Privacy

Privacy policy

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Data processing by OTE Limited

from 26 March 2022

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I. Introduction
In this data protection declaration, we, OTE Limited with registered office at 

 

27, Old Gloucester
Street, LONDON, WC1N 3AX

UNITED KINGDOM

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(hereinafter referred to as "OTE", "we" or "us"), explain the extent to which we collect and otherwise process personal data in connection with the website we operate at www.otelimited.com (hereinafter referred to as "our website"), whereby the description is not exhaustive. Personal data is understood to be all information that relates to a specific or identifiable person.

 

II. consent to data processing
By using our website, you as a user of our website (hereinafter "you", "you" or "your") consent to the processing of personal data in accordance with this privacy policy, including the use of cookies and Google Analytics. Otherwise, please refrain from using our website.

Please note that the content of our website is intended for users who have reached the age of 18. We do not knowingly collect personal data from children and young people under the age of 18. Persons who use our website or otherwise transmit personal data to us thereby declare that they are 18 years of age or older or are acting with the consent of their legal representative.

 

III. scope of application
This privacy policy applies to the processing of your personal data by OTE in connection with your access to and use of our website, including the use of cookies. This privacy policy does not apply to other websites, in particular those of third parties, even if they are linked to our website or we otherwise refer to them ("Third Party Sites"). OTE has no control over the content or privacy practices of Third Party Sites and is therefore not responsible for their content or privacy practices. This privacy policy also does not apply to the processing of personal data by OTE in connection with the provision of its services.

 

IV. Legality of data processing
Personal data is processed within the framework of the Swiss Federal Law of 19 June 1992 on Data Protection ("DPA") and in compliance with the EU General Data Protection Regulation (EU Regulation 2016/679; "GDPR"), in particular on the basis of Art. 12 and 13 DPA and Art. 6 GDPR.

 

V. Categories of personal data processed
The personal data we regularly process can be roughly divided into two categories:

Website usage data: this includes technical information about the computer, browser and internet connection you are using (in particular browser type and version, IP address, internet provider, operating system) as well as information about the time of access to our website and usage behavior.

Contact information: This includes your names and e-mail address.

When we refer to "personal data" below, we mean such categories of your personal data as described in this Section V.

 

VI Purpose of Processing Personal Data
We process personal data in order to be able to offer and inform you about our services, to enable an optimal user experience of our website and to analyze your use of the website. Additional information on this can be found below in the explanations on the use of cookies and Google Analytics in sections VIII and IX.

 

VII. collection of personal data
We collect personal data on website use (see section V above) as soon as you access our website and while you are using our website. For this purpose, we use cookies and, under certain circumstances, Google Analytics. For more information about cookies and Google Analytics, see VIII and IX below.

We obtain your contact information (see section V above) by you providing it to us, for example by contacting us via the contact form on the website.

 

VIII. Use of cookies
In order to make visiting our website more attractive, to enable the use of certain functions and to improve user-friendliness, we use cookies. These are small text files that the browser you are using downloads and stores on your computer when you access and use our website. Cookies provide information about your browser settings, the location of your computer, technical data about your computer, which other Internet pages you have visited, etc. Some cookies (so-called session cookies) are deleted at the end of the browser session, other cookies remain on your computer (so-called permanent cookies).

IX. Use of Google Analytics
We sometimes use Google Analytics to analyze your use of our website (so-called conversion tracking) and to find out how you access and use our website. Google Analytics is an analysis service provided by Google Inc. ("Google"), which uses cookies that are stored on your computer and enable an analysis of your use of our website. The information generated by the cookies, including personal data, is usually transferred to a Google server in the USA and stored there. Google uses this information to evaluate your use of our website, to compile reports on website activity and to provide OTE with other services related to the use of our website and the Internet. According to the settings we have made, Google automatically deletes the data sent by Google Analytics and linked to cookies, user IDs or advertising IDs after a retention period of 24 months. Further information on Google Analytics can be found at https://support.google.com/analytics/answer/6004245?hl=de.

For your option to control the use of cookies by browser settings or to delete cookies, please refer to section VIII above.

Please note that our influence on the processing of your personal data by Google is limited to making user settings in Google Analytics. We therefore cannot accept any responsibility or liability for any further processing of your personal data by Google.

 

X. Disclosure of personal data to third parties
In principle, we do not pass on the personal data we process to third parties; nor do we sell your personal data. However, we do involve external natural persons or legal entities, so-called agents or third-party service providers, for the handling of business processes that may involve the processing of personal data (for example, for the operation and design of our website, for the operation of our e-mail servers, for the storage of our business data that may contain personal data, in the context of the use of Google Analytics [see Section IX above], etc.). The processing of your personal data by such agents or service providers is based on agreements that we have concluded with them.

In addition, OTE may be obliged to disclose personal data (for example, to authorities) due to legal regulations or official orders.

 

XI. Transfer of personal data abroad
Personal data is generally processed in Switzerland. However, agents or third-party service providers (see Section X above) may be located abroad or process Personal Data abroad. This may involve countries whose legally guaranteed level of data protection is lower than in Switzerland, such as the USA. On the other hand, we generally do not transfer personal data to international organizations within the meaning of Art. 4 No. 26 of the GDPR.

Such a transfer of personal data abroad is in principle in accordance with Art. 6 DSG and Art. 44 DSGVO. This means in particular that either the transfer takes place to countries whose legislation has been determined by the Federal Data Protection and Information Commissioner and the competent EU Commission to have an adequate level of data protection, or that appropriate legal safeguards have been put in place. Such safeguards include, but are not limited to: (i) entering into an agreement with the Data Recipient abroad that is either based on EU standard contracts or approved by the Swiss Federal Data Protection and Information Commissioner, or (ii) as far as the U.S. is concerned, subjecting the Data Recipient to the Swiss-U.S. Privacy Shield or the EU-U.S. Privacy Shield. Please note that we have only limited influence on the transfer of Personal Data abroad that may be carried out by appointed agents or third-party service providers.

Please also note that OTE may be obliged to disclose personal data to recipients abroad (e.g. to authorities) due to legal regulations or official orders.

XII. Retention of personal data
OTE retains the collected personal data for as long as this is justified on the basis of the purpose of the data processing, is required by the applicable laws or is necessary for a possible assertion of legal claims or for the defense against claims or on the basis of official procedures. As a rule, the retention period does not exceed 5 years, but may be longer or significantly shorter. After expiry of the retention period, the relevant personal data is deleted or destroyed. Regarding the retention of cookies and Google Analytics data, we also refer to sections VIII and IX above.

 

XIII. Your rights
You have various rights in relation to our processing of personal data:

Right to information: you can request information from us at any time about whether and which personal data we process about you, for what purpose and based on which legal basis we do so, where the personal data originates if we have not collected it directly from you, to which categories of third parties we have disclosed your personal data and to which countries we have transferred your personal data. In addition, you are entitled to receive a copy of the personal data we have processed about you free of charge. The time limit for providing the information is usually 30 days.

Right to rectification: You may at any time ask us to rectify your personal data if it is incorrect.

Right to restrict data processing: You have the right to request that a certain form of processing of your personal data, its processing for certain purposes or its processing as a whole be omitted. However, such a request will only have an effect in relation to the future processing of your personal data and will not affect the lawfulness of the previous processing.

Right to erasure: You have the right to request the erasure or destruction of personal data collected about you at any time. Such a request has no effect on the lawfulness of the processing of your personal data to date.

Restricting data processing or deleting your personal data may, under certain circumstances, mean that you cannot use certain content or functions of our website or that we cannot offer you our services.

The exercise of such rights generally requires that you clearly prove your identity.

Please also note that in individual cases, the rights listed in this section XIII may be restricted due to legal provisions (for example, justification on the part of OTE).

 

XIV Updating this Privacy Policy
From time to time, we may update this Privacy Policy at our discretion. In such a case, we will make the updated version of this Privacy Policy available on our website. The updated Privacy Policy will only apply to data processing that occurs after the effective date of the updated version. Please check our website for any updates. By continuing to use our website and disclosing your personal data after the updated version of this privacy policy has been published, you accept the changes that have been made.

 

XV. Contact
OTE is the person responsible for processing personal data. If you have any questions, wish to exercise your rights or have any other concerns regarding data protection, you can contact OTE at the following e-mail address: info@otelimited.

Depending on the applicable data protection law, you also have the option of contacting the Federal Data Protection and Information Commissioner or another data protection authority in the event of complaints about data processing.
 

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