The OTM Privacy Policy describes
how we treat personal information when you use OTM's products and
services. In addition, the following describes our privacy
practices that are specific to OTM Checkout.
Information we collect and how we use it
* Registration information - When
you sign up for OTM Checkout, we ask for your personal information
so that we can provide you with the service. The information we
require to register for the service includes your name, credit or
debit card number, card expiration date, card verification number
(CVN), address, phone number, and email address. For sellers, we
also require you to provide your bank account number, and in some
situations, your personal address, your business category, a
government-issued identification number (for example, social
security number or taxpayer identification number for U.S.
residents), and certain information about your sales or transaction
volume. This information allows us to process payments and protect
users from fraud. In some cases, we may also ask you to send us
additional information or to answer additional questions to help
verify your information. The information we collect is stored in
association with your OTM Account.
* Information obtained from third parties - In order to protect you
from fraud or other misconduct, we may obtain information about you
from third parties to verify the information you provide. For
example, we may use card authorization and fraud screening services
to verify that your credit or debit card information and address
match the information that you provided to us. Also, for sellers,
we may obtain information about you and your business from a credit
bureau or a business information service such as Dun &
Bradstreet.
* Transaction information - When you use OTM Checkout to conduct a
transaction, we collect information about each transaction,
including the transaction amount, a description provided by the
seller of the goods or services being purchased, the names of the
seller and buyer, and the type of payment used.
* Information about your use of the service - In order to protect
you from fraud, phishing, and other misconduct, we may collect
information about your interaction with the service to help
validate your identity or detect potentially fraudulent conduct.
For example, in some circumstances we may try to determine service
usage patterns (such as how quickly you type) so that we can try to
detect and prevent unauthorized attempts to access your account
(such as automated hacking attacks, or the use of stolen usernames
or passwords). Any such information we collect will only be used to
detect and prevent fraud or other misconduct, unless you explicitly
grant us permission to use it in another manner.
* OTM cookies - When you access a OTM Checkout webpage, we send one
or more cookies - a small file containing a string of characters -
to your computer that uniquely identifies your browser. We use
cookies to improve the quality of our service by storing user
preferences and tracking user trends. Most browsers are initially
set up to accept cookies, but you can reset your browser to refuse
all cookies or to indicate when a cookie is being sent. Please note
that you will not be able to access OTM Checkout if your cookies
are disabled.
* Log information - When you use OTM Checkout, our servers
automatically record information that your browser sends whenever
you visit a website. These server logs may include information such
as your web request, Internet Protocol address, browser type,
browser language, the date and time of your request and one or more
cookies that may uniquely identify your browser.
* User communications - When you send email or other communication
to us, we may retain those communications in order to process your
inquiries, respond to your requests and improve our
services.
* Links - We may present links in a format that enables us to keep
track of whether these links have been followed. We use this
information to improve the quality of our search technology,
customized content and advertising. For more information about
links and redirected URLs, please see our FAQs.
In addition to the above, we use
the information we collect to:
* Provide our products and
services to you, including the display of customized content and
advertising;
* Perform auditing, research and analysis in order to maintain,
protect and improve our services;
* Ensure the technical functioning of our network;
and
* Develop new services.
We process personal information on
our servers in the United States of America and in other countries.
In some cases, we process personal information on a server outside
your own country. We may process personal information to provide
our own services. In some cases, we may process personal
information on behalf of and according to the instructions of a
third party, such as our advertising partners.
Information sharing
We will not sell or rent your
personal information to companies or individuals outside of OTM. If
you are making a purchase through OTM Checkout, we may share
portions of your credit card number with the seller to identify the
transaction, but we will not share your full credit card number
with the seller without your opt-in consent, except in the limited
circumstances described below. In addition, we will only share your
personal information with other companies or individuals outside of
OTM in the following circumstances:
* As necessary to process your
transaction and maintain your account. As with any credit card
payment, if you process a credit card transaction through the
service, we need to share some information (for example, your name
and credit card number) with the banks and other entities in the
financial system that process credit card transactions. Some
sellers require that their buyers provide a telephone number in
order to process a transaction. In those cases, we will share your
telephone number with the merchant, and you will be notified of
that sharing before you complete your
transaction.
* To detect, prevent, or otherwise address fraud, security or
technical issues.
* We have your consent. We require opt-in consent for the sharing
of any sensitive personal information.
* We provide such information to our subsidiaries, affiliated
companies or other trusted businesses or persons for the purpose of
processing personal information on our behalf. We require that
these parties agree to process such information based on our
instructions and in compliance with this Policy and any other
appropriate confidentiality and security
measures.
* We have a good faith belief that access, use, preservation or
disclosure of such information is reasonably necessary to (a)
satisfy any applicable law, regulation, legal process or
enforceable governmental request, (b) enforce applicable Terms of
Service, including investigation of potential violations thereof,
(c) detect, prevent, or otherwise address fraud, security or
technical issues, or (d) protect against imminent harm to the
rights, property or safety of OTM, its users or the public as
required or permitted by law.
* If you are using a credit card issued by the merchant you are
making a purchase from (a "private label credit card"), that
merchant will receive your entire credit card number in association
with your purchase.
* We may share aggregated non-personally identifiable information
with third parties. For example, we may disclose that a certain
percentage of our users have a billing address in a particular
geographic area, or that a certain percentage of users use a
particular type of credit or debit card. However, if we do share
this aggregated information, we do not include personally
identifiable information without your explicit opt-in consent or in
the limited circumstances described above.
OTM Checkout also gives you
various choices regarding whether and how your email address is
shared, on a seller-by-seller basis:
* When you shop at a seller for
the first time and complete an order, you'll be given the option to
keep your email address confidential. If you select to keep your
email address confidential, OTM will not share your email address
with the seller, but will forward all communications from the
seller to the address listed in your account. Please note, however,
that if you decide to keep your email address confidential but have
shared it with the seller in the past, that seller may associate
the information they receive about you through OTM Checkout with
the information they’ve already received from
you.
* You will also be given a choice on a seller-by-seller basis
whether you’d like to receive promotional emails from the seller.
If you decide later that you don't want to receive promotional
emails from a seller, you will need to contact the seller
directly.
If OTM or its subsidiaries become
involved in a merger, acquisition, or any form of sale of some or
all of their assets, we will provide notice before personal
information is transferred and becomes subject to a different
privacy policy.
Information security
We take appropriate security
measures to protect against unauthorized access to or unauthorized
alteration, disclosure or destruction of data. These include
internal reviews of our data collection, storage and processing
practices and security measures, as well as physical and technical
security measures to guard against unauthorized access to systems
where we store personal data. For example, your credit card number
will always be stored in an encrypted form (except when you provide
it to us in a communication outside of our web page
interface).
The security of your account also
depends on keeping your account password confidential, and you
should not share your account name or password with anyone. If you
do share your account information with a third party, they will
have access to your account and your personal
information.
For more information about our
security practices, please see the main OTM Privacy
Policy.
Accessing and updating personal information
You can review and update your
payment information by logging in to your OTM Account and going to
the "Purchase History" page, where you can update or remove your
address and method of payment. You can also view your previous
transaction history on the "Purchase History"
page.
You can disable OTM Checkout by
contacting us. If you do so, your payment information and
transaction history will no longer be viewable through OTM
Checkout. However, in order to meet our reporting and auditing
obligations, and to detect, deter, and prevent fraud or other
misconduct on our systems, the information will be retained in our
systems. If you disable OTM Checkout, your personally identifiable
information will not be used by OTM or shared with third parties
except for these purposes. We may delete these records over time if
permitted or required by law.
Disabling OTM Checkout does not
close or cancel your OTM Account. For more information about how to
manage your OTM Account preferences, please click here. This
Privacy Policy continues to apply to the personal information we
maintain after you disable OTM Checkout or close or cancel your OTM
Account.
Sharing Between
Affiliates
We operate the OTM Checkout
service through wholly-owned subsidiaries of OTM.
The information we collect,
including information obtained from third parties, is shared
between OTM Inc. and its subsidiaries to operate the service.
Neither OTM nor its subsidiaries will share your information with
others except as described in this Privacy
Policy.
We provide you with the right to
opt out of certain sharing between OTM and its subsidiaries.
Specifically, you may choose to opt out of:
* The sharing between OTM and its
subsidiaries of information that does not pertain to your
transactions or experiences with OTM Checkout (also called
"non-transactional information", e.g., information we may obtain
from third parties to verify your identity).
* The use by OTM of information shared between OTM and its
subsidiaries to promote OTM products and
services.
Please remember, regardless of
whether you choose to opt out of this sharing or not, we will never
sell or rent your personal information, and we will not share your
personal information with anyone outside of OTM or its subsidiaries
except as described in this Privacy Policy.
Please note that this Privacy
Policy may change from time to time. We will not reduce your rights
under this Policy without your explicit consent. We will post any
Policy changes on this page and, if the changes are significant, we
will provide a more prominent notice (including notification in
your account interface or email notification). Each version of this
Policy will be identified at the top of the page by its effective
date, and we will also keep prior versions of this Privacy Policy
in an archive for your review.
If you have any questions about
this Policy, please feel free to contact us through our website or
write to us at Privacy Matters, c/o OTM Inc., 15833 Chemical Lane,
Huntington Beach, CA 92649
OTM and its subsidiaries adhere to
the U.S. safe harbor privacy principles of Notice, Choice, Onward
Transfer, Security, Data Integrity, Access and Enforcement, and are
registered with the U.S. Department of Commerce's safe harbor
program.
