At OTA TECHNOLOGY DMCC ('OTA'), we care about the privacy of your data and are committed to protecting it. OTA is the developer, owner, and provider of software and services distributed under the OTA TECHNOLOGY DMCC trademark, which is owned by OTA. This Privacy Policy explains what information we collect about you and why, what we do with that information, and how we handle that information. We’ll also explain what choices you have with respect to the information.

This Privacy Policy applies to OTA TECHNOLOGY DMCC's ('we', 'us', 'our', or 'OTA') desktop, mobile, and SMART-TV applications and Services (collectively, the 'Products') developed and provided under the OTA TECHNOLOGY DMCC trademark, which is owned by OTA. It also applies to ota-technology.com and other OTA websites (collectively, the 'Sites'), as well as other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with OTA. If you do not agree with the terms, do not access or use the Products, Sites, or any other aspect of OTA's business.

The Privacy Policy does not apply to third party services. Where third party services are used, and the third party is not a Data Processor, no Relevant Data (as defined below) is shared with them, or the Relevant Data has been anonymised such that the GDPR does not apply. Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

In addition, a separate agreement governs the delivery, access, and use of the Products (the 'Terms of Service').

This Privacy Policy applies to Relevant Data received and processed by OTA TECHNOLOGY DMCC ('OTA'). Communications regarding this Privacy Policy may be sent to OTA using email addresses ending with @ota-technology.com, which are authorized for use by OTA in connection with the distribution of products and services under the OTA Technology DMCC trademark.

Capitalized terms used in this Privacy Policy and not otherwise defined shall have the meanings provided below:

Roles and Responsibilities

OTA TECHNOLOGY DMCC ('OTA'), as the Data Controller, determines the purposes and means of processing Personal Data and is responsible for ensuring compliance with data protection legislation. OTA is responsible for implementing appropriate technical and organizational measures to ensure and demonstrate that processing is performed in accordance with applicable laws.

OTA TECHNOLOGY DMCC ('OTA') as the Data Processor, processes Personal Data and is responsible for processing Personal Data securely and for assisting OTA in fulfilling its obligations under data protection laws, including responding to data subject requests and maintaining records of processing activities.

ОТА is committed to ensuring the confidentiality, integrity, and availability of Personal Data and to implementing measures to protect against unauthorized or unlawful processing and against accidental loss, destruction, or damage.

Relevant Data - Personal Data and Special Categories of Data are the Relevant Data covered by this Policy and as defined in the applicable data protection legislation.

Personal Data - any information relating to an identified or identifiable natural person.

Special Categories of Data - Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health or a person’s sex life or sexual orientation.

Processing/Processed - any operation on Personal Data, whether automated or not.

Other capitalized terms have the same meaning as in the applicable Terms of Service.

The OTA TECHNOLOGY DMCC trademark is owned by OTA TECHNOLOGY DMCC. OTA develops, owns, and provides the software and services distributed under the OTA TECHNOLOGY DMCC trademark.

Certain data about the devices you use to connect with OTA and your use of the Site and/or Product are automatically logged in our systems, including:

• Сontact details, namely, email, phone number, birthday date, country of residence. This information might be needed to have an agreement with you, provide you with our services and communicate with you.
• Location information. This is the geographic area where you use your TV, computer and mobile devices (as indicated by an Internet Protocol [IP] address or similar identifier) when interacting with our Site and/or Product. This information might be necessary to determine your general geographic location, applicable data protection legislation and provide you with customized, localized and personalized content.
• Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect data when you access or use our Site and/or Product and record it in log files. This log data may include the IP address, browser type and settings, the date and time of use, information about browser configuration, language preferences, and cookie data. This information is needed to ensure security of our systems, prevent detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce our Terms of Service..
• Product and Site Specific Data. This is information about the Site and/or Product you use and how you use them. We may also obtain data from our third-party partners and service providers to analyze how users use our Site and/or Product. For example, we will know how many users access a specific page on the Site and which links they clicked on. We use this aggregated information to better understand and optimize the Site.
• Device information. These are data from your TV, computer or mobile device, such as the type of hardware and software you are using (for example, your operating system and browser type), as well as unique device identifiers for devices that are using OTA Product. This is needed to provide you with the best experience, ensure compatibility and update our Services.

The detailed information on the basis for collection, storage and processing of each type of Personal Data is provided in the Lawful Basis for Personal Data Processing section of this Privacy Policy.

OTA uses cookies and similar technologies in our Site and Services that help us to provide, analyze, understand and enhance the use of our Services, enforce our terms, prevent fraud, improve Site performance, monitor visitor traffic and actions on our site, deliver and tailor our marketing or advertising, and understand interactions with our emails, marketing, and online ads on third party sites. The Site and Services may also include cookies and similar tracking technologies of third parties, which may collect information about you via the Site and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy.

OTA may receive data about Site visitors, marketing campaigns and other matters related to our business from affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with other information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

We also receive Personal Data when submitted to our Site or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with OTA.

Our order process is conducted by third-party payment service providers as designated by us from time to time (“Payment Service Providers”). Payment Service Providers are the Merchants of Record for all our orders. Payment Service Providers provide all customer service inquiries and handle returns.

Payments information (this includes name, location, contact details, and billing information) provided by you may be stored and processed by Payment Service Providers. All such information is subject to the privacy policy of the respective Payment Service Provider.
Payment Service Providers and us have a legitimate interest to use provided data for product fulfilment, order processing, fraud prevention, and product support.

OTA does not knowingly collect Personal Data from children under the age of 16. If we determine we have collected Personal Data from a child younger than 16 years of age, we will take reasonable measures to remove that information from our systems. If you are under the age of 16, please do not submit any Personal Data through the Site and/or Products. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing their children never to provide Personal Data through the Sites and/or Products without their permission.

We will only use your Personal Data for the purpose for which it was originally collected, as described in this Privacy Policy, unless we deem it necessary to use it for another purpose compatible with the original purpose. If we need to use your Personal Data for a new purpose unrelated to the original purpose, we will notify you and explain the legal basis that allows us to do so. If required by law, we will seek your explicit consent before using your Personal Data for the new purpose.

We use, process, and store your information as necessary to perform our contract with you and for our legitimate business interests, in operating our Sites, Products, Services, and business including:

• To help us administer our Sites and/or Products, authenticate users for security purposes, provide personalized user features and access, process transactions, conduct research, develop new features, and improve the features, algorithms, and usability of our Sites and/or Products.
• As required by applicable law, legal process or regulation.
• To calculate aggregate statistics on the number of unique devices using our Sites and/or Products.
• To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Products, our Products offerings, and important Products-related notices, such as security and fraud notices. These communications are considered part of the Products and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about OTA. We will only send you marketing information if you provide the respective consent to us.
• For billing, account management and other administrative matters. OTA may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
• To investigate and help prevent security issues, fraud and abuse.

If information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, OTA may use it for any business purpose.

We only disclose Personal Data to third parties when:

• We use service providers who assist us in meeting business operations needs, including hosting, delivering, and improving our Products. We also use service providers for specific services and functions, including email communication, customer support services, and analytics. These service providers may only access, process, or store Personal Data pursuant to our instructions, according to the applicable data protection legislation and to perform their duties to us.
• We have your explicit consent to share your Personal Data (if required).
• We believe it is necessary to investigate potential violations of the Terms of Products, to enforce those Terms of Products, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or potential threats against persons, property, or the systems on which we operate our Site and/or Products.
• We determine that the access, preservation, or disclosure of your Personal Data is required by law to protect the rights, property, or personal safety of OTA and users of our Site and/or Products, or to respond to lawful requests by public authorities, including national security or law enforcement requests.
• We need to do so in connection with a merger, acquisition, bankruptcy, reorganization, sale of some or all of our assets or stock, public offering of securities, or steps in consideration of such activities (e.g., due diligence). In these cases some or all of your Personal Data may be shared with or transferred to another entity, subject to this Privacy Policy.
• We may disclose Non-Personal Data publicly and to third parties – for example, in public reports about word usage, to partners under agreement with us, or as part of progress reports we may provide to users.

OTA does not share your Personal Data/personally identifiable information with third parties for the purpose of enabling them to deliver their advertisements to you.

OTA does not sell or rent your Personal Data.

From time to time, we may contact you with information about product announcements, software updates, and special offers related to the Products provided under the OTA TECHNOLOGY DMCC trademark. These communications may come from email addresses ending with @ota-technology.com, authorized for use by OTA TECHNOLOGY DMCC.

We only send marketing communications to you with your prior consent.

All OTA account holders will continue to receive transactional messages related to our Products, even if you unsubscribe from promotional emails.

Information submitted to OTA will be processed, and stored in the United Arab Emirates. We ensure that appropriate safeguards are in place to protect your Personal Data in accordance with applicable data protection laws, including the Dubai International Financial Centre (the ‘DIFC’) Data Protection Law of 2020; Law No.(26) of 2015, to regulate the dissemination and exchange of data in the Emirate of Dubai; and the Abu Dhabi Global Market (‘ADGM’) data protection law of 2021; and the European Union General Data Protection Regulation (‘GDPR’); and the Data Protection Act 2018 in UK.
These safeguards may include implementing Standard Contractual Clauses, regulator approvals, obtaining your explicit consent, or ensuring that the transfer is necessary for the performance of a contract between you and OTA.

When you use the Product on your computing device, user content you save will be stored locally on that device and synced with our servers. By using our Sites and/or Products or providing any Personal Data, you consent to the transfer, processing, and storage of your information in these countries, which may have data protection laws different from those in your country of residence.

As the general rule, we retain your Personal Data while you are a customer and will delete your Personal Data within 30 (thirty) calendar days of either party’s termination of the User Agreement or upon written request. You can remove your Personal Data from OTA at any time by emailing us with the respective request: support@ota-technology.com. However, we may keep some of your Personal Data for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations.

When you give us Personal Data, we take steps to make sure that it’s treated securely.

Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.
We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology.

Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. The security of the data stored locally in any of our Products installed on your computing device requires that you make use of the security features of your device. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Site and Product.

OTA takes the security of your data very seriously and works to protect your data from loss, misuse and unauthorised access or disclosure.

All staff and officers who handle Relevant Data are aware of this Privacy Policy and have been given training in how to correctly collect, process, store and delete data. OTA holds a log of when staff training was undertaken and updates it on an annual basis.

All breaches will be reported to the relevant supervisory authority within 72 hours, unless the data was anonymised or encrypted or if it has a particularly high risk.

Breaches of this Privacy Policy by staff, contractors, officers of OTA will be dealt with under the OTA’s grievance and disciplinary policy and may lead to a disciplinary sanction.

If OTA learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through SMS or messenger of the phone number or email address that you have provided to us or by posting a notice on the Site. Depending on where you live, you may have a legal right to receive such notices in writing.

OTA uses, processes, and stores Personal Data, as necessary to perform our contract with you, and based on our legitimate interests in order to provide the services in connection with the Product and maintaining Product’s functionality, namely:

• Log data (crash data and other diagnostic reports) - for identifying and fixing defects in Product's functionality. Logs and entire reports are important to analyze user problems, application misfunctions and crashes. Data is mandatory and is frequently the main source, which helps to understand and resolve application issues.
• Device information: Operating System (OS) running on your device, Internet Protocol (IP) address, access times, browser type, and language, OS localization, CMM bundle IDs, CMM version, screen resolution, cid, battery info, RAM usage info, drive info, processor info, GPU info, disk info (type, total, free, backups), files metadata, applications preferences data, installed applications, network names and preferences
• Computer uptime in hours - to identify and localize user issues (bugs) and to understand and localize user problems, for the Product correct operation, Product functioning.
• We are collecting your data when you’re contacting our customer support team via call, email or another communication tool. The purpose of collecting is for helping you to solve any issue you have with our services. The legal basis of collecting is fulfillment of our contractual or pre-contractual obligations to you. Additionally, we may record the calls. The purpose of call recording is quality control of our customer support services and personnel training. The legal basis of call recording is our legitimate interests in retaining you as a customer and providing you with first-class customer support services.

We rely on your consent to process Personal Data:

• to send promotional emails,
• to place cookies on your devices, and
• for in-app analytics events and actions, used by us to understand user behaviour, analyze and optimize it.

In some cases, OTA may process Personal Data pursuant to legal obligation or to protect your vital interests or those of another person.

You have the following rights in respect to your Personal Data, including the right to access, correct, or delete Personal Data we process through your use of the Site and/or Product.

You can:

• Have your Personal Data corrected or deleted. You may ask us to correct information you think is inaccurate or completely delete all information that we hold about you by emailing: support@ota-technology.com.
• Access your Personal Data report by submitting a request at support@ota-technology.com. This report will include Personal Data we have about you, provided to you in a structured, commonly used, and portable format.
• Object to us processing your Personal Data. It is your right to lodge an objection to the processing of your personal data by emailing: support@ota-technology.comi if you feel the “ground relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.
• Ask us to stop using your Personal Data, including when we use your Personal Data to send you marketing emails. We only send marketing communications to you with your prior consent, and you may withdraw your consent at any time by clicking the “unsubscribe” link found within OTA emails and changing your contact preferences. Please note you will continue to receive transactional messages related to our Product, even if you unsubscribe from marketing emails.
• Complain to a regulator. If you’re based in the European Economic Area (EEA) or UAE and think that we haven’t complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority.
• Request to know more details about the categories or specific pieces of Personal Data we collect (including how we use and disclose this information), to delete their Personal Data, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

To communicate with our Data Protection Officer, please email dpo@ota-technology.com.

We may need to update this Privacy Policy to keep pace with changes in our Sites, Products, Services, our business, and laws applicable to us and you. We will, however, always maintain our commitment to respect your privacy. We will notify you in advance of any material changes that impact your rights under this Privacy Policy by email (to your most recently provided email address) or by posting a prominent notice on our Sites at least 30 days before the changes take effect. If required by applicable law, we will obtain your consent to such changes.

Please note that your continued use of OTA's Sites and/or Products after any changes take effect means that you agree to and accept the updated Privacy Policy. If you disagree with any changes in this Privacy Policy and do not wish your information to be subject to it, you must stop using the Sites and/or Products before the changes become effective and, if necessary, deactivate your account with us.

This Privacy Policy may be translated into other languages for your convenience. In the event of any inconsistency or discrepancy between the English version and any translated version, the English version shall prevail.

You may contact us with any questions relating to this Privacy Policy by emailing support@ota-technology.com. This email address is authorized for use by OTA TECHNOLOGY DMCC in connection with the products and services provided under the OTA TECHNOLOGY DMCC trademark.

Company DetailsOTA TECHNOLOGY DMCC

• Address: 1469, DMCC Business Centre, Level No 1, Jewellery & Gemplex 3, Dubai, UAE
• support@ota-technology.com.