OTO PRIVACY POLICY

OTO is committed to respecting your privacy and the confidentiality of your personal data, traffic data and communications content.

This Privacy Policy is designed to assist you in understanding how OTO uses and safeguards the information you provide in using OTO's International Call

1. WHAT INFORMATION DOES OTO COLLECT AND USE?

OTO may gather and use information about you, including (but not limited to) information in the following categories:

(a) Identification data (e.g.  mobile number, email address);

(b) Profile information (e.g. country of residence, language preference);

(c) Survey results;

(d) Information about your usage of and interaction with the OTO software, our products and websites including computer, platform, device and connection information, device capability, browser type, bandwidth, statistics on page views, and traffic to and from our websites.

(e) Products or services ordered and delivered;

(f) Your username and password for other email accounts where you have provided this to us.

(g) Correspondence between yourself and OTO;

(h) Traffic data (data processed for the purpose of the conveyance of communications or the billing thereof, including, but not limited to, the duration of the call, the number calling and the number called); and

(i) Content of instant messaging communications (please see section 12);

(j) Mobile device information, such as manufacturer's name, device model number, operating system, carrier network;

2. HOW DOES OTO USE THIS INFORMATION AND FOR WHAT PURPOSE?

Our primary purpose in collecting information is to provide you with a safe, smooth, efficient, and customized experience. OTO collects and uses, or has third party service providers acting on OTO's behalf collecting and using, personal data relating to you, as permitted or necessary to:

3. OUR DISCLOSURE OF YOUR PERSONAL INFORMATION

Except as provided below, OTO will not sell, rent, trade or otherwise transfer any personal and/or traffic data or communications content outside of OTO and its controlled subsidiaries and affiliates without your explicit permission, unless it is obliged to do so under applicable laws or by order of the competent authorities. Please note that information that you voluntarily make public in your account or user profile, or which you disclose on forums, discussions boards or by posting comments will be publicly available and viewable by others.

OTO may disclose personal information to respond to legal requirements, exercise our legal rights or defend against legal claims, to protect OTO's interests, fight against fraud and to enforce our policies or to protect anyone's rights, property, or safety.

In order to provide you with OTO products you have requested, OTO may sometimes, if necessary, share your personal and traffic data with OTO's group companies, carriers, partner service providers and/or agents. For example the PSTN-VoIP gateway provider, WiFi access services providers, distributors of OTO software and/or OTO products, and/or the third party banking organizations or other providers of payment, email delivery, analytical services, customer support, or hosting services. OTO will always require these third parties to take appropriate organizational and technical measures to protect your personal data and traffic data and to observe the relevant legislation.

Some OTO products may be co-branded and offered together with or via a partner company. If you register for or use such products, you consent to both OTO and the partner company's use of personal data collected in connection with the co-branded product. OTO may offer its products in connection with other websites or services or may team with other online services to give you the combined results of both products/services or additional services and benefits.

OTO, OTO's local partner, or the operator or company facilitating your communication may provide personal data, communications content and/or traffic data to an appropriate judicial, law enforcement or government authority lawfully requesting such information. OTO will provide all reasonable assistance and information to fulfill this request and you hereby consent to such disclosure.

Your information may be stored and processed in any country in which OTO or its affiliates, subsidiaries or service providers maintain facilities, including outside of Korea. In this regard, or for purposes of sharing or disclosing data in accordance with this article 4, OTO  reserves the right to transfer information outside of your country. By using OTO software, OTO's websites or OTO products you consent to any such transfer of information outside of your country.

In the event that OTO and all of its assets are acquired by a third party, personal information of OTO users will generally be one of the transferred business assets. We reserve the right to include your personal information in any such transfer to a third party.

3. YOUR USER PROFILE

Your user profile is the information provided by you at registration which is displayed in your profile in the OTO software client and on your personal details page in your account. It may include your mobile numbers, country, language and any other information that you decide to make available.

4. HOW DOES OTO PROTECT YOUR PERSONAL INFORMATION?

OTO will take appropriate organizational and technical measures to protect the personal data and traffic data provided to it or collected by it with due observance of the applicable obligations and exceptions under the relevant legislation. Your personal and traffic data can only be accessed by authorized employees of OTO or its affiliates, subsidiaries or service providers who need to have access to this data in order to be able to fulfill their given duties.

5. CONTACTING YOU

OTO may from time to time ask you to provide information on your experiences which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms on the website or any survey that you take part in is used for the purposes of reviewing this feedback and improving the OTO software, OTO products and websites.

OTO may contact you to send you messages about faults and service issues. Further, OTO reserves the right to use email, the OTO software or SMS to notify you of any eventual claims related to your use of OTO software, the OTO websites and/or OTO products, including without limitation claims of violation of third party rights.

OTO may send you alerts by email or SMS to notify you when someone has tried to contact you. OTO may also use email, SMS or the OTO software to keep you up to date with news about the OTO software and OTO products that you have purchased and/or to inform you about other OTO products or other OTO related information. You can opt-out of the receipt of alerts and/or promotional (a) emails by clicking the ‘unsubscribe’ link on the email that you receive or by changing your notification settings on your account page; and (b) SMS by following the instructions on the SMS that you receive.

6. HOW CAN YOU ACCESS OR AMEND YOUR PERSONAL DATA?

You have the right to access and, where relevant, to amend your personal information. Some of your information may be viewed or edited online by signing into your account page. We will respond to requests to view, correct, complete or remove your personal information within a reasonable period of time and upon verification of your identity.
OTO will use all reasonable endeavours to accommodate requests to delete personal information unless it is required to be retained by law or for lawful business purposes

7. HOW LONG IS YOUR PERSONAL DATA KEPT BY OTO?

OTO will retain your information for as long as is necessary to: (1) fulfill any of the Purposes (as defined in article 3 of this Privacy Policy) or (2) comply with applicable legislation, regulatory requests and relevant orders from competent courts.

Retention of Instant Messages

Your instant messaging (IM) communications-content may be stored by OTO (a) to convey and synchronise your messages and (b) to enable you to retrieve the messages and history where possible. IM messages are currently stored for a maximum of 30 days unless otherwise permitted or required by law. OTO will at all times take appropriate technical and security measures to protect your information. By using this product, you consent to the storage of your IM and voicemail communications as described above.

8. CAN THIS PRIVACY POLICY BE MODIFIED?

OTO will occasionally update this Privacy Policy to reflect changes in our software and/or products and customer feedback. When we post changes to this Privacy Policy at our website we will update the "last revised" date at the bottom of the Privacy Policy. If there are material changes to this Privacy Policy or in how we will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification. You agree that your continued use of the OTO software or OTO products after notice shall constitute your acceptance of the Privacy Policy. We encourage you to periodically review this Privacy Policy to be informed of how OTO is collecting, using, and protecting your information.

© OTO – Last revised: August  2012