.
4. Right to restrict the processing of your personal data
You have the right to request a restriction of processing of your personal data if you dispute the accuracy of your data, or we no longer need these data for processing purposes and if you are against the processing of the data.
5. Right to withdraw your consent
You have the right to withdraw your consent for the collection and processing of your personal data at any time by contacting us. After your request, we will process such request in a timely manner and we will no longer process your personal data unless stated otherwise under applicable laws.
6. Right to object to the processing of your personal data
You have the right to object to processing of your personal data on the basis of legitimate interest or as part of a task in the public interest or for an official authority; or we process your data to pursue our or third party’s legitimate interests, and you believe that such interests are overridden by your interests or fundamental rights and freedoms. However, in some specific cases, the public interest may prevail and we may be allowed to continue using your personal data.
7. Right to lodge a complaint
You have the right to lodge a complaint directly with us or with the competent data protection authority in the case you consider our processing of your personal data as non-compliant with the applicable data protection laws.
If you make a request objecting to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing.
Any requests to exercise your rights can be directed to us through the contact details provided below. These requests are free of charge.
Time for reply and reaction.
We will provide information about the actions taken on your request, within one month after receiving the request. This period may be extended by two further months if we consider it necessary, considering the complexity and number of the requests. We will notify you about such renewal within one month of the receipt of the request together with the reasons for such delay.
How we protect personal data?
We process your data by using computers and/or other IT enabled tools. We take both technical and organizational measures to ensure that your personal data are processed in a manner that provides appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage.
We use verified contractors, with whom we sign data processing agreements, who might have access to your personal data. We also guide and train our personnel to process your data securely and in accordance with our internal data protection policies.
We use only secure places of storage, such as provided its own or rent servers located in Germany and Holland.
Are you already 18 years old?
Our Website is intended for adult use only. We do not knowingly collect data from minors under 18 years old and its Website does not target such minors. We encourage parents and legal guardians to take an active role in their children’s online activities as well as their interests and ask the minors not to submit any personal data to us.
If any of your personal data is stolen, lost or illegally accessed - known as a personal data breach - we would inform you as well as the respective data protection agencies as to such accidents without undue delay. We would also inform you directly if there are serious risks related to your personal data or privacy due to the personal data breach. We will do our best to minimize any possible risks related to personal data breach.