Ottenn Fintech Private Limited Ottenn Fintech Private Limited (“We”, “Our”, “Ottenn” or “Us”, where such expression shall, unless repugnant to the context thereof, be deemed to include its respective legal heirs, representatives, administrators, permitted successors and assigns) owns and operates the website and mobile application Ottenn (“Website”, “Our Website”, “Site”).
For the purpose of providing the Services (as defined in Clause 1 below), Ottenn is required to collect and use certain information of the users of the Website (“Users”) using the Services and involves capturing, storage, and transmission of such information. This privacy policy ("Privacy Policy" / “Policy”) explains how We collect, use, share, and protect personal information of the Users of the Services (jointly and severally referred to as “You”, “Your”, “Yourself” or “User” or “Users” in this Privacy Policy). We have created this Privacy Policy to ensure our steady commitment to the privacy of the information of the Users who interact with our Services. Your use of and access to the Services is subject to this Privacy Policy and our Terms and Conditions. Any capitalized term used, but not defined, in this Privacy Policy shall have the meaning attributed to it in our Terms and Conditions.
The headings used herein are only for the purpose of arranging the various provisions of the Privacy Policy. The headings are for the purpose of reference only and shall not be interpreted to limit or expand the provisions of the clauses contained therein.
In this Privacy Policy, unless the context otherwise requires, the terms defined shall bear the meanings assigned to them below, and their cognate expressions shall be construed accordingly.
“Personal Information” shall have the same meaning as given in Rule 2(1)(i) of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 to mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available to a body corporate, is capable of identifying such person.
The SPI Rules further define “Sensitive Personal Data or Information” of a person to mean Personal Information about that person relating to: passwords; financial information such as bank accounts, credit and debit card details or other payment instrument details; physical, physiological and mental health condition; sexual orientation; medical records and history; biometric information; information received by body corporate under lawful contract or otherwise; visitor details as provided at the time of registration or thereafter; and call data records.
“You”, “Your”, “Yourself” and “User”shall mean and refer to natural & legal individuals and legal entities/companies who visit and/or use the Services and will also include the individuals/entities/companies who avail the services by submission of details by some other person.
“Third Parties” refer to any website/application/web portal, company or individual apart from the User and Us.
“Services” shall mean the Website https://ottenn.com/ and Mobile Application (Ottenn) and contextual information transmitted to/ received from Users via various communication channels including but not limited to e-mail, SMS, WhatsApp, Notification, phone calls, website chat, IVR. We are primarily engaged in the business of providing web and app-enabled cashback, and saving services. We currently operate under the brand name Ottenn, which primarily drives transactions to the e-commerce, platforms with which We have partnered.
“User Information” shall mean Personal Information and Sensitive Personal Data or Information.
“Website” shall mean and refer to https://ottenn.com/, the “Application” and/or “App” shall refer to the Ottenn mobile application available on Android Play Store or iOS App Store. These shall be collectively referred to as the “Platform”.
This Policy is published in compliance with:
- Section 43A of the Information Technology Act, 2000;
- Regulation 4 of the SPI Rules;
- Regulation 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 (“Intermediaries Guidelines”).
This Privacy Policy states, inter alia, the following
- The type of information collected from the Users, including Sensitive Personal Data or Information;
- The purpose, means and modes of usage of such information; and
- How and to whom Ottenn will disclose such information.
The User unequivocally agrees that this Policy and the aforementioned Terms and Conditions constitute a legally binding agreement between the User and Ottenn, and that the User shall be subject to the rules, guidelines, policies, terms, and conditions applicable to any service that is provided by Ottenn, including the Services, and that the same shall be deemed to be incorporated into the Terms and Conditions, and shall be treated as part of the same.
This document is an electronic record in terms of the Information Technology Act, 2000 and rules thereunder as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Information Technology Act, 2000. This electronic record is generated by a computer system and does not require any physical or digital signatures. Further, this document is published in accordance with the provisions of the SPI Rules and Intermediaries Guidelines.
The terms ‘Party’ and ‘Parties’ shall respectively be used to refer to the User and Ottenn individually and collectively, as the context so requires.
The headings of each section in this Policy are only for the purpose of organizing the various provisions under this Policy in an orderly manner and shall not be used by either Party to interpret the provisions contained herein in any manner. Further, it is specifically agreed to by the Parties that the headings shall have no legal or contractual value.
The Parties expressly agree that, subject to clause 13 of this Policy, Ottenn retains the sole and exclusive right to amend or modify the Policy and the aforementioned Terms and Conditions without any prior permission or intimation to the User, keeping in mind best practices and laws set by the State/Central Government of India, and the User expressly agrees that any such amendments or modifications shall come into effect immediately.
The User has a duty to periodically check the Policy and Terms and Conditions and stay updated on their provisions and requirements. If the User continues to use the Services following such a change, the User will be deemed to have consented to any and all amendments/modifications made to the Policy and Terms and Conditions.
In so far as the User complies with the Policy and Terms and Conditions, he/she is granted a personal, non-exclusive, non-transferable, revocable, limited privilege to enter, access, and use the Services.
Privacy of the Parties is of prime importance to Ottenn, and all Services are strictly designed within the jurisdiction of laws defined by the Government of India.
Generally, the Services require us to know who you are so that we can meet your needs in the best possible manner. When you access the Services, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. Without prejudice to the generality of the above, information collected by Ottenn from you may include (but is not limited to) the following:
- We collect user informtion like Email address, Phone number, First name, Last name, Gender, date of birth & ZIP / Postal code.
- Email address - We collect this informtion to ensure user security and prevent fraud.
- Phone number - We collect this information to ensure user security and prevent fraud.
- First name, Last name - basic user information details.
- Gender - We collect this data to provide users with relevant deal / cashback information.
- date of birth (DOB) - We collect this information to provide users with age relevant information like shopping deals, etc.
- Demographic data (such as your ZIP Code / Postal code) - We collect this data to provide users with relevant local information and events based on their location..
- Data regarding your usage of the Services and other transactions made by or with you through the use of Services;
- Information about your clicks on and from the Ottenn mobile device, web browser, web and mobile browsing patterns, and retailer preferences;
- Your bank account information including name of the bank account holder, account number, IFSC code, bank branch, or any other payment-related information;
- Know Your Customer (KYC) Information, including Permanent Account Number (PAN) and Aadhaar number or masked Aadhaar document, for regulatory and verification purposes, in compliance with applicable laws and RBI/SEBI guidelines. This may also include scanned copies or digital documents submitted during the KYC process.
- Any other information that you voluntarily choose to provide to us (such as information shared by you with us through emails, calls, or letters, your work details, home/work address, your family details, details about transactions done on e-commerce sites, screenshots of transactions, order IDs for transactions, alternate numbers and emails, and various other information provided from time to time).
The information collected from you by Ottenn shall constitute ‘Personal Information’ or ‘Sensitive Personal Data or Information’ under the SPI Rules.
5.1. The User expressly agrees and acknowledges:
- Information that is freely available in the public domain or accessible under the Right to Information Act, 2005 or any other applicable law will not be considered as ‘Personal Information’ or ‘Sensitive Personal Data or Information’ for the purposes of this Policy.
- That Ottenn may automatically track information about the User based on the User’s IP address and behavior on the Platform, and the User expressly consents to the same. The User understands that such information may be used to conduct internal research on user demographics, interests, and behavior to better understand and serve users. Such information may include, but is not limited to, the User’s computer and web browser details, IP address, mobile device details, etc. The linkage between the User’s IP address and personally identifiable information may be shared with or disclosed to third parties in order to facilitate the Services. The User hereby consents to such sharing.
- Ottenn may share aggregated (non-personally identifiable) findings with third parties for market research and product development purposes.
- All information pertaining to the User, including personal correspondence such as emails, letters, SMS, WhatsApp notifications, calls, feedback, and complaints, may be collected and compiled by Ottenn into a file/folder created for the User. The User expressly consents to the same.
- In order to keep Users informed of activity on the Platform, Ottenn may send transactional messages via SMS, WhatsApp, emails, app notifications, and browser alerts, such as Cashback earnings, referral bonuses, and payment confirmations.
- Marketing communications including newsletters, alerts, and promotional offers may also be sent by Ottenn. Users can opt out of these communications by contacting Ottenn at any time.
- Ottenn does not support or permit spamming by Users. Incidents of spamming should be reported via contact channels for investigation.
- The User consents to the use of their contact details for offers and promotions, including those based on their interests. Users may unsubscribe by clicking the ‘unsubscribe’ link in communications or by emailing Ottenn at service@ottenn.com
- Ottenn may request users to participate in optional online surveys that may ask for demographic and contact details. This information is used to personalize services.
- Ottenn may retain call recordings and communications for customer support, compliance, development, and quality assurance.
- Users may be invited to write reviews for services availed. Ottenn is authorized to publish these reviews along with the user’s name and limited details for the benefit of other users. Ottenn reserves the right to remove such content without prior notice.
- Collection and use of ‘Sensitive Personal Data or Information’ under the Information Technology Act, 2000 requires explicit consent. By agreeing to the Terms and clicking “I agree with Terms and Policy,” the User provides such consent.
- The User is responsible for the accuracy of information submitted. To update or correct data, the User may contact Ottenn at service@ottenn.com. If false or outdated information is found, Ottenn may suspend Services as per the Terms.
- There are circumstances under which Ottenn may not correct or delete data, such as when the information is retained for evaluative purposes or legal obligations.
- All information provided by the User is voluntary. Consent can be withdrawn at any time; however, this will not affect the legality of past usage and may limit the availability of Services.
- To delete an account or request cessation of information usage, Users may write to service@ottenn.com. Upon request, personal information will be retained only as long as required by law or for essential purposes. After that, data may be anonymized and retained for analytics.
- Withdrawal of consent or deletion of the account may impact the availability of Services or termination of relationships.
- To opt out of non-essential communications, Users may email service@ottenn.com.
All the information provided to Ottenn by a User, including Personal Information or any Sensitive Personal Data or Information, is voluntary. Such information may be shared with third parties only in accordance with the User’s consent as described herein.
You understand that Ottenn may use certain information, including information designated as “Personal Information” or “Sensitive Personal Data or Information” under applicable Indian laws and the SPI Rules, for the following purposes:
- To provide You with our Services;
- To gather feedback about our products and services;
- To inform You about and offer new products, services, or features;
- To analyze usage patterns to improve the design and user experience of our app and platform;
- To send You alerts, reminders, SMS messages, notifications, or promotional content;
- To use the information in aggregate or non-personally identifiable form for business analysis, research, intelligence, or to enhance service offerings;
- To debug or resolve technical or support-related issues;
- To track data like IP addresses and Device IDs for demographic insights and fraud prevention.
In the event that Ottenn is acquired by or merged with another company, Your personal and sensitive data will be transferred to the acquiring or merging entity. Such an entity will have the right to continue using your data in accordance with their own privacy policy, which will be communicated via email or notice on our app/website.
You expressly agree and acknowledge that Ottenn stores your Personal Information and/or Sensitive Personal Information on a secure cloud-based system, as provided by You during your interactions with our Platform and Services.
While Ottenn uses your information to enhance your experience and improve services, no personally identifiable information will be shared with any third party without your explicit consent, unless required by law.
Ottenn may disclose or transfer Your information to third parties as described below:
- To government institutions or authorities, as required by law, regulation, or legal order (judicial or quasi-judicial);
- To protect the legal rights and interests of Ottenn, its partners, or other users;
- To detect or prevent fraud, security threats, or technical issues;
- In compliance with an official legal request from law enforcement agencies regarding identity verification, cyber investigations, or criminal prosecution;
- To enforce the Terms and Conditions governing User access and usage of Ottenn’s services.
Additionally, Ottenn may work with third-party service providers and advertising partners who may track user activity via standard tools (e.g., cookies, pixel tags) to deliver targeted ads and marketing content. These third parties may collect anonymized or aggregated data about your visits to our platform and other sites across the internet to help serve relevant ads. They are not permitted to sell or disclose your personal data.
The following third-party vendors, including Google, Facebook, advertising platforms, remarketing platforms like CleverTap, customer query management platforms like Freshworks & Exotel use cookies to serve ads based on a user's prior visits to Your website.
Google's use of the DoubleClick cookie enables it and its partners to serve ads to your users based on their visit to your sites and/or other sites on the Internet.
Users may opt out of the use of the DoubleClick cookie for interest-based advertising by visiting Ads Settings.
7.1. Your information is treated as confidential and will not be disclosed to any third parties, except as specified in this Privacy Policy or where legally required by authorities, or if disclosure is necessary to provide the Services effectively through the Ottenn Platform.
7.2. Your Personal Information and/or Sensitive Personal Data is maintained in electronic format on our secure servers and systems, as well as on devices used by our authorized employees. From time to time, this data may be converted to physical form, where necessary.
7.3. Who Can Access Your Personal Information: Your User Information may be processed by Ottenn employees, authorized personnel, marketing partners, or agents, strictly on a need-to-know basis, depending on the specific purposes for which the data was collected. Ottenn may retain and submit such records to relevant stakeholders where applicable or required.
7.4. Security Practices: We treat your data as a critical asset and take every reasonable precaution to protect it against loss or unauthorized access. We implement industry-standard security practices, including managerial, technical, operational, and physical safeguards, to protect User Information. Despite our best efforts, if data loss or theft occurs due to unauthorized access to your personal devices through which you use our Services, Ottenn shall not be held responsible for any resultant damages.
7.5. Measures We Expect You to Take: When creating your account, please choose a strong password (including a mix of letters, numbers, and special characters) and never share your password credentials with others. Avoid saving passwords on shared or public devices and remember to log out after each session. We also encourage the use of available privacy settings and security features within our app or platform to further safeguard your account.
7.6. Unauthorised Use of Your Account: Ottenn will not be liable for any unauthorized activity or misuse of your account. If you suspect that your account has been compromised, please notify us immediately by emailing service@ottenn.com with details of the issue.
7.7. External Security Breaches: Ottenn cannot be held responsible for the confidentiality, security, or misuse of your data by third parties beyond the scope of our agreements with them. Additionally, we disclaim liability for breaches caused by events outside our reasonable control, including but not limited to government action, hacking incidents, unauthorized access to systems, system failures, or lapses in encryption technologies.
In accordance with applicable laws, We will use & retain the User Information for as long as necessary to satisfy the purposes for which such User Information was collected (as described in Section 4 above) or to comply with applicable legal requirements.
9.1. Access to Personal Data: You have the right to access, review, and request a physical or electronic copy of the personal data held by Ottenn about you. You may also request information regarding the source from which your Personal Information or Sensitive Personal Information was obtained.
9.2. Additional Rights (e.g., Modification, Deletion of Personal Data):
- Request deletion, portability, correction, or revision of your User Information;
- Restrict or object to the use and disclosure of your Personal Data;
- Revoke previously given consent to any of Ottenn’s data processing activities.
Please note that Ottenn may still be required to retain certain User Information even after a deletion request has been made, in order to comply with legal, contractual, or business obligations.
We strongly encourage parents and guardians to supervise the online activities of their minor children and to consider using parental control tools available from online services and software providers to help create a child-friendly internet environment.
Although the Services offered by Ottenn are not intended for use by minors, we respect the privacy of every individual who may inadvertently access or use the Platform or Mobile Application to avail of our Services.
You acknowledge that this Privacy Policy forms an integral part of the Terms and Conditions of the Website and the Services offered by Ottenn, and you further acknowledge that your continued use of the Platform and the Services constitutes your unconditional acceptance of this Privacy Policy. Your visit to the Website, use of the App, and access to the Services are all subject to this Privacy Policy and the applicable Terms and Conditions.
When you avail Our Services on the Platform, a persistent cookie is placed on your device.
These cookies enable us to track any purchases you make with our participating retailers, allowing us to provide Cashback or Rewards to you.
Disabling/enabling cookies: You have the ability to accept or decline cookies by modifying your browser settings. However, please note that disabling cookies may limit your use of some interactive features of Our Platform.
Important Note: If you disable the cookies in your browser that are used to track your purchases via Our Platform, you will not be eligible to earn Cashback or Rewards when you shop from our website.
Ottenn may update this Privacy Policy at any time, with or without prior notice. In the event of significant changes in the way Ottenn handles User Information, or in the Privacy Policy itself, Ottenn will display a notice on the Platform or send Users an email, enabling the User to review the updated terms before continuing to use the Services.
If the User disagrees with any of the modifications to our terms and no longer wishes to use Our Services, the User may inform us at contact@ottenn.in to request deactivation of their account.
Unless otherwise specified, the current version of this Privacy Policy shall apply to all information Ottenn has about You and Your account.
If a User continues to use the Services after such notice has been displayed or communicated, such User will be deemed to have automatically consented to the updated terms.
Vinod Ransariya - Director
Ottenn Fintech Private Limited
Maruti Nagar - B-25 (RAM), Ravapar Road,
Morbi MDG, Rajkot, Morbi, Gujarat, India - 363641
Email: service@ottenn.com
Hasmukh Padsumbiya - IT Manager Director
Ottenn Fintech Private Limited
Maruti Nagar - B-25 (RAM), Ravapar Road,
Morbi MDG, Rajkot, Morbi, Gujarat, India - 363641
Email: service@ottenn.com