Privacy
Policy

Depending on how you interact with OTTO, we may collect different categories of information.

You should not provide sensitive personal information unless specifically requested and necessary for a legitimate purpose.

When you connect a cryptocurrency wallet, participate in an NFT mint, or otherwise interact with the Services, certain information may become publicly available through the applicable blockchain.

This may include:

• Public wallet addresses.
• Blockchain transaction hashes.
• NFT ownership information.
• Token identifiers.
• Transaction timestamps.
• Blockchain activity associated with a public wallet address.

Blockchain transactions are generally public and immutable. OTTO does not control the Ethereum blockchain and cannot delete, modify, or remove information permanently recorded on a public blockchain. You should carefully consider this before connecting a wallet or participating in an NFT transaction.

When you access our website, we or our service providers may automatically collect certain technical information.

This may include:

• IP address.
• Browser type and version.
• Device type.
• Operating system.
• Approximate geographic location.
• Language preferences.
• Referring website.
• Pages visited.
• Date and time of access.
• Website interactions.
• General usage and diagnostic information.

This information may be collected through cookies, analytics tools, server logs, pixels, or similar technologies.

OTTO may use cookies and similar technologies to operate, secure, analyse, and improve the website.

Cookies may be used for purposes including:

• Website functionality.
• Security.
• Session management.
• Analytics.
• Performance monitoring.
• Understanding how visitors use the website.
• Remembering preferences.

Where required by applicable law, OTTO will obtain appropriate consent before placing non-essential cookies or similar technologies on your device. You may be able to control cookies through your browser settings or other tools made available by us. Disabling certain cookies may affect website functionality.

We may use information we collect for purposes including:

• Providing and operating the Services.
• Processing NFT mint participation.
• Managing whitelist and Priority WL eligibility.
• Verifying referrals and community activities.
• Responding to support requests.
• Communicating with users.
• Managing our Discord and other community channels.
• Preventing fraud, abuse, scams, and manipulation.
• Protecting the security of our website, systems, and community.
• Detecting and preventing unauthorised activity.
• Maintaining and improving the Services.
• Analysing website and community usage.
• Complying with applicable laws and regulations.
• Responding to lawful requests from governmental or regulatory authorities.
• Enforcing our Terms of Service and other policies.
• Establishing, exercising, or defending legal claims.
• Protecting the rights, property, safety, and security of OTTO and others.
• Communicating announcements, updates, or other information relating to OTTO where permitted by law.

Where applicable privacy laws require a lawful basis for processing personal information, OTTO may rely on one or more of the following bases:

• Consent — where you have provided consent for a specific purpose.
• Contract — where processing is necessary to provide Services or perform an agreement with you.
• Legitimate interests — where processing is reasonably necessary for operating, securing, improving, and protecting our business and Services.
• Legal obligations — where processing is necessary to comply with applicable laws or regulations.
• Vital interests — where necessary to protect the life or safety of an individual.
• Legal claims — where necessary to establish, exercise, or defend legal rights.

The applicable legal basis may depend on the circumstances and the jurisdiction in which you are located.

OTTO may operate or maintain communities on platforms such as Discord, X, and other social media services.

If you interact with OTTO publicly or through these platforms, information associated with your account may be visible to OTTO or other users.

This may include:

• Username.
• Public profile information.
• Public messages.
• Public interactions.
• Community activity.
• Publicly visible wallet information.
• Information you voluntarily provide in public channels.

Third-party platforms have their own privacy policies and terms. OTTO does not control how third-party platforms collect, use, or process information.

If you contact OTTO through Discord, support tickets, or other community channels, we may collect and retain information necessary to respond to your request.

This may include your username, user ID, messages, screenshots, referral information, wallet address, and other information you voluntarily provide.

Do not share private keys, seed phrases, passwords, recovery phrases, or other sensitive credentials with OTTO or any member of the OTTO team.

If you participate in an OTTO referral or whitelist programme, we may collect information necessary to verify eligibility.

This may include:

• Discord username or ID.
• Wallet address.
• Referral information.
• Screenshots or other proof submitted through support tickets.
• Information regarding whitelist participation.
• Information regarding referral activity.

This information may be used to prevent fraud, duplicate claims, manipulation, and abuse of whitelist systems.

We may receive information about you from third parties, including:

• Blockchain analytics or infrastructure providers.
• Wallet and blockchain services.
• NFT marketplaces.
• Discord and social media platforms.
• Analytics providers.
• Security and fraud prevention providers.
• Service providers assisting us with the Services.
• Publicly available sources.

We may combine information obtained from these sources with information collected directly from you.

OTTO does not sell your personal information as a business practice.

We may share information with third parties where reasonably necessary to operate the Services or for the purposes described in this Privacy Policy.

These third parties may include:

• Website hosting providers.
• Cloud and infrastructure providers.
• Analytics providers.
• Security and fraud prevention providers.
• Blockchain infrastructure providers.
• Customer support providers.
• Email or communication providers.
• Professional advisers.
• Legal advisers.
• Auditors.
• Regulators and governmental authorities.
• Law enforcement where legally required or appropriate.
• Service providers assisting with corporate or business operations.

We require service providers handling personal information on our behalf to process that information appropriately and, where applicable, in accordance with contractual obligations.

We may disclose information where we reasonably believe disclosure is necessary to:

• Comply with applicable laws.
• Respond to lawful requests.
• Comply with court orders, subpoenas, or regulatory requirements.
• Prevent fraud or financial crime.
• Investigate suspected unlawful activity.
• Protect the safety or security of users, OTTO, or others.
• Enforce our Terms of Service.
• Protect our legal rights.

If OTTO is involved in a merger, acquisition, restructuring, financing, sale of assets, corporate transaction, bankruptcy, or similar event, personal information may be transferred as part of that transaction.

Where appropriate, we will take reasonable measures to protect personal information during such transactions.

OTTO is incorporated in the British Virgin Islands and may use service providers, contractors, and infrastructure located in other countries.

As a result, your information may be processed or stored outside the country in which you reside.

Where applicable law requires safeguards for international transfers of personal information, OTTO will seek to implement appropriate safeguards.

By using the Services, you acknowledge that information may be transferred and processed internationally, subject to applicable legal requirements.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

Retention periods may depend on:

• The nature of the information.
• The purpose for which it was collected.
• Legal and regulatory obligations.
• Fraud prevention and security requirements.
• The establishment, exercise, or defence of legal claims.
• Operational requirements.

Certain blockchain information cannot be deleted because it is permanently recorded on a public blockchain.

OTTO takes reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration, disclosure, or destruction.

However, no internet transmission, website, computer system, blockchain network, or electronic storage system can be guaranteed to be completely secure.

You acknowledge that you use the Services at your own risk.

You are responsible for maintaining the security of your own devices, accounts, passwords, wallets, and credentials.

Depending on where you live and which privacy laws apply to you, you may have certain rights regarding your personal information.

These may include the right to:

• Request access to personal information we hold about you.
• Request correction of inaccurate information.
• Request deletion of personal information where legally permitted.
• Request restriction of certain processing.
• Object to certain processing.
• Withdraw consent where processing is based on consent.
• Request portability of certain information.
• Lodge a complaint with an applicable data protection authority.

These rights are subject to applicable legal limitations and exceptions. OTTO may need to verify your identity before processing certain requests.

You acknowledge that information recorded on a public blockchain may not be capable of being deleted, modified, corrected, or restricted.

For example, wallet addresses, transaction hashes, NFT ownership records, and other blockchain records may remain publicly available indefinitely.

Accordingly, you should not provide personal information as part of a blockchain transaction or publicly associate personal information with a wallet address unless you are comfortable with that association being publicly accessible.

The Services are not intended for children who are below the minimum legal age required to use the Services in their jurisdiction.

OTTO does not knowingly collect personal information from children where such collection is prohibited by applicable law.

If you believe that a child has provided personal information to OTTO in violation of applicable law, appropriate information may be deleted where reasonably possible.

The Services may contain links to third-party websites and services.

OTTO is not responsible for the privacy practices, security, content, or policies of third-party websites.

You should review the privacy policy of each third-party service before providing personal information.

Where permitted by applicable law, OTTO may send you communications relating to the project, Services, mint events, announcements, updates, or community activities.

Where required, we will obtain appropriate consent before sending marketing communications.

You may unsubscribe from marketing communications where an unsubscribe mechanism is provided.

Transactional, security, legal, or service-related communications may still be sent where necessary.

OTTO may process personal information and technical information to detect and prevent:

• Fraud.
• Scams.
• Phishing.
• Botting.
• Sybil activity.
• Wallet manipulation.
• Whitelist abuse.
• Referral abuse.
• Account abuse.
• Hacking.
• Money laundering.
• Other unlawful or malicious activity.

This may include analysing wallet activity, transaction information, technical information, and community activity where reasonably necessary.

OTTO may be required to collect, retain, or disclose certain information to comply with applicable legal and regulatory requirements.

The British Virgin Islands has a regulatory framework governing certain virtual asset service activities under the Virtual Assets Service Providers Act, 2022.

Nothing in this Privacy Policy represents that OTTO CLUB NFT INC is subject to, licensed under, or registered with any particular regulatory framework unless OTTO expressly states otherwise.

OTTO may update this Privacy Policy from time to time.

When we make changes, we may update the "Last Updated" date at the top of this Privacy Policy.

Where required by applicable law, we may provide additional notice or obtain consent before implementing material changes.

Your continued use of the Services after an updated Privacy Policy becomes effective constitutes acknowledgement of the updated policy.

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the British Virgin Islands, except to the extent mandatory privacy or data protection laws in your jurisdiction apply.

Nothing in this Privacy Policy is intended to remove or restrict any mandatory rights you may have under applicable data protection laws.

If any provision of this Privacy Policy is found to be invalid, unlawful, or unenforceable, that provision shall be modified or removed to the minimum extent necessary, and the remaining provisions shall remain in full force and effect.

The Services are operated by OTTO CLUB NFT INC, British Virgin Islands.

Official Website: ottoclub.io