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.