Privacy Statement

Effective Date: November 11, 2017

This Privacy Statement describes the type of information that Project OTY (“Project OTY” or “we”) collects through your use of our website and Project OTY platform (collectively, the “Services”). This Statement does not apply to information collected about you through any other means, including information collected by third parties or through non-electronic or offline means (including phone).

This Statement covers:

  • What personal information is collected by Project OTY through our Services.
  • How Project OTY uses this information.
  • With whom Project OTY may share personal information.
  • What choices are available to you with respect to collection, use and sharing of this information.
  • What types of security procedures are in place to protect the loss or misuse of this information under our control.

By accessing or using the Services, or by clicking the “accept” button when you register to use a Service, you consent to our use of your personal information as described in this Statement. This Statement may change from time to time. Your continued use of a Service after we make changes is deemed to be acceptance of those changes, so please check the statement periodically for updates.

This Statement is part of, and is governed by, the Project OTY Terms of Service.

A. Information We Collect

We collect information from you in two ways. First, you provide us with certain information when you register for and use our Services. Second, we collect certain information automatically as you interact with our Services.

1. Information You Provide to Us

We may collect this information from you when you register as a user, sign up to receive newsletters, interact with us on our social media channels, submit content or send us feedback. Project OTY is a voluntary service; if you do not want us to collect this information, please do not use the Services. We directly collect the following types of information that you provide to us:

  • Identifying information. We may collect personally identifying information, including your name, telephone number, mailing address, birth date (day and month only) and email address.
  • “Roadmap Data.” When you complete the exercises within the Services, you may provide personal information about your goals and plans (“Roadmap Data”).
  • Payment card information. After the Services launch, our third-party payment processor may collect payment card information.

2. Information We Automatically Collect from You When You Use the Services

  • Information collected through our cookies. We (or service providers on our behalf) may use technologies, including “cookies” to automatically collect information from you when you use the Services. Cookies are small amounts of data that are stored within your Internet browser that saves and recognizes your earlier browsing.

Information that may be collected by cookies when you use the Services may include, without limitation:

  • web pages you visit;
  • usage and activity data (for example, we track your progress within the Services so you can return to the place where you left off);
  • date and time of your visit to or use of the Services;
  • amount of time you spend using the Services;
  • Internet Protocol (IP) address used to connect your computer or mobile device to the Internet; and
  • your computer or mobile device and connection information such as your browser type and version, operating system and platform.

You can delete cookie files from your hard drive, or avoid them altogether, by configuring your browser to reject them or to notify you when a cookie is being placed on your hard drive. Not all features of the Services will function as intended if you reject cookies.

  • Location information. Our app may collect your device’s general geolocation information (no more specific than the [neighborhood/zip code] level.

The information we collect automatically is statistical information and may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. If you do not want us to collect this information, do not download the app or use the Services, and delete the app from your device.

B. Do Not Track Requests

Your Internet browser and mobile device may allow you to adjust your browser settings so that “do not track” requests are sent to the websites you visit. Project OTY honors “do not track” requests.

C. How We Use the Information We Collect

We may use information collected from or about you for any of the following purposes:

  • to develop, provide and improve the Project OTY products and services;
  • to manage and verify your account and the identity of users of the Services;
  • to contact you when necessary about your account or your use of the Services;
  • to send you information and promotional materials about our products and services as well as our company in general;
  • to comply with regulatory requirements for the maintenance of records;
  • to conduct internal reviews of our Services and to help us better understand visitors’ and customers’ uses of our Services;
  • to protect the security and integrity of our Services;
  • to comply with court orders and legal process, and to enforce our terms of Service and this Statement; and
  • for any other legal, business or marketing purposes that are not inconsistent with the terms of this Statement.

We may also combine information we collect about you through the Services with other information about you that we receive from third-party sources. By way of example and not limitation, we may use a change of address or other list service to ensure that our records for your account are accurate.

D. How We Share Your Information with Third Parties.

While you may share Roadmap Data with third parties that you designate, Project OTY never shares personalized Roadmap Data with third parties without your consent. We may share other information we collect in connection with the Services with the following third parties:

1. Service Providers

We may share your personal information with our third-party distributors, vendors, suppliers and other service providers who provide services to us or on our behalf, such as operating and supporting the Services, performing marketing or consulting services, assisting us with the preparation and mailing of our business and marketing communications, and with service processing and fulfillment functions. These third-party service providers are contractually restricted from using your personal information for their own marketing purposes.

2. Third-Party Analytics Providers

We may also share your personal information with third parties who conduct marketing studies and data analytics. These third parties may combine your information with the information of other consumers for purposes of conducting these studies and/or analytics. For example, Google Analytics helps us understand how many people use the Services, where the users live, and which content is most popular. Read more about how Google uses data when you use our partners’ sites or apps.

3. Our Affiliates

We may share some or all of your information with our subsidiaries and corporate affiliates, joint venturers, or other companies that are or may become under common control with us. We will require these entities to comply with the terms of this Statement with regard to their use of your information.

4. Transfer or Assignment in Connection with Business Transfers or Bankruptcy

In the event of a merger, acquisition, reorganization, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your personal information and other information we have collected from users of the Services to third parties. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the use and disclosure of all transferred user information will be subject to this Statement. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

5. Response to Subpoenas or Court Orders or to Protect Rights

We may disclose your information to government authorities or third parties if:

  • you have given us permission to share your information;
  • we are required to do so by law, or in response to a subpoena or court order;
  • we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, or to protect our property or other rights or those of other users of the Services, third parties or the public at large; or
  • we believe that you have abused a Service by using it to attack or gain unauthorized access to a system or to engage in spamming or other conduct that violates applicable laws or the Project OTY Rewards Terms of Service. 

6. Aggregate Information

We may share aggregate or de-identified information without restriction. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.

E. Your Choices

We provide the opportunity to opt out of receiving communications from us and our partners at the point where we request information about you. In addition, you may unsubscribe or opt out of receiving communications from us by clicking the unsubscribe link on any email marketing communication you receive.

You may choose not to share your location details with us by adjusting your location services settings. For instructions on changing these settings, contact your service provider or mobile device manufacturer. If you choose not to share your location details with us, you will be denied access to certain Services, or parts of them.

F. California Privacy Rights

Project OTY does not allow third parties to use your personal information for their own marketing purposes, so California Civil Code sections 1798.83-1798.84 does not apply.

G. How We Protect Your Information

We have implemented commercially reasonable measures designed to secure your personal information from unauthorized access, use, alteration and disclosure. For example, database information is kept separate from live servers, and is firewall protected. However, the transmission of information via the Internet is not completely secure. You acknowledge that: (a) the limitations of the Internet are beyond our control; (b) the security, integrity and privacy of information and data exchanged between you and us cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party. Project OTY has no responsibility or liability for the security of information transmitted via the Internet.

H. No Use by Children

The Services are not intended for users younger than 13. We do not knowingly collect contact information from children under the age of 13 without verifiable parental consent. If we become aware that a visitor under the age of 13 has submitted personal information without verifiable parental consent, we will remove his or her information from our files.

I. Use of Information Outside Your Country of Residence

The Services are directed to users located in the United States. If you are located outside of the United States and choose to use the Services or provide your information to us, you should be aware that we may transfer your information to the United States and process it there. The privacy laws in the United States may not be as protective as those in your jurisdiction. Your consent to this Privacy Statement followed by your submission of information to us through or in connection with the Services represents your agreement to the transfer of your information to the United States.

J. Changes to This Privacy Statement

We may change this Privacy Statement from time to time. If we decide to make a material change in our Privacy Statement, we will post it on this page. Your continued use of the Services after the posting of changes to this Privacy Statement will mean you accept these changes. In some cases, we may attempt to contact you through an email or other address you have provided, so we can give you choices about our using your information in a manner different from that stated at the time of collection. If we make any material changes in our privacy practices that affect your personally identifiable information that is already in our possession, we will apply those changes to that older information only with your consent or as otherwise allowed by law.

K. Contact Us

If you have any questions about this Privacy Statement or our use of the information we collect from you in connection with the Services, email us at