Privacy Policy

Last updated: December 8, 2025

Otty AI ("we," "us," or "our") is committed to protecting your privacy and handling your data in a transparent, secure, and GDPR-compliant manner. This Privacy Policy explains how we collect, use, store, and share your information when you use our SMS automation and performance-based marketing services.

By using Otty AI, you agree to the practices described in this policy.

1. Data Controller

Otty AI acts as the Data Controller for the personal data we collect and process in connection with your use of the service.

If you need to contact us about data protection matters, reach out via our support channels.

2. Information We Collect

a. Information You Provide Directly

• Name, email address, account credentials

• Store details & configuration settings

• Messaging preferences, segmentation, and discount rules

b. Store & Customer Data (Processed on Your Behalf)

To function properly, Otty AI processes:

• Abandoned cart data

• Order and revenue data

• Customer identifiers, interactions, and behavioral signals

• Message deliveries, clicks, purchases

• Coupon usage and attribution metrics

This data is processed solely to perform the service you requested.

c. Automatically Collected Data

We may collect:

• IP address, device info, browser type

• Usage analytics and performance logs

• Authentication tokens

• Cookies and tracking technologies (see Section 7)

d. AI Processing Disclosure (GDPR Article 13)

• Our AI systems generate automated messages and recommendations.

• We do not perform fully automated decision-making that produces legal effects.

• You maintain full control of which messages are sent.

3. Legal Basis for Processing (GDPR Articles 6 & 28)

We process your data under the following legal bases:

• Performance of a Contract:

  Operating Otty AI, automating SMS, generating performance metrics, and running dynamic discounting.

• Legitimate Interests:

  Improving service reliability, fraud prevention, attribution accuracy, platform analytics.

• Consent:

  Cookie tracking, optional marketing communications, and non-essential analytics.

• Legal Obligation:

  Compliance with applicable laws and regulatory requirements.

For customer data imported from your store, you are the Data Controller, and Otty AI acts as your Data Processor.

4. How We Use Your Information

We use your data to:

• Deliver and operate the Otty AI platform

• Automate & personalize SMS messages

• Provide dynamic discounting & customer segmentation

• Attribute revenue for performance-based billing

• Improve AI models and campaign performance

• Maintain platform security and detect abuse

• Provide support and communicate updates

We do not use your store's customer data for unrelated purposes.

5. Performance-Based Billing Disclaimer

Otty AI operates on a performance model where we charge 10% of revenue attributed to our SMS messages.

To calculate performance accurately, you consent to Otty AI collecting and processing:

• Order data

• Attribution events

• Coupon usage

• UTM and tracking parameters

• Click-through and conversation events

These metrics are necessary for contractual performance.

Billing is final and non-refundable because charges occur after revenue has been generated.

6. Information Sharing

We never sell or rent personal information.

We may share your data only with:

a. Service Providers (Processors)

Such as:

• SMS gateways

• Cloud hosting providers

• Analytics and monitoring tools

• Security and anti-fraud services

All processors are bound by strict confidentiality and GDPR-compliant agreements.

b. Legal & Safety

We may disclose data if required by law or necessary to protect users, our platform, or our rights.

c. Business Transfers

If Otty AI undergoes a merger or acquisition, your data may be transferred securely as part of the transaction.

7. Cookies & Tracking Technologies

Otty AI uses cookies to:

• Maintain login sessions

• Secure the dashboard

• Analyze website performance (with your consent)

• Improve user experience

Types of cookies we use:

• Essential cookies: Required for the website to function

• Analytics cookies: Optional; used only with your consent

• Preference cookies: Store your settings and language

You can manage or disable cookies through your browser settings. Declining non-essential cookies will not affect core functionality.

8. Data Security

We use industry-standard security measures, including:

• Encryption in transit & at rest

• Access controls & authentication

• Monitoring, backups, and threat detection

• Secure internal processes

No system is perfectly secure, but we take all reasonable steps to protect your data.

9. International Data Transfers

Your information may be transferred to and processed in countries outside your jurisdiction.

Where required, we implement safeguards such as:

• Standard Contractual Clauses (SCCs)

• GDPR-compliant processor agreements

• Adequacy decisions when available

10. Data Retention

We retain data only as long as necessary for:

• Operating Otty AI

• Fulfilling legal requirements

• Providing accurate billing records

• Resolving disputes or enforcing agreements

When data is no longer needed, it is deleted or anonymized.

11. Your Rights Under GDPR

You have the right to:

• Access your data

• Correct inaccurate data

• Delete your data ("right to be forgotten")

• Restrict or object to processing

• Request a copy of your data

• Withdraw consent for cookies or newsletters

• File a complaint with your data protection authority

To exercise rights, contact us through support.

For store customer data, please contact the merchant directly (they are the Data Controller).

12. Children's Privacy

Otty AI is not intended for children under 16.

We do not knowingly collect data from minors.

13. Changes to This Policy

We may update this Privacy Policy at any time.

Changes will be posted on this page with an updated "Last updated" date.

Continued use of Otty AI indicates acceptance of the updated policy.

© 2025 Otty AI. All rights reserved.