Privacy Policy

This Privacy Policy describes how Ottri (“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”).

Scope

This Privacy Policy applies to information collected through the Platform. It applies to:

• Merchants and merchant personnel, including owners, principals, and officers
• Partners and authorized users
• Lenders and their 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.

For purposes of this Privacy Policy, “Ottri Global LLC” refers to Ottri Global LLC, a Delaware limited liability company (NMLS ID 2776988) that holds state financial services licenses where required and conducts only those licensed activities for which it is authorized in each applicable jurisdiction. “Ottri Inc.” refers to Ottri Inc., a Delaware corporation and an affiliate of Ottri Global LLC that operates the Ottri Platform technology. References to “Ottri,” “we,” “us,” and “our” refer to the entity whose activities are described in the relevant provision. Both entities are subject to this Privacy Policy with the following allocation of responsibilities:

(a) Ottri Global LLC is the contracting party with Merchants, Partners, and Lenders and is the controller of personal information collected in connection with merchant onboarding, partner services, lender relationships, consumer financing requests, and its state-licensed activities, including merchant owner identity and credit report information it obtains under the Merchant Platform Services Agreement. Ottri Global LLC is the responsible party for obligations specific to those activities under applicable federal and state financial services and privacy laws. This Privacy Policy is Ottri Global LLC’s privacy notice under the Gramm-Leach-Bliley Act and applicable state financial privacy laws for those activities.

(b) Ottri Inc. operates the Platform technology and provides technology, infrastructure, and operational support to Ottri Global LLC, processing personal information on Ottri Global LLC’s behalf for those purposes. Ottri Inc. is the controller of information collected from visitors to Ottri’s public marketing website who do not otherwise have a relationship with Ottri Global LLC. Ottri Inc. does not originate, underwrite, fund, or service credit and does not engage in lending, underwriting, or other regulated consumer-facing activities.

Where this Privacy Policy describes an activity, the responsible entity is the entity whose role corresponds to that activity under (a) or (b) above. The Ottri Terms of Service identify the applicable Ottri contracting entity. If you have signed an agreement with Ottri, such as a Merchant Platform Services Agreement, a Partner Agreement, a lender agreement, or a Business Associate Agreement, that agreement also governs how Ottri handles information under it.

Notice at Collection

If you are a California resident, the categories of personal information we collect, the purposes for which we use it, the third parties we share it with, whether it is sold or shared, and our retention practices are described in the “State Privacy Rights” section of this Policy. Ottri does not sell personal information for money. Ottri may use advertising cookies and similar technologies that may constitute a “sale,” “sharing,” or targeted advertising under certain state privacy laws. You may opt out through Your Privacy Choices or supported universal opt-out preference signals where required by law.

Ottri’s Role

Ottri is a technology platform. Ottri does not originate, underwrite, fund, or service credit, does not make credit decisions, does not determine eligibility for credit, and does not set interest rates, fees, repayment terms, or other credit terms. All of those matters are determined solely by independent participating lenders.

Where applicable law requires a licensed entity to conduct a particular consumer financing-related activity, that activity is conducted by Ottri Global LLC, NMLS ID 2776988, under its state financial services licenses where required. With consumer consent, Ottri Global LLC obtains consumer report information solely to determine the lender offers for which the consumer may prequalify, as described in “Credit Information and Soft Pulls” below. With a Merchant owner’s written authorization, Ottri Global LLC may also obtain that owner’s credit report, as described in “Merchant Owner Information and Credit Reports” below.

Data Controller and Processor Roles

Ottri’s role in relation to data varies depending on the context:

When Ottri collects and uses information for its own business purposes, such as operating the Platform, onboarding and verifying Merchants, routing, fraud prevention, complying with regulatory obligations, performing analytics, and maintaining security, Ottri acts as the data controller. This includes merchant onboarding data, routing and fraud data, and Platform operational data.

Ottri acts as a processor for a Lender only when it transmits applications, presents offers, or facilitates funding on that Lender’s documented instructions.

When a medical practice uses the Platform, Ottri Global LLC acts as the practice’s business associate under HIPAA for the limited information described in “Health Information” below.

Partners do not control consumer data processing. A Referring Partner that supports a home improvement Merchant for Ottri under a written agreement may see limited consumer information about that Merchant’s customers, as described in the “How We Share Information” section. Otherwise, Partner access is limited to the Merchant business information described in that section.

Categories of Information We Collect

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

How We Collect Data

Ottri collects information through three methods:

Directly from you

Information you provide when interacting with the Platform, including merchant onboarding forms, consumer financing applications, partner registration, and communications with Ottri.

Automatically

Information collected through cookies, server logs, and similar technologies when you access or use the Platform, including IP address, browser type, device information, and session activity.

From third parties

Information received from consumer reporting agencies, identity verification providers, business verification providers, participating lenders, referring Merchants, and other service providers in connection with Platform operations, including credit data (with consumer consent or, for a Merchant owner, that owner’s written authorization), verification outputs, and publicly available business information.

How We Use Information

Ottri uses information to:

• Operate, maintain, and secure the Platform
• Verify Merchant, owner, Partner, and authorized user information
• Verify consumer identity and prevent fraud through identity verification providers
• Facilitate consumer soft credit inquiries with consent, solely to determine the lender offers for which a consumer may prequalify
• Route consumers to participating Lenders
• Obtain a Merchant owner’s credit report, with that owner’s written authorization, solely to decide whether, and to which Lender, to submit the Merchant’s application
• Place calls and send text messages, including automated, prerecorded, and AI-voice calls, as described in “Calls, Recording, and Artificial Intelligence”
• Send business users information about Platform features and offers, with marketing calls and texts sent only to those who opted in on the Platform’s sign-up page
• Comply with legal, licensing, and regulatory obligations
• Communicate with consumers, merchants, lenders, and partners

Consumer information Ottri receives from a Merchant or a Lender is used only to provide the services under Ottri’s agreement with that party and as applicable law permits. Ottri may create aggregated or de-identified information for analytics, security, compliance, and platform improvement where the law allows. Such information does not identify individuals or businesses. Ottri does not sell personal information, and does not use personal information to train large language models or other generative AI systems.

Messaging Practices and Mobile Information

This section describes how Ottri collects and uses mobile phone numbers and messaging and calling consent data. Calls and text messages described in this Policy are sent by Ottri Global LLC and Ottri Inc.

What we collect. When you provide a mobile phone number to Ottri, we collect that number, the date, time, and method of your consent, the messaging or calling program you opted in to, and your opt-out status.

How we use it. We use mobile phone numbers to send the messages and place the calls you have opted in to receive. Depending on the program you selected, messages may include account notifications, onboarding and activation steps, financing application status updates, requests for information or documents that a Lender has asked for, customer support communications, and, only where you opted in to them on the Platform’s sign-up page, marketing or promotional messages about the Platform. Ottri may use artificial intelligence to write and answer text messages. Message frequency varies based on your account activity and lifecycle stage and may include multiple messages per day during active onboarding, activation, support, or re-engagement periods. Message and data rates may apply.

Non-sharing of mobile information. We do not share, sell, or provide your mobile phone number or messaging consent data to third parties or affiliates for marketing or promotional purposes. Apart from a consumer’s phone number included in a financing application sent to participating Lenders, and Merchant owner contact details shared with a Referring Partner as described in “How We Share Information,” mobile phone numbers are disclosed only to service providers acting on Ottri’s behalf, such as messaging and calling platform vendors and compliance vendors, solely to deliver messages and calls, maintain opt-out lists, honor revocation requests, and support Ottri’s legal and regulatory obligations. These service providers are contractually prohibited from using mobile information for any purpose other than performing services for Ottri. Messaging and calling consent data is never shared with Lenders or Partners.

Consent is specific to Ottri. Your messaging and calling consent is collected by and for Ottri only. It is not transferred, assigned, or extended to any other sender or caller. If you interact with a participating lender, that lender obtains its own consent for any messages it sends or calls it makes.

Opting out. You may opt out of text messages and automated calls at any time by replying STOP, QUIT, END, REVOKE, OPT OUT, CANCEL, or UNSUBSCRIBE to any message, by telling us during a call, by emailing privacy@ottri.com or support@ottri.com, or by calling (800) 809-0011. We honor opt-out requests within 10 business days, and an opt-out applies to all automated calls and text messages from Ottri to that number. For help, reply HELP, email privacy@ottri.com or support@ottri.com, or call (800) 809-0011.

Carriers are not liable for delayed or undelivered messages.

Calls, Recording, and Artificial Intelligence

This section describes how Ottri places and handles phone calls.

Calls to business users. Ottri may call Merchants, Partners, and their personnel at numbers they have consented to, about their account, onboarding, verification, support, and service, including requests for information or documents that a Lender has asked for. These calls may use an automatic telephone dialing system or an artificial or prerecorded voice, including a voice generated by artificial intelligence. Ottri places marketing calls only to people who opted in to them on the Platform’s sign-up page. Consent to these calls is not a condition of using the Platform or buying anything.

Recording and artificial intelligence. Calls with Ottri, including calls you place to us, may be monitored, recorded, transcribed, and analyzed, including while they are in progress. Ottri may use artificial intelligence to place, conduct, and summarize calls and to write and answer text messages. Ottri uses call recordings, transcripts, and summaries to deliver the communications described in this Policy, provide support, keep records, and secure and improve Ottri’s services.

Who processes call data. Calling, messaging, recording, transcription, and artificial intelligence providers process call recordings, transcripts, and summaries on Ottri’s behalf under contract. Ottri does not sell call recordings or transcripts and shares them only with those service providers and as otherwise described in this Policy.

Stopping calls. You may stop automated calls at any time by saying so during a call or by any method described under “Opting out” above. Ottri honors these requests within 10 business days.

Legal Basis for Processing

Ottri processes information on the following grounds, as applicable:

Consent

Where you have given consent or authorization, such as consent to a soft credit inquiry, a Merchant owner’s written authorization for a credit report, consent to receive text messages or automated calls, consent to call recording, or acceptance of non-essential cookies. You may withdraw consent at any time by contacting support@ottri.com. Privacy rights requests may also be submitted to privacy@ottri.com.

Contractual necessity

Where processing is necessary to perform or enter into an agreement with you, including merchant onboarding, platform access, and partner services.

Legitimate interest

Where processing is necessary for Ottri’s legitimate business interests, such as platform security, fraud prevention, analytics, and service improvement, provided those interests are not overridden by your rights and interests.

Legal obligation

Where processing is required to comply with applicable laws, regulations, licensing requirements, or legal process.

Credit Information and Soft Pulls

With consumer consent obtained in the Platform experience, Ottri Global LLC obtains soft-pull consumer report information from TransUnion solely to determine the lender offers for which the consumer may prequalify. Ottri tells the consumer whether the consumer has prequalified for any offers. Consumer identity verification and fraud prevention are performed through separate identity verification providers, not through this consumer report information. Ottri’s rules for routing and ordering lenders do not use a consumer’s credit information.

Ottri does not disclose consumer report information or credit scores it obtains to any Lender, Merchant, Partner, or other third party, except service providers acting on Ottri’s behalf and as required by law. A Lender that considers your application obtains its own credit report.

Soft credit inquiries are not used by major credit-scoring models, including FICO and VantageScore, in score calculations. Prequalification results are preliminary and do not guarantee approval, final terms, APR, or funding.

Ottri Global LLC does not make credit decisions, determine eligibility for credit, set APRs, fund loans, or service loans. Participating lenders perform independent credit evaluations and determine all loan terms, approvals, denials, and funding decisions.

Under the Fair Credit Reporting Act, you have the right to know if information in your consumer file has been used against you, to dispute incomplete or inaccurate information, and to limit prescreened offers of credit. For more information about your rights under the FCRA, visit the Consumer Financial Protection Bureau at consumerfinance.gov or contact the nationwide consumer reporting agencies.

If you accept a financing offer or submit an application to a participating lender, that lender may conduct a hard credit inquiry as part of its independent evaluation, processing, or servicing of your loan. A hard credit inquiry may affect your credit score.

Merchant Owner Information and Credit Reports

A Merchant must provide identifying information for each of its owners, principals, and officers, including full name, date of birth, current and previous residential addresses, and Social Security number, so that Ottri can verify the identity of each owner.

If you sign the Merchant Platform Services Agreement on behalf of a Merchant and you are an owner of that Merchant, you provide written instructions under the Fair Credit Reporting Act authorizing Ottri Global LLC to obtain your personal consumer credit report from one or more consumer reporting agencies when you sign and before any later submission of the Merchant’s application to a Lender. Ottri Global LLC obtains each report as a soft inquiry, which does not affect your credit score, and uses it solely to decide whether, and to which Lender, to submit the Merchant’s application. Ottri does not share the report, or information derived from it, with any Lender, Partner, or other third party. Ottri obtains a credit report only on an owner who has given this authorization.

Information You Provide Before Submitting

If you provide information during your application but do not click ”Agree & Continue” to submit, we may retain that information so you can resume your application if you return, maintain security, prevent fraud, and improve the Platform. We do not use that information to obtain a soft credit inquiry or share it with participating lenders unless you complete the required authorization and submit your financing request.

Health Information

Ottri is a financing technology platform and is not a health care provider. A medical practice provides patient information to Ottri only after signing Ottri’s Business Associate Agreement.

When a medical practice uses the Platform, Ottri Global LLC acts as the practice’s business associate under the Health Insurance Portability and Accountability Act (HIPAA) for the limited information the practice provides: the patient’s name and contact details that the practice enters to send the financing application link, the procedure the practice selects from the Platform list, and the application status and lender decisions Ottri reports back to the practice. Ottri protects that information as HIPAA and its Business Associate Agreement with the practice require. Ottri’s affiliate Ottri Inc., which operates the Platform, handles that information as Ottri Global LLC’s subcontractor under the same restrictions.

When the patient submits a financing application, Ottri sends the patient’s name and contact details to the lenders that consider the application, and the procedure only to the lenders that need it to decide. These disclosures are made at the patient’s request so the practice can be paid for its services. Ottri does not request diagnoses, medical history, medical records, photos, clinical notes, or insurance details, and deletes any such information it receives.

The financing application a patient completes and submits is received from the patient. It is protected under this Policy and financial privacy law. Ottri treats all procedure or treatment information as sensitive personal information under this Policy. It is never sold and is never used for marketing or advertising.

Residents of Washington, Nevada, and other states with consumer health data laws may exercise the rights described in the “State Privacy Rights” section with respect to health-related information.

How We Share Information

This section describes Ottri’s information sharing practices.

Ottri may share information with:

• Participating lenders, as needed to route, process, evaluate, and support consumer financing requests, and with appropriate consumer consent. Information transmitted to a lender as part of a financing request includes the identity, contact, and application information the consumer provided, which may include the consumer’s phone number so the lender can process the request. This transmission is part of the financing application and is not a disclosure of messaging consent data. Lenders obtain their own consent for any messages they send. Ottri does not disclose consumer report information or credit scores it obtains to any Lender. For Merchants, Ottri shares Merchant business, owner, and financial information with the Lenders to which the Merchant applies through the Platform, but never a Merchant owner’s credit report or information derived from it.
• Consumer reporting agencies and other data providers, as needed to obtain soft-pull consumer report information, verify identity, prevent fraud, verify businesses, and support related Platform operations.
• Service providers, including hosting, analytics, messaging, calling, call recording, transcription, artificial intelligence, compliance, identity verification, fraud prevention, data processing, customer support, and security providers, subject to contractual confidentiality and use restrictions.
• Our affiliate, Ottri Inc., which operates the Platform on Ottri Global LLC’s behalf. Ottri does not share information among its affiliates for marketing purposes.
• Referring merchants and their service providers, limited to information necessary to support the consumer’s project and financing request, including application status, high-level financing outcome, funding status, lender/product status, and project-related identifiers.
• Referring Partners, as described below.
• Regulators, law enforcement, courts, or other third parties, when required or permitted by law, subpoena, court order, regulatory request, legal process, or to protect the rights, property, safety, or security of Ottri, users, consumers, merchants, lenders, or the public.

Referring Partners. Where a Merchant was referred to the Platform by a distribution partner (a “Referring Partner”), and with the Merchant’s authorization in its Merchant Platform Services Agreement, Ottri shares Merchant business information with that Referring Partner through the Platform to support the referral relationship. This information includes business name, logo, website, main vertical, service categories, business phone number, business and mailing addresses, state of incorporation, join date, onboarding, account, and agreement status, business verification and tax identification verification status, annual revenue, average job size, publicly available business data (such as ratings, review counts, and business status), whether compliance documents have been provided, owner names, owner email addresses, owner phone numbers, and transaction status. Ottri never shares with a Referring Partner Social Security numbers, dates of birth, owner residential addresses, tax identification numbers, ownership percentages, identity verification, fraud screening, or sanctions screening results, bank account or routing numbers, bank statements, financial account connection data, third-party financial analysis outputs, or compliance document files. A Merchant may revoke this sharing by written notice to Ottri. Revoking may limit the Referring Partner’s ability to support the Merchant.

Consumer information shared with Referring Partners. Where a Referring Partner supports a home improvement Merchant’s customers for Ottri under a written agreement that limits its use of the information to that support, Ottri may share with that Referring Partner, for that Merchant’s customers only: the consumer’s name, email address, phone number, and property address; the income, employment, requested amount, and project information the consumer entered in the application; and the application status. Where the participating lender permits, Ottri may also share the financing outcome, funding status, and lender/product status. Ottri never shares with a Referring Partner a consumer’s Social Security number, date of birth, government identifiers, consumer report information, credit score, bank or financial account information, or health or treatment information, and never shares any consumer information for medical Merchants. A Referring Partner may not contact the consumer, may use the information only to support the Merchant, and must protect and delete it as its agreement with Ottri requires.

Ottri does not share any consumer report information, credit score, or Social Security number with the referring Merchant. Other information may be shared only as described in this Policy and as permitted by law.

Ottri does not share a Merchant owner’s credit report, or information derived from it, with any Lender, Partner, or other third party.

We do not share, sell, or provide your mobile phone number or messaging consent data to third parties or affiliates for marketing or promotional purposes.

Gramm-Leach-Bliley Act Notice

This Privacy Policy is Ottri Global LLC’s privacy notice under the Gramm-Leach-Bliley Act and Regulation P (12 C.F.R. Part 1016) for its licensed consumer financing activities. It applies to current and former consumers alike.

What we collect. The categories of nonpublic personal information we collect are described in “Categories of Information We Collect,” and include information from your application, from consumer reporting agencies, and from identity verification providers.

What we disclose and to whom. We disclose the identity, contact, and application information you provide to the participating lenders that consider your financing request; application status, financing outcome, and funding status to the referring Merchant; your name, contact details, property address, the application information you entered (other than your Social Security number and date of birth), and application status to the Referring Partner that supports your home improvement Merchant for us under a contract that restricts its use of the information; identifying information to consumer reporting agencies and identity verification providers to process your request; the categories of information described in “Categories of Information We Collect” to service providers that perform services for us under contracts that restrict their use of the information; and information to our affiliate Ottri Inc., which operates the Platform for us. We also disclose information as required or permitted by law. We do not disclose nonpublic personal information to nonaffiliated third parties for their own marketing, we do not disclose it under joint marketing agreements, and we do not share it among affiliates for marketing.

Your right to limit sharing. Because we share nonpublic personal information only as permitted by law without an opt-out, you have no opt-out to exercise today. If our sharing practices change in a way that gives you a right to opt out, we will provide you with a revised notice and an opportunity to opt out before any such sharing occurs.

How we protect your information. We maintain physical, electronic, and procedural safeguards that comply with federal standards to protect your nonpublic personal information, and we limit access to those who need it to provide our services. See “Data Security and Retention.”

Questions. Contact privacy@ottri.com or call (800) 809-0011.

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 may not use Platform data to market to consumers outside the Platform. Lenders and third-party services maintain their own privacy policies. When you accept a financing offer from a participating lender, that lender’s privacy policy will then govern your continued relationship with that lender, and we will identify the lender to you at the point you receive an offer. Ottri is not responsible for the privacy practices of third parties not under its control.

Data Security and Retention

Ottri maintains administrative, technical, and physical safeguards designed to protect information, consistent with industry standards and applicable regulatory requirements. Safeguards include encryption of data in transit and at rest, role-based access controls, continuous monitoring, and regular security assessments.

Ottri retains personal information for the period necessary to fulfill the purposes described in this Policy and to comply with legal, licensing, and regulatory record-retention obligations. Retention periods by category are set out in the “State Privacy Rights” section. We securely dispose of information when the applicable retention period expires and no legal or regulatory obligation requires further retention.

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.

Cookies and Tracking Technologies

Ottri uses cookies and similar technologies on its website and Platform for the following purposes:

Essential cookies are used for security, fraud prevention, session management, and core Platform functionality. These cookies are necessary for the website and Platform to operate and cannot be disabled.

Analytics and behavioral cookies, including Google Analytics, HubSpot, Customer.io, and session replay tools, are used to measure website performance, understand how visitors interact with our website, attribute leads, deliver lifecycle communications, and improve Platform functionality. These tools may collect information such as pages visited, time on site, click and scroll behavior, referring URLs, form submissions, and email engagement. Analytics data is processed by third-party service providers and may be transferred to servers outside the United States.

Advertising cookies, including Meta Pixel, LinkedIn Insight Tag, and Google Ads conversion tracking, are used to measure the effectiveness of Ottri’s marketing campaigns and to deliver relevant advertisements to you on third-party platforms. These cookies may collect information about your browsing activity on the Ottri website and share it with advertising platforms for measurement and targeting purposes. Advertising cookies are used only on Ottri’s public marketing website. They are not used within consumer financing application screens.

When you first visit the Ottri website, you will be presented with a cookie consent notice that allows you to accept or decline non-essential cookies (analytics and advertising). You may update your preferences at any time by clicking the “Your Privacy Choices” link in the website footer. If you decline non-essential cookies, only essential cookies will be used.

Ottri does not send promotional marketing communications to consumers based on Platform activity. Ottri does not sell personal information for money. Ottri may use advertising cookies and similar technologies that may constitute a “sale,” “sharing,” or targeted advertising under certain state privacy laws. You may opt out through Your Privacy Choices or supported universal opt-out preference signals where required by law.

Users may also control cookies through browser settings. Disabling cookies may affect website functionality.

State Privacy Rights

Residents of U.S. states with comprehensive privacy laws have rights that may include the right to:

• Access personal information
• Correct inaccuracies
• Request deletion where permitted by law
• Obtain a copy of personal information in a portable format
• Opt out of the sale of personal data, targeted advertising, and certain profiling
• Limit use and disclosure of sensitive personal information (California residents, CPRA §1798.121)

Certain personal information collected by Ottri Global LLC in connection with its licensed financial services activities is subject to the Gramm-Leach-Bliley Act and is exempt from some state privacy law rights. Information Ottri holds as a business associate under HIPAA may also be exempt. Where an exemption applies, Ottri will tell you in its response.

California Notice at Collection

The table below describes the categories of personal information Ottri has collected in the preceding 12 months, the purposes for which each category is used, the categories of third parties to which it is disclosed for a business purpose, and whether it is sold or shared. Retention periods for each category follow in the next table.

*Internet and device activity may be shared through advertising cookies or similar technologies on Ottri’s public marketing website where advertising cookies are enabled. You may opt out through Your Privacy Choices or supported universal opt-out preference signals where required by law.

Ottri does not sell contact information, Social Security numbers, government identifiers, consumer application information, health or treatment information, credit information, or call recordings. Ottri processes sensitive personal information only for purposes permitted under the CPRA and does not use sensitive personal information to infer characteristics about you.

Retention Periods

A Merchant’s confidential information is returned or destroyed when its Merchant Platform Services Agreement ends or on its reasonable request, except where law, licensing, or regulatory rules require Ottri to keep it.

Sources of Personal Information

Ottri collects personal information directly from you, automatically through the Platform, and from third parties including consumer reporting agencies, identity and business verification providers, participating lenders, and referring Merchants.

How to Exercise Your Rights

To exercise these rights, email privacy@ottri.com or call (800) 809-0011. California residents may also exercise opt-out rights through the “Your Privacy Choices” link available on the Ottri website.

Verification. To protect your information, we will verify your identity before responding to a request to access, correct, or delete personal information. We will ask you to confirm at least three data points we already hold, such as name, email address, phone number, date of birth, or the last four digits of your Social Security number. Requests to opt out of sale, sharing, or targeted advertising do not require verification.

Authorized agents. An authorized agent may submit a request on your behalf where permitted by law. We will require the agent to provide written, signed permission from you or a valid power of attorney, and we may also ask you to verify your identity directly with us.

Universal opt-out signals. Ottri recognizes universal opt-out preference signals, including the Global Privacy Control (GPC), as valid opt-out requests where required by applicable state law. When Ottri detects a GPC signal, it will process the signal as an opt-out of the sale of personal data and targeted advertising for that browser or device.

Timing and appeals. Ottri will respond within the timeframes required by applicable law, generally within 45 days, and may extend that period where permitted. If a request is denied, you may appeal within 45 days by contacting privacy@ottri.com with the subject line “Privacy Appeal.” We will respond to your appeal within 45 days. California residents may also submit complaints to the California Privacy Protection Agency (CPPA). Residents of other states may submit complaints to their respective state attorneys general.

Right to Non-Discrimination

We will not discriminate or retaliate against you for exercising any of your privacy rights. This means we will not deny you goods or services, charge different prices or rates, provide a different level or quality of goods or services, or suggest you may receive different treatment because you exercised your rights under California or other applicable state privacy laws.

California “Shine the Light”

California Civil Code §1798.83 permits California residents to request information about disclosures of personal information to third parties for those third parties’ direct marketing purposes. Ottri does not disclose personal information to third parties for their direct marketing purposes.

Nevada Residents

Ottri does not sell personal information as defined under Nevada law. Nevada residents may submit a request to privacy@ottri.com to confirm this or to opt out of any future sale.

Children’s Privacy

The Platform is intended for adults 18 years of age or older. Ottri does not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a person under 18, we will delete it. Ottri does not knowingly sell or share personal information of consumers under 16 as those terms are defined under the CCPA/CPRA.

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.

Changes to This Policy

Ottri may update this Privacy Policy from time to time. Updates will be posted with a revised “Last Updated” date at the top of this Policy. If we make material changes to how we use or share personal information, we will provide notice through the Platform or by email before the change takes effect. An update to this Policy does not amend any signed agreement, which changes only as that agreement provides.

Contact Us

Ottri Global LLC and Ottri Inc.
110 E Broward Blvd, Suite 1580
Fort Lauderdale, FL 33301

Privacy requests: privacy@ottri.com
Support: support@ottri.com
Phone: (800) 809-0011