Otto Privacy Policy

(Last updated: April 23, 2021)

New Foundation Labs, Inc. d/b/a Ottopay (“Otto,” “we,” “us,” or “our”) provides this Privacy Policy to explain our collection, use, and disclosure of personal information through our Site and Services.  This Privacy Policy is hereby incorporated by reference into our Terms of Use.  All defined terms not defined herein shall take their meaning from the Terms of Use.  By accessing and using the Website or Services, you agree to be bound by this Privacy Policy.  If you do not agree to any of the provisions as set hereunder in this Privacy Policy, you have no right to use the Website or Services.

This Privacy Policy is comprised of (i) the Otto U.S. Consumer Privacy Notice pursuant to the Gramm-Leach-Bliley Act and U.S. state financial information laws and (ii) our “General Disclosures” for information that we may collect, use, or disclose about you outside of the context of U.S. financial information laws.

FACTS

WHAT DOES NEW FOUNDATION LABS, INC. (“OTTO”) DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security number
  • Employment information and income
  • Account balances
  • Checking account information

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reason Otto chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Otto Share?

Can you limit sharing?

For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations

Yes

No

For our marketing purposes – to offer our products and services to you

Yes

No

For joint marketing with other financial companies

No

We don't share

For our affiliates’ everyday business purposes –information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes — information about your creditworthiness

Yes

Yes

For our affiliates to market to you

No

We don't share

For nonaffiliates to market to you

No

We don't share

Questions?

To limit sharing

Email us at support@Ottopay.com.

Please note: If you are a new customer, we can begin sharing your information thirty (30) days from the date we send this notice.  When you are no longer our customer, we continue to share your information as described in this notice.  However, you can contact us at any time to limit our sharing.

Questions?

Who we are

Who is providing this notice?

New Foundation Labs, Inc.

What we do

How does Otto protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with industry standards. These measures include computer safeguards and secured files and buildings.

How does Otto collect my personal information?

We collect your personal information, for example, when you:

  • Open an Otto account or provide account information,
  • Give us your contact information
  • When you use the Otto Services

Why can’t I limit all sharing?

Federal law gives you the right to limit only

  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you
  • for joint marketing with other financial companies

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account.

Definitions

Affiliates

Companies related by common ownership or control.  They can be financial and nonfinancial companies.
New Foundation Labs, Inc

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Nonaffiliates with whom we may share can include (i) other financial services companies (including other financial institutions, such as banks) and (ii) non-financial service providers such as hosting platforms, KYC/AML and fraud protection vendors, sanctions screening vendors, data processors, marketing partners, and API integrators.
  • Plaid: In order to provide you with the best service possible, Otto uses an Application Programming Interface supplied by Plaid (“Plaid”), used to gather your data from financial institutions. By using the Website and/or Services, you acknowledge and agree to Plaid’s privacy policy and acknowledge and agree that your information shall be treated in accordance with such policy.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Otto does not perform joint marketing

Other Important Information

California Residents: We will not share your information with companies outside of Otto or any of its affiliates, except for our everyday business purposes, for marketing our products and services to you, or with your consent.

Vermont Residents: We will not share your information with companies outside of Otto or any of its affiliates, except for our everyday business purposes, for marketing our products and services to you, or with your consent.  Notwithstanding the foregoing, we will not disclose credit information about you to Otto affiliates (or to unaffiliated parties) except as required or permitted by law.

Nevada Residents: We are providing this notice to you pursuant to Nevada law. If you prefer not to receive marketing calls from us, you may be placed on our internal Do Not Call List by writing to us at 3765 Cahuenga Blvd. Studio City, CA 91604. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protections, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101, phone number (702) 486-3132, email BCPINFO@ag.state.nv.us.

GENERAL DISCLOSURES

The below are disclosures related to information that we may collect, use, or disclose outside of the context of U.S. financial information laws.

Contact Information
We may collect your contact information, to the extent you provide it to us, such as by signing up for a blog post, emailing us, or otherwise submitting an inquiry to us via our Website or Services. 

Cookies and Other Tracking Technologies
Otto uses “cookies” and similar technologies (e.g., pixel tags, SDKs) to track your use of the Website and Services.  These technologies collect information in relation to your experience on our Website and Services, such as pages clicked, navigation path, bounce rates, actions taken (typically called “events”), and other metrics.We and our vendors use these technologies to optimize our Website and Services and understand user engagement in relation thereto. 

Server Logs
Like most websites today, our servers may keep log files that record data each time a device accesses our Website or Services.  The log files may contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Websites or Services, or the pages you’ve clicked on while on our Websites or Services).  We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.

Marketing Communications
You can manage your receipt of marketing communications by clicking on the “Unsubscribe” (or similar) link located on the bottom of an applicable Otto marketing email and following the instructions found on any page to which the link may take you.  Note, however, that you cannot opt-out of transactional or administrative emails.

Retention
Otto retains your personal information for as long as it is deemed necessary and relevant by Otto for Otto’s operations unless a longer or different retention period is required or permitted by law.

Your California Privacy Rights
“Do Not Track”We do not respond to “Do Not Track” signals or similar mechanisms at this time.

Other Disclosures
In addition to the purposes described above, we may collect, use, or transfer your information (a) as part of, or during negotiations of, a merger, consolidation, sale of our assets, as well as equity financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of Otto, (b) for purposes of responding to requests by law enforcement, regulators, and other government bodies, (c) in aggregated or anonymized fashion for further analysis and optimization of the Website or Services, (d) for our everyday businesses purposes, or (e) as otherwise permitted by applicable law.

Questions?
If you have questions or concerns regarding this statement, or if you have any questions or suggestions, please contact support@Ottopay.com.