PRIVACY POLICY

Effective Date: December 2025
Last Updated: March 2026

This Privacy Policy describes how Ottri Inc. (“Ottri,” “we,” “us,” or “our”) collects, uses, shares, and protects information when individuals or businesses interact with the Ottri platform, including websites, applications, dashboards, embedded widgets, and APIs (the “Platform”).

1. Scope

This Privacy Policy applies to information collected through the Platform.

It applies to:

  • Merchants and merchant personnel
  • Partners and authorized users
  • Consumers interacting with Ottri-powered experiences through a Merchant
  • Any visitors to our Platform

This Policy does not apply to lender-controlled application portals or third-party websites or services not operated by Ottri. Lenders maintain their own privacy practices and notices.

2. Ottri’s Role

Ottri provides technology infrastructure and platform functionality. Ottri does not underwrite loans, make credit decisions, set loan terms, or service loans.

Licensed activities, where required by applicable law, are conducted by Ottri Global LLC (NMLS ID 2776988). Licensed entities do not operate or control the Platform.

3. Categories of Information We Collect

Ottri collects information necessary to operate the Platform. Depending on the interaction, this may include:

A. Identifiers and Contact Information

Business names, contact names, email addresses, phone numbers, Social Security numbers, dates of birth, and similar identifiers.

B. Commercial and Business Information

Merchant onboarding information, ownership and control data, verification outputs, and transaction-related metadata.

C. Internet or Device Activity

IP address, browser type, device information, session data, and Platform usage logs.

D. Limited Consumer Information (Routing Use Only)

With consumer consent, limited information such as name, contact details, and identifiers required to facilitate a soft credit inquiry for routing purposes.

E. Sensitive Personal Information

Where applicable, sensitive personal information may be processed in a limited manner for verification or routing, subject to legal and contractual controls.

Ottri does not require consumers to submit full loan applications, banking login credentials, or identity documents directly to Ottri. Such information is generally collected by the lender, or by service providers acting on Ottri’s behalf, depending on the financing flow.

4. How We Use Information

Ottri uses information to:

  • Operate, maintain, and secure the Platform
  • Verify Merchant, Partner, and authorized user information
  • Facilitate consumer soft credit inquiries with consent
  • Route consumers to participating Lenders
  • Comply with legal, licensing, and regulatory obligations
  • Communicate with consumers, merchants, lenders, and partners

We may communicate with you or others by phone, SMS, WhatsApp, and other messaging channels.

Ottri may use aggregated or de-identified information for analytics, security, and platform improvement. Such information does not identify individuals or businesses.

You may opt out of messaging at any time by replying STOP to any message or emailing privacy@ottri.com.

5. Credit Information and Soft Pulls

With consumer consent obtained in the Platform experience, Ottri may facilitate a soft credit inquiry for routing purposes.

  • Soft credit inquiries are typically not used by credit reporting agencies in credit score calculations
  • Results are used to help route and present potential financing options
  • Results do not guarantee approval, final terms, APR, or funding
  • Ottri does not make credit decisions
  • Lenders perform independent credit evaluations

6. How We Share Information

Ottri may share information with:

  • Participating Lenders, limited to routing and eligibility purposes and with appropriate consent
  • Consumer reporting agencies and other data providers
  • Service providers that support Platform or Ottri operations, under appropriate contractual confidentiality and security obligations
  • Ottri Global LLC for licensing and compliance purposes
  • Regulators or authorities when required by law
  • Others when provided for by law
  • Ottri does not share mobile information or data with third parties for marketing or promotional purposes

7. Third-Party Services

The Platform integrates with third-party services and Lender systems. These third parties process information as necessary to provide services to Ottri and are subject to contractual restrictions.

Lenders and third-party services maintain their own privacy policies. Ottri is not responsible for the privacy practices of third parties not under its control.

8. Data Security and Retention

Ottri maintains commercially reasonable administrative, technical, and physical safeguards designed to protect information. Information is retained only as long as necessary for Platform operations, legal obligations, compliance, and security purposes. We securely dispose of information when appropriate.

Ottri does not transfer consumer data to external organizations except as described in this Policy, and maintains strict controls to prevent unauthorized sharing.

Platform safeguards are designed to ensure the confidentiality and security of Social Security numbers. Ottri limits access to Social Security numbers to those who need to process the information and prohibits the unlawful disclosure of Social Security numbers.

9. Cookies and Analytics

Ottri uses cookies and similar technologies for security, fraud prevention, session management, and performance analytics. Analytics tools may be used to measure performance and improve Platform functionality.

Ottri does not track Platform users over time and across multiple sites, and third parties do not collect personal information on Platform users. Ottri does not send promotional marketing communications to consumers based on Platform activity.

Users may control cookies through browser settings.

The Platform does not respond to Do Not Track signals.

10. State Privacy Rights

Residents of certain U.S. states may have rights under applicable privacy laws, which may include the right to:

  • Access Personal Information
  • Correct inaccuracies
  • Request deletion where permitted by law
  • Obtain a copy of Personal Information
  • Opt out of certain processing activities

To exercise these rights, contact privacy@ottri.com.

California residents may also exercise opt-out rights through the "Your Privacy Choices" link available on the Ottri website.

We may require verification of your identity before processing a request. Authorized agents may submit requests on your behalf where permitted by law.

Ottri will respond within the timeframes required by applicable law, which are generally within 45 days and may be extended where permitted. If a request is denied, you may appeal by contacting privacy@ottri.com.

11. Children’s Privacy

The Platform is intended for users 18 years of age or older. Ottri does not knowingly collect information from minors. If Ottri learns that the Platform has collected or received personal information from a child under 18, Ottri will delete that information. If you believe Ottri might have any information from or about a child under 16, please contact us by emailing us at privacy@ottri.com.

12. U.S. Operations and International Access

The Platform is intended for use in the United States. Information is primarily processed and stored in the United States and may be accessed by authorized personnel or service providers from other locations as necessary to support Platform operations.

13. Changes to This Policy

Ottri may update this Privacy Policy from time to time. Updates will be posted with a revised “Last Updated” date. Please check this Policy for changes.

14. Contact Information

For questions about our messaging practices, contact privacy@ottri.com or call 800-809-0011

Privacy inquiries and rights requests:
privacy@ottri.com

Operational support:
support@ottri.com

Mailing Address:
Ottri Inc
110 E Broward Blvd, Suite 1580
Fort Lauderdale, FL 33301
Phone: 800-809-0011