Last updated on JUNE 2018
On Track Innovations Ltd. and its wholly owned subsidiaries (“OTI“, “we” or “us”) has created this Privacy Notice to demonstrate our firm commitment to secure and trustworthy internet commerce and the individual’s right to privacy. This Privacy Notice sets OTI’s privacy policies and practices in relation to information that is collected by us through OTI’s websites (www.otiglobal.com, www.otieuropa.com, www.otipetrosmart.com, investors.otiglobal.com), and any web-pages included thereto (collectively: the “Website“).
We strongly urge you to read this Privacy Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please discontinue and avoid Browsing and/or make any other use of the website.
By using the Site, you consent to the collection and use of information terms set forth herein
For What Purposes Do We Use Your Information
We will use your Personal Data in the scope and manners to which we receive your consent; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Websites and the content included thereto, understanding how our Website is used, improving our customer service and support operations, and protecting and securing our users, ourselves and our Website.
Accordingly, we use Personal Data for the following purposes:
- To facilitate, operate, and provide our Website;
- To provide our users with customer care, assistance and technical support;
- To further develop, customize and improve the Website and your user experience, based on personal or general experiences and difficulties;
- To contact our users (via e-mail, or any other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance notices); to contact our users with promotional messages (such as updates, new features and services, newsletters, etc.); and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
- To comply with any applicable laws and regulations.
Promotional Communications. We may also contact you via the email you provide us with in order to notify you about new services, events and special opportunities or any other information we think you will find valuable.
If you wish not to receive such promotional communications, you may notify us at any time by contacting us by filling out the electronic form below, or by following the “unsubscribe”, “stop” or “change e-mail preferences” instructions in the promotional communications you receive.
How Do We Collect Your Information?
We collect two main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as “Personal Data“):
- Data Automatically Collected or Generated. When you visit, interact with or use our Websites, including any e-mail sent to you by us, we may collect or generate technical data about you. We collect or generate such data either independently or with the help of third party services, including through the use of “cookies” and other tracking technologies (as further detailed in our “cookies policy“.
Such data consists of connectivity, technical or aggregated usage data, such as IP address, non-identifying data regarding the device, operating system, browser version locale and language settings used, the cookies and pixels installed on such device, and the activity (clicks and other interactions) of users of our Website.
We do not use such data to learn a person’s true identity or contact details, but mostly to have a better understanding on how our users typically use browse our Website. The use of such technical and device data also helps us and our partners to deliver contextual or otherwise more effective advertisements and content; to optimize our ad management and our users’ viewing experience, and to improve the overall user experience and functionality of our Website.
- Data Received From You. You may provide us Personal Data voluntarily, such as your name, e-mail address, phone number, your bio description, and location when you contact us.
If you choose to give us your e-mail address, we will communicate with you via e-mail. We do not share your e-mail address with others outside OTI. Depending on how your e-mail application is set up, information about your actions, use of the email sent by us, may be transmitted automatically when you receive, open and/ or click on an e-mail from OTI. In any event, you may opt out from receipt of any additional e-mails from OTI, at any time
How Do We Retain and Store Your Information?
On Track Innovations Ltd., is based in a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
While privacy laws may vary between jurisdictions, OTI has taken reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.
In general, we retain your Personal Data for a period of 36 months. However, may retain your Personal Data for a longer period for legal and accounting purposes (i.e., as required by laws applicable to our record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our Data Retention Notice.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
Who Do We Share Information With?
We may share your data (including Personal Data) with certain third parties, including law enforcement agencies, our service providers and our affiliates – but only in accordance with this Privacy Notice:
- Compliance with Laws, Legal Orders and Authorities. We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
- Service Providers and Business Partners. We may engage selected third party companies and individuals to perform services complementary to our own (hosting services, data analytics services, e-commerce, user engagement services, e-mail distribution and monitoring services, and our business, legal, financial and compliance advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating the purposes of our Website, and may only use it for such purposes.
- Protecting Rights and Safety. We may share your Personal Data with others, if we believe in good faith that this will help protect the rights, property or personal safety of OTI, any of our users or any members of the general public.
For the removal of doubt, OTI may share your Personal Data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may share or otherwise use non-personal data in our sole discretion and without the need for further approval.
OTI maintains physical, electronic and procedural safeguards to help guard your Personal Data. We restrict access to personally identifiable information to those persons who need to know that information to provide products or services to you and any persons you have authorized to have access to such information. While we strive to protect your personal information, we cannot guaranty the security of any information you transmit to us.
Transfer of Data Between the OTI Group Entities
We may allow access to your Personal Data for the uses prescribed in this Privacy Notice, internally, between our group entities. In instances where Personal Data is collected from individuals within the EU, we will make sure that transfer outside EU borders (a) an EU Commission Adequacy Decision is in place, or (b) we have a legitimate interest of such transfer, and the recipient entity is bound by similar security measures that we apply, and further subject to the provisions of Section 5.
Your Rights Regarding Your Personal Information
We care about your privacy rights. Please note that you may have certain rights regarding the manner of collection, processing and usage of your personal information pursuant to applicable privacy laws (such as the EU GDPR). Under the GDPR (to the extent applies to you) you may be eligible for the following rights:
- The right to have your personal information deleted, to the extent that, and other than in connection with our compliance with a legal obligation / our exercise of a legal defense.
- The right to access the Personal Data collected and processed;
- The right to rectify untrue or incorrect Personal Data;
- The right to object to us processing your Personal Data;
- The right to have your Personal Data exported at your request, which we will make efforts to comply with within reasonable time, and provide you with such complied data by form of an electronic medium of our choice.
Please note that the above list contains a summary of the main rights you may have under the GDPR. Under no circumstances shall the above be deemed as an exhaustive list.
Please also note that we may require certain identification means for facilitating such rights in your favor, as a part of our protection means.
This Website is directed towards and designed for use by persons aged 16 and older. We do not solicit or knowingly collect Personal Data from children under the age of 16. If we nevertheless receive Personal Data from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 16, we will delete such information from our systems.
Links to Third Party Websites
The Website may contain links to other websites. While we try to link only to websites that share our respect for privacy, please be aware that OTI is not responsible for the privacy practices or the content of other websites. Websites that are accessible by hyperlinks from the Website may use “cookies.” We encourage you to read the privacy statements provided by other websites before you provide personally identifiable information to them.
Changes to this Privacy Notice
This Privacy Notice may change over time as we modify or expand our service. If we decide to change our Privacy Notice, we will prominently post those changes on this page. Your continued use of the Website after we post such notice constitutes your agreement to any such changes.
If you have any questions about this Privacy Notice, or in the event that you wish to exercise certain rights you are eligible for with respect to your Personal Date, please contact us via the below online contact for. We welcome your questions and suggestions about our Privacy Notice.