OTO.Coach Inc.’s policy and intention is to comply at all times with applicable data privacy laws, including the European Union data protection law that came into effect on May 25, 2018.
We respect your privacy and take great care to protect your personal data during the usage of our OTO.Coach Inc. websites, Mobile Applications, and Services (hereinafter, collectively “the Services”).
Personal Data means information which relates to you and identifies you (hereinafter “Personal Data”) and does not relate to any anonymous data generated when using the Services.
The Services are owned and operated by OTO.Coach Inc. (Finnish Business ID 3277794-9), a company specializing in sports technology solutions with its office located at Otakaari 5a, FI-02150 Espoo, Finland.
If you are an EU citizen, OTO.Coach Inc. is the data controller for your Personal Data as defined in the EU General Data Protection Regulation (GDPR) law.
WHAT PERSONAL DATA DO WE COLLECT?
In order for OTO.Coach Inc. to provide the Services to you, we need to collect and use certain Personal Data about you. OTO.Coach Inc. collects the following Personal Data:
- First name and last name
- Date of birth
- Height and weight
- Email, telephone number and other contact information
- Physiological data: Electrocardiography and/or DC potential data observed by your mobile device and submitted to the Services. The electrocardiography data is essential for us to provide you with the core functionalities of and adversely affect the Services. DC potential data refers to data collected by your Sensor and then relayed by your mobile device into our Services (“DC potential data”).
WHAT DO WE DO WITH THE PERSONAL DATA?
OTO.Coach Inc. may use your Personal Data for any of the following purposes (excluding your Physiological Data):
- to register you for use of our Services and to deliver and maintain our Services;
- to enable us to monitor, review and improve the Services;
- for our internal records regarding the use of the Services;
- (subject to the direct marketing section below) for marketing purposes; and
- so that we can fulfil our obligations under our agreement with you relating to the Services and to support you in your use of the Services.
OTO.Coach Inc. uses your Physiological Data (such as electrocardiography data, DC potential data) only to the extent necessary to provide the Services to you and may use it on an anonymous basis for research and scientific purposes, and for no other purposes whatsoever.
We will only retain information about you for as long as is necessary for the purpose for which it was intended and not for any longer, or for as long as may be required under any contract or by law.
We will not collect an excessive amount of information from you nor information that is not relevant to the purposes for which it was collected.
You have the right to request access to information we gather from you. We will comply with your request promptly and we may ask you to verify your identity for that purpose.
You have the right to have your information corrected and Personal Data updated if it is incorrect, incomplete, or out of date.
You have the right to restrict and limit the processing of your Personal Data.
You have also the right to object any Personal Data requested by us.
If you want to withdraw your consent from OTO.Coach Inc. to use your Personal Data, you have the right to be forgotten. We will process your request promptly and have your account and Personal Data deleted. It may take up to 30 days until we have fully completed the deletion from our system.
To do so, please send us your requests in written format via email to email@example.com. Please bear in mind that by doing so under certain circumstances (restriction, objection, and/or deletion), it may not be possible for you to use features or the Services provided by OTO.Coach Inc..
HOW DO WE COLLECT THE PERSONAL DATA?
We collect your Personal Data by various methods including the following:
- When you place an order on our e-commerce website to purchase our products and the Services;
- When you submit your Personal Data through the Services by whatever means, including but not limited to via your mobile device;
- When you contact us by whatever means other than through the Services; and
- When your designated coach or trainer enters data about you into the Services. This will be, however, only the case when you have granted your coach or trainer consent to use your Personal Data. Should you not have granted such consent please contact us urgently so that we may take steps to cease processing your Personal Data.
HOW DO WE KEEP YOUR PERSONAL DATA SAFE?
OTO.Coach Inc. will act in accordance with applicable laws and regulations when collecting, processing and storing your Personal Data.
You will be able to define in the Services who besides you and OTO.Coach Inc. has the right of access to your Personal Data. You may, for instance, give access to your Personal Data to your coach or trainer.
In order to keep your Personal Data and all the other information we have stored safe, we have implemented various security measures and taken reasonable steps to prevent unauthorized access, use, alteration, destruction or disclosure of your Personal Data.
All Personal Data will be stored on servers located within the European Union. If you live outside the European Union, you acknowledge and specifically agree that your Personal Data may be transferred to the European Union.
We will only retain information about you for as long as is necessary for the purpose for which it was intended and not for any longer, or for as long as may be required under any contract or by law. Unless we are required to retain the information under any contract or by law, your Personal Data will be removed after a reasonable period of time when you choose to cease using the Services.
We will take all reasonable precautions to ensure that our staff and employees who have been specifically granted access to information about you have received adequate training to ensure that they process that information only in accordance with this policy and with our obligations under applicable legislations.
We may use your contact information in order to provide you with information about products, special offers and other information relating to our products or services or which we believe may be of interest to you.
We may send you such information by email, telephone (including automated calls which means a call which delivers a pre-recorded message with marketing content to your telephone), SMS text message and/or any other form of electronic messages (including MMS, picture messages, video messages; instant messages and next generation messages), post, fax, or any other method which becomes relevant from time to time.
We will only use Personal Data that we collect from you for direct marketing if you give us your consent to do so. When you provide us with information about yourself, you will be given the option to tick an “opt-in” box in the Services to let us know that you do not want that information to be used for direct marketing purposes, although we may also ask for your consent by other means as well.
You have the right to object, so that we stop processing your Personal Data from direct marketing. If you change your mind later on in respect of direct marketing, please select your preferred settings. To do so, login to the Omegawave Web Application with your given credentials, go to “My Account” and select “Edit account“. You can also send us an email to firstname.lastname@example.org at any time. In addition, if you receive direct marketing from us by email you will be reminded in the email that you are able to request a change to your preferences.
THIRD PARTY INFORMATION
We may share your information with third parties in order to support and provide OTO.Coach Inc. with services, such as promoting, improving and support the Services, processing payments, completing and fulfilling orders. We may also use your information with the help of third party analytics to support us in monitoring, reviewing and improving the Services.
In any of those cases, these third parties will only have access to the most necessary information to provide us with their services and functions on our behalf. No sensitive or unnecessary Personal Data will be shared.
If you choose to use third party applications, plug-ins, that are integrated with the Services (for example, third party login), they may gather your information and/or personal data (such as, first and last name, email address). Gathered information by these third parties are liable to their terms and policies. OTO.Coach Inc. is not responsible for the terms and conditions or policies of those third parties.
COOKIES AND WEB BEACONS
When we provide the Services to you, we want to make it easy, useful and reliable. As the Services are provided to you via Internet, this sometimes involves placing small amounts of information on your device, for example, computer or mobile phone. These include small files known as cookies.
These pieces of information are used to improve the Services for you through, for example enabling a service to recognise your device so you don’t have to give the same information several times during one session, recognising that you may already have given a username and password so you don’t need to do it for every web page requested, measuring how many people are using services and gathering other information on how the Services are used.
Most web browsers allow you to turn off cookies. To do this look at the “help” menu on your browser. Switching off cookies may restrict the use of the Services and/or delay or affect the way in which it operates.
Webpages and HTML emails may also contain a small snippet of code called a web beacon. In their simplest form, web beacons allow a website to transfer or collect information through a graphic image request. OTO.Coach Inc. may use web beacons as part of the Services, but only for fraud detection.
HOW TO CONTACT US TO AMEND OR RECEIVE COPIES OF THE PERSONAL DATA WE HAVE COLLECTED?
Should you wish to review the Personal Data being held by us about you, you have the right to request details. Please make any requests in written form via email to email@example.com and we will comply with your request promptly.
Please help us to ensure that the information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please write an email to firstname.lastname@example.org. We will correct or update any information about you as soon as reasonably possible.
You have the right to be forgotten, also known as Data Erasure. Should you wish us to permanently delete your account and Personal Data being held by us, we will do so upon your request. In such case, you understand, that OTO.Coach Inc. will not be able to provide the Services to you anymore. It may take up to 30 days until we have fully completed the erasure of your account and Personal Data from our system.
Updated and valid as per January 16, 2023.
Address: OTO.Coach Inc., Otakaari 5a, FI-02150 Espoo, Finland.