Information we collect
OTP collects personal data in the course of its business activities, including in connection with some client services. We also collect personal data on certain areas of the Sites when you register for or apply for jobs through the OTP Recruitment Portal, create a user profile, register for OTP newsletters and alerts, participate in our alumni activities through our Alumni Center Website, sign up for conferences and events, and/or participate in public user posting areas (such as bulletin boards, discussion forums and surveys). The personal data collected varies and may include information that you provide, such as your name, mailing address, e-mail address, telephone number, fax number, and background information required to apply for a job.
We may also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected will be associated with any personal data you have provided.
OTP may also collect personal data about you from third parties, such as data brokers or aggregators, in the course of its business activities including in connection with some client services. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities (e.g., analysis of recruiting practices across an industry, detecting fraud patterns in connection with financial transactions, foot traffic in retail environments). We will always seek to confirm that the third party has informed you in advance about its, and OTP’s, use of this data.
Use of information
Our Sites do not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.
Use of information collected via mobile devices
In connection with our mobile applications, OTP may use third party service providers to analyze user activity to fix errors, monitor usage, and improve the performance of the mobile applications. For example, OTP receives reports on some of our mobile applications’ aggregate usage and browsing patterns, including information about the type of device used, articles accessed, and other events occurring within our apps. OTP also receives reports on certain errors occurring within mobile applications.
In addition, our OTP Insights app offers a personalized list of recommendations (called “Insights for you”) directing you to OTP content that we think you will find interesting. Recommendations are based solely on what you have viewed in the Insights app. A unique user identifier that is generated by the app helps personalize your app experience and tracks the articles that you read in the app. We do not share your viewing history or trends with other users or any external third parties (i.e., persons or entities that are not affiliates or third party service providers of OTP).
The legal basis by which we process your personal data
Our processing of your personal data for the purposes mentioned above is based:
- in part, on our legitimate interests in promoting and protecting OTP, building and maintaining relationships. recruitment, and providing our services;
- in part, on your consent, for example if you create a user profile, or register for our newsletters or alerts, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our web-sites;
- in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.
Data recipients and international data transfers
Personal data collected in the course of OTP business activities, including in connection with some client services, as well as on the Sites may be transferred from time to time to OTP subsidiaries and affiliates and their personnel across our global organization, as well as to our third party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by OTP and our third party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by OTP subsidiaries, affiliates and third party service providers, including the transfer of your personal data to countries other than the one in which you reside. If you would like more information about these legal mechanisms, which may include the EU’s Standard Contractual Clauses, please contact us at the address below. By using any of the Sites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.
We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing recruitment materials, administering surveys or contests, or communicating with you.
In addition, we may disclose information about you:
- If we are required to do so by law or legal process;
- To law enforcement authorities or other government officials;
- When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
- If disclosure is necessary to protect the vital interests of a person;
- To protect our property, services and legal rights;
- To prevent fraud against OTP, our subsidiaries, affiliates and/or business partners;
- To support auditing, compliance, and corporate governance functions; or
- To comply with any and all applicable laws.
In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. OTP is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.
Link to third party sites
OTP has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized OTP personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, OTP cannot guarantee that unauthorized persons will not obtain access to your personal data.
OTP retains personal data, as necessary, for the duration of the relevant business relationship.
The Sites are not designed for or directed at children 13 years of age or younger, and OTP does not intentionally collect or maintain personal data about anyone under this age.
Where granted by applicable law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.
In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.
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