Privacy Policy
PRIVACY POLICY
This privacy policy sets out how Frontdoor Labs Ltd. (trading as Otio) uses and protects your personal data.
Privacy policy
This privacy policy gives you information about how we collect your personal data and how we use it when we interact with you or when you sign up for products or services that we offer (including through our the website https://otio.ai (the “Site”), the Chrome extension of the Site, the mobile application Otio (the “App”) together the “Services”), regardless of where you visit from).
This Services we provide are not intended for children and we do not knowingly collect data relating to children.
Important information and who we are
This privacy policy relates to Frontdoor Labs Limited, trading as Otio (referred to as “Otio”, "we", "us" or "our" in this privacy policy). Otio is the controller and responsible for your personal data collected as part of the Services.
If you have any questions about this privacy policy or our privacy practices, please contact us on the details below:
Full name of legal entity: Frontdoor Labs Limited (Company Number 14138209)
Email address: contact@otio.ai
Postal address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
UK’s Information Commissioner’s Office Registration Number: ZB390660
Complaints
You will always have the right to lodge a complaint with a supervisory body if you think we have not followed data protection rules. The relevant authority for individuals within the UK (and where we are based) is the Information Commissioner’s Office (www.ico.org.uk). For individuals we engage with in other jurisdictions, there may be an alternative supervisory body you can refer matters to. We are happy to help you identify the appropriate supervisory body if you contact us using the details above.
If you do have a complaint or any questions about our data protection practices, we would appreciate the chance to deal with your concerns before you approach a supervisory body, so please do contact us in the first instance if possible, at the email address above.
Third-party links
Where our Services includes any links to third-party websites, plug-ins and applications, clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site or App , we encourage you to read the privacy policy of every website you visit.
Changes to this Policy
We keep this privacy policy under regular review. This notice was last updated in July 2024.
The personal data we collect about you
Personal data means any information about an individual from which that person can be identified. It does not include any data where the identity has been fully removed and anonymised.
As part of the Services, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Contact Data includes name, address, telephone number and email address.
Financial Data includes bank account and payment card details.
Profile Data includes your username and password, any subscriptions you have requested, your interests, preferences, feedback and survey responses.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website together with information on how you use our Services.
Communications Data includes your communication and marketing preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Technical Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our Services to help improve our service offering. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We also do not knowingly collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Input and Output Data
As part of the Services, we also collect any personal data which is included in any of your input and output data (like questions, prompts, content you upload or otherwise submit to the Services) . This might not always include personal data, and will depend on what you include and upload. Where you have submitted information to the Services, this is used solely to provide the Services and may be shared with third party providers who are involved in providing the Services. Such data will not be used by us or any third party providers to train any AI tool or large language model.
How is your personal data collected?
We use different methods to collect data from and about you. The main way we will collect your personal data is through your direct interactions with us, but we will also collect data through automated technologies and third parties or other publicly available sources.
Your interactions with us. You may give us Contact, Financial and Transactional Data by interacting directly with us through the Site or App, including when you sign up or register for Services. It also might include any information you give us when you request marketing information is sent to you or where you give us feedback or otherwise contact us.
Automated technologies or interactions. As you interact with Site and App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites we operate which use our cookies. Details of the cookies we use can be found in our cookie policy.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, like providers of technical and payment services that we engage. Additionally, Technical Data may be received from third party analytics providers or advertising networks (see our cookie policy for further details.
How we use your personal data
We will only use your personal data when we are allowed to do so under data protection law. We will not collect your personal data without letting you know. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you when you register for our services or access our services through our App.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently agreed to by you. We also will not collect any personal data that is not needed for the mentioned purposes. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rule, where it is required or otherwise permitted by law.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Direct marketing
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing. We will process your Contact and Technical Data to form a view on what we think you may want or need or what may be of interest to you. We will not share your personal data with third parties for marketing purposes.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the details at the start of this policy.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
Cookies
Cookies (and similar technologies) are small files of letters and numbers that are downloaded on to your computer or device when you visit a website. Cookies are used by many websites and can do a number of things, e.g. remember your preferences and count the number of people looking at a website.
The law distinguishes between “strictly necessary” cookies, such as those which enable websites to operate properly and those which are not strictly necessary, such as analytics cookies. Analytics cookies, and especially third-party analytics cookies, are commonly used as ways for third parties to compile records of individuals’ browsing histories. We are allowed to place strictly necessary cookies on your device without your consent (as long as we inform you, such as by way of this statement), but for all other cookies we require your express consent.
You are free to accept or refuse any non-essential cookies we use (including our analytic cookies) and can update your consent at any time. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Services may become inaccessible or not function properly.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out below.
Service providers: Where we appoint third parties to provide services on our behalf, like AI providers or IT providers. Where we engage third party AI providers, we ensure that any data shared with them is only used for the limited purpose of providing services, and data is not used for training or improvement to any AI tool or large language model.
Professional advisers: including lawyers, bankers, auditors and insurers who provide banking, legal, insurance and accounting services.
Authorities: regulatory, government and industry bodies, like the ICO (or other supervisory authority in relation to data protection and privacy matters), HM Revenue & Customs (or other relevant tax authority), fraud prevention organisation or law enforcement bodies who require reporting of processing activities in certain circumstances, especially in the prevention of money laundering and fraud.
Corporate partners: includes third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
Since we provide an online service and our Services are available in various countries, we may (a) need to transfer your personal data outside the United Kingdom or European Economic Area (EEA) to enable us to provide our services or (b) receive your data from outside the United Kingdom or EEA.
Whenever we transfer your personal data internationally, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the ICO or other appropriate regulatory body; or
We may use specific contracts approved for use in international transfers which give personal data appropriate levels of protection (like the International Data Transfer Agreement approved by the ICO for international transfers out of the UK); or
We may rely on another ground or exemption to allow us to transfer the personal data internationally. For example, where you are based out with the United Kingdom and have engaged us for services, we will rely on your consent to transfer data from our UK entity to you in another country.
We host all personal data within the EEA based on the decision of the ICO that Europe has adequate level of protection for personal data. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data internationally.
Data security
We know that it is incredibly important to protect and manage personal data appropriately, but unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted online or through our website.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
How long will you use my personal data for?
We will only retain personal data for as long as necessary to fulfil the purposes they collected it for, such as legal, accounting or reporting requirements. This means we may will generally keep your personal data for up to six years after the end of your relationship with us. We may keep your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. We will delete data where it is no longer required for the purpose it is originally collected for.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data . In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
If you want us to establish the data's accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
