1. OTO MEDICAL DEVICES LTD and our affiliated businesses or associates (collectively, “OTO MEDICAL DEVICES LTD”) are committed to respecting and protecting the personal information you or your organisation provide to us and the information we collect in the course of operating our business.

2. “Personal Information” means any information that can be used to identify an individual or that we can connect to a person. Such Personal Information does not consist of anonymous data.

3. In this Policy you will find a description of how OTO MEDICAL DEVICES LTD may collect, use, protect, store and share your Personal Information, particularly in relation to our website and social media accounts (“Digital Accounts”) and any other link to this Policy. This Policy has been prepared using brevity and may be amended from time to time. You may periodically review this Policy. If we make any material changes in this Policy we will notify you via our Digital Accounts.

4. We process your Personal Information in accordance with the General Data Protection Regulation 2016/679 which entered into force on 25 May 2018 and the applicable local laws and regulations, as amended.

5. This Policy further describes:

• How to contact us;
• The types of Personal Information we collect;
• How we use the Personal Information we collect;
• How we may disclose the Personal Information we collect;
• Legal grounds for processing your Personal Information;
• Third party interactions;
• How we protect and store the Personal Information we collect; and
• Your choices and rights.

5.1 How to contact us

OTO MEDICAL DEVICES LTD is the entity responsible for processing your Personal Information.

If you would like to contact us with questions about our data protection or privacy practices, please contact us at [email protected].

5.2 The types of Personal Information we collect

The types of data we collect largely depend on the service or product that you request from us and our business relation. We collect Personal Information you voluntarily provide to us, including when you communicate with us via email or otherwise, when you sign up for our newsletters, alerts, webinars, events or other matters, when you submit an application to work with us, and when you respond to our requests for information. Such information may be your name and surname, contact details, ID, title and information about your organization, if any. We may collect certain information when you use, access, or interact with our Digital Accounts. Any sensitive data is collected on the basis of your consent or limited statutory purposes.

In addition, when you use, access or interact with our Digital Accounts we use browser cookies and ancillary technologies (“Cookies”) to collect and store required information. Please see below our Cookies Policy for further information about how we use Cookies and your choices and rights. Such information may be your type of device, operating system and version, IP address, general geographic location, precise location information (if you access our Digital Accounts via a mobile device and you permit us to do so in order to provide you with content based on your location and proximity to us), browser type, viewed content, accessed features and search terms.

Our website (including our mobile site) uses cookies (including session and persistent cookies). Cookies are a file of text and numbers that are stored on your computer or mobile device when you visit our website. We use cookies on our website to help us improve the functionality of our website and your experience when using it, and the services and products we offer. We may disclose the information collected with third parties for such purposes.

• Google Analytics provide us with information including anonymous information, the number of visitors to our website, how visitors use our website and the pages or links our visitors browse.
• Session cookies provide us with non-personally identifiable information including our visitors’ IP address, browser type, Internet Service Provider and operating system. Such cookies are also used for our email subscription service to record related communications and help us manage our online subscriptions.
Cookies can be disabled by changing the settings on your browser; however you may then not be able to access some areas of our website.

Moreover, third parties and associates that we cooperate with may provide us with your Personal Information for our business purposes. We may collect information from other public sources, such as social media platforms that may share information about how you interact with our social media content. Such collection of information is governed by the privacy settings, policies and procedures of the social media platform which you may periodically review.

5.3 How we use the Personal Information we collect

We may use your data as follows:

• To reply to your enquiries;
• To provide you with services that you request;
• To operate or update our Digital Accounts;
• To enhance our services and products;
• To send you newsletters, updates, marketing communications, and other information that may interest you;
• To maintain our list of contacts;
• To understand how you use our Digital Accounts i.e. analytical statistics;
• For business purposes i.e. data analysis, invoicing, addressing actual or potential fraud, illegal activities, intellectual property or technology infringement;
• To assess the effectiveness of our events, promotional campaigns and publications;
• To assess, acquire, recruit and hire personnel;
• To the extent we deem necessary or appropriate to comply with our legal and regulatory obligations;
• To respond to any legal process or requests for information issued by public authorities or third parties; and
• To protect your, our and third parties’ rights.

We do not use automated decision-making; however we may notify you accordingly if we do so.

5.4 How we may disclose the Personal Information we collect

For the purpose of providing our services we share information with our affiliated businesses or associates to undertake internal administration, billing, promotion of our events, services and products, and providing you with our services or products.

We do not disclose, sell, rent or otherwise share your Personal Information with any third parties or unaffiliated entities for their independent use, except as expressly stipulated in this Policy or with your prior consent. We may share data that does not reasonably identify you to the extent permitted by applicable laws or regulations.

In addition, we may disclose your data as follows:

• To third party service providers that perform services on our behalf e.g. web-hosting, mailing, data analytics, event hosting and information technology providers;
• To our affiliated businesses or associates;
• To law enforcement, other government authorities or third parties in any jurisdiction to the extent permitted by applicable laws or regulations as stipulated under contract, or as we deem necessary or appropriate to provide our services and products. In such circumstances, we make reasonable efforts to notify you before we disclose information that may reasonably identify you, unless prior notice is prohibited by applicable laws or regulations or not possible or reasonable in the circumstances; and
• To our affiliated companies or associates, service providers, advisors, potential transactional partners or other third parties in relation to the discussion, consideration, negotiation or completion of any transaction in which we are involved, including merger, acquisition, liquidation or business transfer.

5.5 Legal grounds for processing your Personal Information

We process your Personal Information on the basis of the following legal grounds:

• Legitimate interests i.e. to safeguard and enhance our services and products, and Digital Accounts, and in accordance with your choices and rights or consents required under applicable laws or regulations, for our marketing purposes;
• Consent i.e. to withdraw your consent to our use of your Personal Information as described in this Policy; to do so you can contact us at [email protected]. As required by applicable laws or regulations we will rely on your consent for direct marketing or to collect information from your computer or mobile device; and
• Performance of a contract i.e. to enter into a contract with you or to perform a contract that we entered into.

5.6 Third party interactions

Our Digital Accounts may contain content or links connected to content provided by third parties; however this Policy does not cover the privacy, security or other practices of such third parties that provide any similar content. We cooperate with third parties such as data analytics providers that assist with operation of our Digital Accounts. Such third parties may use technologies to identify your online activities from time to time throughout various websites or online platforms. Please see above our Cookies Policy for further information about how we use Cookies and your choices and rights.

5.7 How we protect and store the Personal Information we collect

We put in place appropriate administrative, technical and physical safeguards for the purpose of compliance with applicable legal and regulatory requirements to protect and store the Personal Information we collect. You will appreciate no information system can be entirely secure, therefore we cannot guarantee absolute security of your information nor be responsible for the security of any information you send to us over networks outside our control.

Our Digital Content is controlled from and stored in Cyprus or other countries where our affiliated businesses or associates are located. We currently do not, however in the future we may transfer information to countries which may have different data protection and privacy laws or regulations. We currently do not, however in the future we may transfer data to countries outside the European Union (EU) or European Economic Area (EEA) if we are required by any applicable laws or regulations or upon your consent to do so. Any transfers of information from the EU to countries outside the EEA will be made on the basis of specific requirements, including the model clauses approved by the European Commission (EC) for transfers from EU controllers to non-EU controllers, which may be found at the EC website.

We keep the information we collect for as long as you require our services or products or as reasonably necessary to fulfill the purposes for which we collect such information and to comply with our legal and regulatory requirements.

5.8 Your choices and rights

You may elect to no longer receive marketing communications from us by letting us know via email at [email protected].

Do let us know if your information changes or if any information we collected about you is inaccurate to update or correct it accordingly.

You can ask us to inform you what Personal Information we hold (i.e. data subject access request), to erase such Personal Information if there is no further reason for us continuing to process it or if you object to our use of such Personal Information. You may also request restriction of processing your Personal Information. We may not always be in a position to comply with such request for erasure or restriction or if you object to our use of such Personal Information, if we have specific legal reasons or compelling legitimate grounds which we will notify to you if applicable upon your request.

You may also request that we transfer your Personal Information to you or to a third party and, if the processing of your Personal Information takes place on the basis of your consent, withdraw consent at your discretion. In such event we will notify you if we will no longer be in a position to provide our services or products.

If you would like to exercise the rights you may have, please contact us at [email protected]. Any excessive, unfounded or repetitive requests will be subject to additional administrative fees, as appropriate.

Do inform us if you are not satisfied with how we used your Personal Information; you may also submit a complaint to the Cyprus Data Protection Commissioner.