Privacy Policy
Last modified: May 27, 2022
1. Our approach to privacy Otto Optical Systems Inc. (“Company” “Otto” or “We”)respect the privacy of the Users of our Service and are committed toprotecting it by complying with this policy. The words and phrases used inthis Policy have the same meaning as in Otto’s Terms of Use. This privacypolicy sets out how we collect, store, process, transfer, share and use datathat identifies or is associated with our Users, (“personal information”)and information regarding our use of cookies and similar technologies. Thispolicy also sets out how we protect personal health information ofPatients connected to the Service. Personal Health Information, andPersonal Information are collectively referred to as “Information”.
Otto uses a number of safeguards to protect the privacyof users of the Otto Service. There are two main stakeholders to which thisprivacy policy primarily applies; The term User refers to eyecare professionals who have entered into contractual relationships with Otto touse its services, and the term Patient refers to health careusers, whose personal health information is collected, stored, and used by OttoServices. For the purposes of clarity within this policy, the terms “Users”and/or “You” are meant to apply to all vested stakeholders to which thisprivacy policy applies. We are committed to complying with this Policy and withapplicable Provincial and Federal privacy legislation.
Otto operates a cloud-based eyewear patient relationshipand practice management solution available via our website (our “Websites”)including at ottooptics.io as well as other products and services that we makeavailable (the “Otto Service”).
This privacy policy applies to the Otto Service.
Note that this policy does not apply to the collection,use, retention, disposal, destruction, and protection of Information by opticalhealth care providers using Otto’s proprietary software. Healthcare providersare subject to privacy legislation and professional requirements that governtheir management of Information, including Information they collect, use andretain in the course of providing services through the Otto Service.
Before accessing or using the Otto Service, pleaseensure that you have read and understood our collection, storage, use anddisclosure of personal information as described in this privacy policy. Byaccessing or using the Otto Service, you are accepting and consenting to thepractices described in this privacy policy.
2. Application of privacy policy
Privacy laws in Canada generally define “personalinformation” as any information about an identifiable individual, whichincludes information that can be used on its own or with other information toidentify, contact, or locate a single person. Personal information does notinclude business contact information, including your name, title, or businesscontact information.
This policy applies to information we collect,use, or disclose about you:
· On this Service.
· In email, text, andother electronic messages between you and this Service.
· Through mobile anddesktop applications you download from this Service, which provide dedicatednon-browser-based interaction between you and this Service.
· When you interactwith our advertising and applications on third-party platforms and services ifthose applications or advertising include links to this policy.
· Any other proprietary software as a service delivered by Otto.
The Service may include links to third-party Services,plug-ins, services, social networks, or applications. Clicking on those linksor enabling those connections may allow the third party to collect or sharedata about you. If you follow a link to a third-party Service or engage athird-party plugin, please note that these third parties have theirown privacy policies and we do not accept any responsibility orliability for these policies. We do not control these third-party Services,and we encourage you to read the privacy policy of every Serviceyou visit.
This policy DOES NOT apply to informationthat:
· We collect offlineor through any other means, including on any other Company or third-partyService including our affiliates and subsidiaries.
· You provide to or is collected by any third party including ouraffiliates and subsidiaries, through any application or content (includingadvertising) that may link to or be accessible from or on the Service.
Please read this policy carefully tounderstand our policies and practices for collecting, processing, andstoring your information. If you do not agree with our policies andpractices, your choice is not to use our Website or Service. By accessing orusing either, you indicate that you understand, accept, and consent to thepractices described in this policy. This policy may change fromtime to time (see Changes to Our Privacy Policy). Your continued use of thisService after we make changes indicates that you accept and consent to thosechanges, so please check the policy periodically for updates. We willnotify you in advance of any material changes to this policy andobtain your consent to any new ways that we collect, use, and disclose yourpersonal information.
3. Personal Information we collect about you
Information you give to us.
We collect personalinformation about you when you voluntarily submit information directly to us byfilling in forms on our Website or by corresponding with us by phone, email orother means. This includes information you provide when you register to use ourWebsite, subscribe to the Otto Service, and when you report a problem with ourWebsite, or use some other feature of the Otto Service as available from timeto time. The Personal Information we collect is strictly limited to theInformation necessary for the purposes of executing Otto’s obligations both invirtue of its Software, and any of its applications and services it providesthe User as defined in the Terms of Use.If you choose not to provide personal information, wemay not be able to provide the Otto Service to you or respond to your otherrequests. We collect and use several types of information from andabout you, including:
· Personal HealthInformation, that we can reasonably use to directly or indirectly provide youwith optical healthcare services such as eyewear delivery. Information such asyour optical prescription, optical medical history, health card number,insurance information and other data that is provided by healthcareprofessionals to identify you may be provided to us in an effort to provideappropriate care.
· Personal information, that we can reasonably use todirectly or indirectly identify you, such as your name, mailing address, e-mailaddress, telephone number, Internet protocol (IP) address used to connect yourcomputer to the Internet, user name or other similar identifier, billing andaccount information, social insurance number, and any other identifier we mayuse to contact you (“personal information“).
We provide an opportunity for any user to unsubscribefrom our contact delivery service OR refill scheduling or opt-out of contactfor marketing purposes on an ongoing basis by accessing our Service Accountmodule, using the unsubscribe mechanism at the bottom of our e-mails, ore-mailing to help@ottooptics.io.
· Non-personalinformation, that does not directly or indirectly reveal your identity ordirectly relate to an identifiable individual, such as demographic information,or statistical or aggregated information. Statistical or aggregated data doesnot directly identify a specific person, but we may derive non-personalstatistical or aggregated data from personal information. For example, we mayaggregate personal information to calculate the percentage of users accessing aspecific Service feature.
· Technicalinformation, including your login information, browser type and version,time zone setting, browser plug-in types and versions, operating system andService, or information about your internet connection, the equipment you useto access our Service, and usage details.
· Non-personal detailsabout your Service interactions, including the full Uniform ResourceLocators (URLs), clickstream to, through and from our Service (including dateand time), products you viewed or searched for, page response times, downloaderrors, length of visits to certain pages, page interaction information (suchas scrolling, clicks, and mouse-overs), methods used to browse away from thepage, or any phone number used to call our customer service number.
· Public Contribution, you may also provideinformation to be published or displayed (hereinafter, “posted“) onpublic areas of the Service or transmitted to other users of the Service orthird parties (collectively, “User Contributions“. Your UserContributions are posted on and transmitted to others at your own risk.
Information we receive from other sources.
We may receivepersonal information about you from individuals or corporate entities which areusers to the Otto Services, where you are to be designated a patient of theOtto Service. We may receive personal information about you if you use any ofthe other websites we operate or the other services we provide from time totime. We also work closely with third parties (including, for example,subcontractors in technical, payment and delivery services, advertising networks,analytics providers, search information providers, credit reference agencies)and may receive information about you from them, subject to your agreementswith them.
We will only use your personal information in accordancewith this policy unless otherwise required by applicable law. We takesteps to ensure that the personal information that we collect about you isadequate, relevant, not excessive, and used for limited purposes.
4. How we use your personal information
We use information that we collect about you or that youprovide to us, including any personal information:
· To present ourService and its contents to you.
· To provide you withinformation, products, or services that you request from us.
· To fulfill thepurposes for which you provided the information or that were described when itwas collected, or any other purpose for which you provide it.
· To provide you withnotices about your account/subscription, including expiration and renewalnotices.
· To carry out ourobligations and enforce our rights arising from any contracts with you,including for billing and collection or to comply with legal requirements.
· To notify you aboutchanges to our Service or any products or services we offer or provide thoughit.
· To improve ourService, products or services, marketing, or customer relationships andexperiences.
· To allow you toparticipate in interactive features, social media, or similar features on ourService.
· To measure orunderstand the effectiveness of the advertising we serve to you and others, andto deliver relevant advertising to you.
· In any other way wemay describe when you provide the information.
· For any other purpose with your consent.
We may also use your information to contact you aboutour own and third-parties’ goods and services that may be of interest to you,as permitted by law. If you do not want us to use your information in this way,please check the relevant box located on the form on which we collect your data(the order form/registration form), adjust your user preferences in youraccount profile, use the unsubscribe mechanism at the bottom of our e-mailsand/or e-mail us at help@ottooptics.io. For more information, see “Choicesabout how we use and disclose your information.”
We may use the information we have collected from you toenable us to display advertisements to our advertisers’ target audiences. Eventhough we do not disclose your personal information for these purposes withoutyour consent, if you click on or otherwise interact with an advertisement, theadvertiser may assume that you meet its target criteria.
Provision of the Otto Service for Users
· We collect and useyour Information to register you, create your User Account, authenticate youwhen you log in and personalize your experience while using the Otto Service.
· To manage allappointments, track shipments, inventory, accounting, interfacing withlaboratory machines.
· We may confirm youreligibility to use the Otto Service for Healthcare Services and/or ConsumerServices by asking you to confirm your place of residence, authority topractice and date of birth that you provide when registering.
· We use Informationthat you enter, or upload, or consent to our disclosure by a third party tomake it available to you when you access your User Account.
· We may useInformation for loss prevention and anti-fraud purposes, and to comply withregulatory and legal requirements.
· We may useInformation to help us create, develop, operate, deliver, support and improvethe Otto Service, its content and advertising provided to you through it(Otto’s and third parties’) unless you have decided not to receive suchadvertising.
· We may collect location data through the use of GPS technologyand your IP address where applicable to services you have requested, e.g.,ensuring you are connected to an optical healthcare provider that is licensedor authorized to provide such services in the jurisdiction where you arelocated. We also use your IP address for security purposes, e.g., presentingyou with information about your account activity in your account settings.
Provision of the Otto Service for Patients
· We use your opticalprescription information to order and distribute eyewear directly to you onbehalf of your primary optical health provider.
· We may collect yourprovincial health card number in order to bill provincial health plans forthose services that are eligible for coverage by provincial health plans.
· We use your personalinformation to provide you with a complete and protected electronic healthrecord.
· We use informationthat you enter to provide you with services that you request us to perform onyour behalf, e.g., securely faxing your prescription to your chosen optometry.
· We use yourInformation to text or email you to notify you about services that you request.For example, we notify you about the status of your prescription order andother requests such as prescription expiry.
· You may choose toenter or upload and store your Information in the Otto Service such as yourmedical records, and the name and contact information for your emergencycontact.
· When using our services, you may also choose to enter or uploadand store Information about individuals for whom you have legal authority tomake decisions regarding their healthcare and for whom you have created aprofile by providing their first and last name, gender and date of birth (eacha “Registered Dependent”). We use their date of birth where applicable and yourassertion of their relationship with you to confirm your eligibility to obtainHealthcare Services for them, and their eligibility to receive HealthcareServices.
5. Cookies and similar technologies
Information we collect through cookies and otherautomatic data collection technologies
As you navigate through and interact with our Service,we may use cookies or other automatic data collection technologies to collectcertain information about your equipment, browsing actions, and patterns,including:
· • Details of yourvisits to our Service, including traffic data, location data, logs, and othercommunication data and the resources that you access and use on the Service.
· • Information about your computer andinternet connection, including your IP address, operating system, and browsertype.
We may also use these technologies to collectinformation about your online activities over time and across third-partyServices or other online services (behavioral tracking). To learn more or toopt-out of tailored advertising please visit Digital Advertising Alliance ofCanada Opt-Out Tool for information on how you can opt out of behavioraltracking on this Service and how we respond to web browser signals and othermechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically is statisticalinformation and may include personal information and we may maintain it orassociate it with personal information we collect in other ways, that youprovide to us, or receive from third parties. It helps us to improve ourService and to deliver a better and more personalized service, including byenabling us to:
· Estimate ouraudience size and usage patterns.
· Store informationabout your preferences, allowing us to customize our Service according to yourindividual interests.
· Speed up yoursearches.
· Recognize you when you return to our Service.
The technologies we use for this automatic datacollection may include:
· Cookies (or browsercookies). A cookie is a small file placed on the hard drive of yourcomputer. You may refuse to accept browser cookies by activating theappropriate setting on your browser. However, if you select this setting youmay be unable to access certain parts of our Service. Unless you have adjustedyour browser setting so that it will refuse cookies, our system will issuecookies when you direct your browser to our Service.
· Flash Cookies. Certainfeatures of our Service may use local stored objects (or Flash cookies) tocollect and store information about your preferences and navigation to, from,and on our Service. Flash cookies are not managed by the same browser settingsthat are used for browser cookies. For information about managingyour privacy and security settings for Flash cookies, see ChoicesAbout How We Use and Disclose Your Information.
· Web Beacons. Pages of our Service [and our e-mails]may contain small electronic files known as web beacons (also referred to asclear gifs, pixel tags, and single-pixel gifs) that permit the Company, forexample, to count users who have visited those pages or [opened an email] andfor other related Service statistics (for example, recording the popularity ofcertain Service content and verifying system and server integrity).
Third party use of cookies and other trackingtechnologies
Some content or applications on the Service, includingadvertisements, are served by third-parties, including advertisers, ad networksand servers, content providers, and application providers. These third partiesmay use cookies alone or in conjunction with web beacons or other trackingtechnologies to collect information about you when you use our Service. Theinformation they collect may be associated with your personal information orthey may collect information, including personal information, about your onlineactivities over time and across different Services and other online services.They may use this information to provide you with interest-based (behavioural)advertising or other targeted content. In addition to helping advertisers reachthe right people for their products and services, behavioural advertising helpssupport our Service so that you can enjoy free content.
You can opt-out of several third party ad servers’ andnetworks’ cookies simultaneously by using an opt-out tool created by theDigital Advertising Alliance of Canada and/or an opt-out tool created by theNetwork Advertising Initiative. You can also access these websites to learnmore about online behavioural advertising and how to stop websites from placingcookies on your device. Opting out of a network does not mean you will nolonger receive online advertising. It does mean that the network from which youopted out will no longer deliver ads tailored to your web preferences and usagepatterns.
We do not control these third parties’ trackingtechnologies or how they are used. If you have any questions about anadvertisement or other targeted content, you should contact the responsibleprovider directly. For more information about how you can opt out of receivingtargeted advertising from many providers, see Choices About How We Use andDisclose Your Information.
6. Disclosure of your personal information
We may disclose aggregated information about our users,and information that does not identify any individual, without restriction. We may disclose personal information that we collect oryou provide as described in this privacy policy:
· To our subsidiariesand affiliates.
· In accordance withapplicable law, to a buyer or other successor in the event of a merger,divestiture, restructuring, reorganization, dissolution, or other sale ortransfer of some or all of Otto Optical System’s assets, whether as a goingconcern or as part of bankruptcy, liquidation, or similar proceeding, in whichpersonal information held by Otto about our customers and users is among theassets transferred.
· To advertisers andadvertising networks that require the information to select and serve relevantadvertisements to you and others. We do not disclose data about identifiableindividuals to our advertisers, but we may provide them with aggregate informationabout our users (for example, we may inform them that 400 women between 30 and45 have clicked on their advertisement on a specific day). We may also use suchaggregate information to help advertisers target a specific audience (forexample, men in a specific location). We may make use of the personalinformation we have collected from you to enable us to display our advertisers’advertisement to that target audience.
· To third parties tomarket their products or services to you if you have consented to/not opted outof these disclosures. We contractually require these third parties to keeppersonal information confidential and use it only for the purposes for which wedisclose it to them. For more information, see “choices about how we use anddisclose your information”.
· To contractors,service providers, and other third parties we use to support our business (suchas analytics and search engine providers that assist us with Serviceimprovement and optimization) and who are contractually obligated to keeppersonal information confidential, use it only for the purposes for which wedisclose it to them, and to process the personal information with the samestandards set out in this policy.
· To fulfill thepurpose for which you provide it. For example, if you give us an email addressto use the “email a friend” feature of our Service, we will transmit thecontents of that email and your email address to the recipients.· For any otherpurpose disclosed by us when you provide the information.
· With your consent.
We may also disclose your personal information:
· To comply with anycourt order, law, or legal process, including to respond to any government orregulatory request, in accordance with applicable law.
· To enforce or applyour Terms of Use or terms of sale and otheragreements, including for billing and collection purposes.
· If we believe disclosure is necessary or appropriate to protectthe rights, property, or safety of Otto Optical Systems Inc., our customers, orothers. This includes exchanging information with other companies andorganizations for the purposes of fraud protection and credit risk reduction.
7. Transferring your personal information
We may transfer personal information that we collect orthat you provide as described in this policy to contractors, serviceproviders, and other third parties we use to support our business (such asanalytics and search engine providers that assist us with Service improvementand optimization) and who are contractually obligated to keep personalinformation confidential, use it only for the purposes for which we disclose itto them, and to process the personal information with the same standards setout in this policy.
We may process, store, and transfer your personalinformation in and to a foreign country, with different privacy lawsthat may or may not be as comprehensive as Canadian law. In thesecircumstances, the governments, courts, law enforcement, or regulatory agenciesof that country may be able to obtain access to your personal informationthrough the laws of the foreign country. Whenever we engage a service provider,we require that its privacy and security standards adhere to this policy andapplicable Canadian privacy legislation.
You are welcome to contact us to obtain furtherinformation about Company policies regarding service providersoutside of Canada. By submitting your personal information or engaging with theService, you consent to this transfer, storage, or processing.
8. Choices about how we use and disclose your personalinformation
We strive to provide you with choices regarding thepersonal information you provide to us. We have created mechanisms to provideyou with the following control over your information:
· TrackingTechnologies and Advertising. You can set your browser to refuse allor some browser cookies, or to alert you when cookies are being sent. To learnhow you can manage your Flash cookie settings, visit the Flash player settingspage on Adobe’s Service. If you disable or refuse cookies, please note thatsome parts of this Service may not be accessible or may not function properly.For more information about tracking technologies, see Information We CollectThrough Cookies and Other Automatic Data Collection Technologies.
· Third-PartyAdvertising. If you do not want us to share your personal informationwith unaffiliated or non-agent third parties for promotional purposes, you canopt-out by checking the relevant box located on the form where we collect yourdata (the order form/registration form). You can also opt-out by logging intothe Service and adjusting your user preferences in your account profile bychecking or unchecking the relevant boxes or by sending us an email statingyour request to help@ottooptics.io.
· Promotional Offersfrom the Company. If you have opted in to receive certain emails from us butno longer wish to have your email address/contact information used by theCompany to promote our own or third parties’ products or services, you canopt-out by checking the relevant box located on the form on which we collectyour data (the order form/registration form) or at any other time by logginginto the Service and adjusting your user preferences in your account profile bychecking or unchecking the relevant boxes or by sending us an email statingyour request to help@ottooptics.io. If we have sent you a promotional email,you may unsubscribe by clicking the unsubscribe link we have included in theemail. This opt-out does not apply to information provided to the Company aspart of a product purchase, warranty registration, product service experience,or other transactions.
· Targeted Advertising. If you do not want us to useinformation that we collect or that you provide to us to deliver advertisementsaccording to our advertisers’ target-audience preferences, you can opt out by[OPT-OUT METHOD]. For this opt-out mechanism to function, you must have yourbrowser set to accept browser cookies.
We do not control third parties’ collection or use ofyour information to serve interest-based advertising. However, these thirdparties may provide you with ways to choose not to have your informationcollected or used in this way. You can opt out of several third party adservers’ and networks’ cookies simultaneously by using [an opt-out tool createdby the Digital Advertising Alliance of Canada and/or an opt-out tool created bythe Network Advertising Initiative. You can also access these Services to learnmore about online behavioural advertising and how to stop Services from placingcookies on your device. Opting out of a network does not mean you will nolonger receive online advertising. It does mean that the network from which youopted out will no longer deliver ads tailored to your web preferences and usagepatterns.
9. Data security
The security of your personal information is veryimportant to us. We use physical, electronic, and administrative measuresdesigned to secure your personal information from accidental loss and fromunauthorized access, use, alteration, and disclosure. We store all informationyou provide to us behind firewalls on our secure servers. Any paymenttransactions and personal information will be encrypted using SSL technology.
The safety and security of your information also dependson you. Where we have given you (or where you have chosen) a password foraccess to certain parts of our Service, you are responsible for keeping thispassword confidential. We ask you not to share your password with anyone. Weurge you to be careful about giving out information in public areas of theService like client feedback and review spaces, which any Service visitor canview.
Unfortunately, the transmission of information via theInternet is not completely secure. Although we do our best to protect yourpersonal information, we cannot guarantee the security of your personalinformation transmitted to our Service. Any transmission of personalinformation is at your own risk. We are not responsible for circumvention ofany privacy settings or security measures contained on the Service.
10. Data retention
Except as otherwise permitted or required by applicablelaw or regulation, we will only retain your personal information for as long asnecessary to fulfill the purposes we collected it for, including for thepurposes of satisfying any legal, accounting, or reporting requirements. Undersome circumstances we may anonymize your personal information so that it can nolonger be associated with you. We reserve the right to use such anonymous andde-identified data for any legitimate business purpose without further noticeto you or your consent.
11. Children under the age of 13
Our Service is not intended for children under 13 yearsof age. No one under age 13 may provide any information to or on the Service.We do not knowingly collect personal information from children under 13. If youare under 13, do not use or provide any information on this Service or on orthrough any of its features/register on the Service, make any purchases throughthe Service, use any of the interactive or public comment features of thisService, or provide any information about yourself to us, including your name,address, telephone number, email address, or any screen name or user name youmay use. If we learn we have collected or received personal information from achild under 13 without verification of parental consent, we will delete thatinformation. If you believe we might have any information from or about a childunder 13, please contact us at help@ottooptics.io.
12. Accessing and correcting your personal information
It is important that the personal information we holdabout you is accurate and current. Please keep us informed if your personalinformation changes. By law you have the right to request access to and tocorrect the personal information that we hold about you.
You can review and change your personal information bylogging into the Service and visiting your account profile page.
If you want to review, verify, correct, or withdrawconsent to the use of your personal information you may also send us an emailat help@ottooptics.io. to request access to, correct, or delete any personalinformation that you have provided to us. We cannot delete your personalinformation except by also deleting your user account. We may not accommodate arequest to change information if we believe the change would violate any law orlegal requirement or cause the information to be incorrect. We may charge you afee to access your personal information, however, we will notify you of any feein advance.
We may request specific information from you to help usconfirm your identity and your right to access, and to provide you with thepersonal information that we hold about you or make your requested changes.Applicable law may allow or require us to refuse to provide you with access tosome or all of the personal information that we hold about you, or we may havedestroyed, erased, or made your personal information anonymous in accordancewith our record retention obligations and practices. If we cannot provide youwith access to your personal information, we will inform you of the reasonswhy, subject to any legal or regulatory restrictions.
We will provide access to your personal information,subject to exceptions set out in applicable privacy legislation.Examples of such exceptions include:
· Informationprotected by solicitor-client privilege.
· Information that ispart of a formal dispute resolution process.
· Information that isabout another individual that would reveal their personal information orconfidential commercial information.
· Information that is prohibitively expensive to provide.
13. Withdrawing your consent
Where you have provided your consent to the collection,use, and transfer of your personal information, you may have the legal right towithdraw your consent under certain circumstances.
To withdraw your consent, if applicable, contact us at help@ottooptics.io. Please note that if you withdraw your consent we may not beable to provide you with a particular product or service. We will explain theimpact to you at the time to help you with your decision.
14. Changes to our privacy policy
It is our policy to post any changes we maketo our privacy policy on this page with a notice thatthe privacy policy has been updated on the Service home page. Ifwe make material changes to how we treat our users’ personal information, wewill notify you by email to the primary email address specified in your accountand through a notice on the Service home page.
We include the datethe privacy policy was last revised at the top of the page. Youare responsible for ensuring we have an up-to-date, active, and deliverableemail address for you, and for periodically visiting our Service and this privacy policy tocheck for any changes.
15. Contact information and challenging compliance
We welcome your questions, comments, and requestsregarding this privacy policy andour privacy practices. Please contact us at:
Chief Privacy Officer
Mr. Alexander McIntosh, Chief Executive Officer
alex@ottooptics.io
We have procedures in place to receive and respond tocomplaints or inquiries about our handling of personal information, ourcompliance with this policy, and with applicable privacy laws.To discuss our compliance with this policy please contact our ChiefPrivacy Officer using the contact information listed above.