1. This policy applies to all of the services offered by OTI Data Networks, LLC ("OTI", "We", "Us", "Ours")
2. This policy covers how We treat personal information that We collect and receive.
   1. Personal information is any information about you that is personally identifiable (like your name, address, email address, or phone number), and that is not commonly, publicly available.
3. This policy does not apply to practices of companies that are not owned or controlled by Us, or to people who are not employed or managed by Us.

1. We collect personal information when you register with OTI and when you use our services, and we may collect personal information when you enter promotions, sweepstakes, give-aways, or other hosted contests.
2. When you register, we may ask for information such as your name, account password, email address, date of birth, gender, zip code, occupation, industry, and personal interests. When you register with OTI and sign in to our service, you are not anonymous to us.
3. We may collect information about your transactions with us and with some of our advertisers. This may include information about your use of financial products and services offered by our advertisers.
4. OTI may use the personal information for the purposes described in section 3 below, as well as:
   1. Customizing the advertising and content you see;
   2. Auditing, research, and analysis to maintain, protect, and improve our services;
   3. Ensuring the technical functioning of our network;
   4. Fulfilling your requests for products and services, including the development of new services;
   5. Contacting you;
   6. Conducting research; and
   7. Provide anonymous reporting for clients.
5. We automatically receive and record information on our server logs, including your IP address, the web request, and one or more cookies which may uniquely identify your browser. These server logs may also include your browser type, browser language, the date and time of your request.
6. Cookies: A cookie is a small file containing a string of characters that uniquely identifies your browser.
   1. When you visit OTI, we may set and access cookies on your computer;
   2. If your browser is set to refuse all cookies, some features of our site may not function properly;
   3. We use cookies to improve the quality of our services by storing user preferences and tracking user trends;
7. When you send email or other communication to us, we may retain those communications in order to process your inquiries, respond to your requests, and improve our services.
8. We may present links in a format that enables us to track when the links are followed. We may use this information to improve the quality and content of our content and advertising.

OTI processes personal information only for the purposes for which it was collected and in accordance with this policy or any other applicable service-specific privacy notice. We retain the right to review our data collection, storage, and processing practices to ensure that we only collect, store, and process the personal information needed to provide or improve our services. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but it is incumbent upon our users so update and/or correct their personal information whenever necessary.

1. Disclosing Personal Information:
   1. We do not rent, sell, or share personal information about you with other people or companies except when we have your permission.
   2. Notwithstanding the above, if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary, we may share your personal information under the following circumstances:
      1. To satisfy any applicable law, regulation, legal process, or enforceable governmental request (which may include, but is not limited to, responding to subpoenas, court orders, or legal process, or establishing or exercising our legal rights or defending against legal claims);
      2. To enforce applicable Terms of Service, including investigation of potential violations thereof;
      3. To detect, prevent, investigate, or otherwise address fraud, security or technical issues; or
      4. To protect against imminent harm to the rights, property or safety of OTI, its users, or the public, as required or permitted by law, and to protect against potential threats to the physical safety of another person.
   3. We may share certain pieces of aggregated, non-personal information with third parties (such as number of users who click on a particular advertisement), but that information shall not identify you individually.
   4. If OTI becomes involved in a merger, acquisition, or any form of sale of any or all of its assets, we will provide notice to you before your personal information is transferred and may become subject to a different privacy policy.
2. Using Personal Information:
   1. OTI may display targeted advertisements based on personal information. Advertisers (including ad serving companies) may assume that people who interact with, view, or click targeted ads meet such targeting criteria (such as, women ages 18-24 in a particular geographic area).
   2. We do not provide any personal information to an advertiser when you interact with or view a targeted ad, however, by interacting with or viewing the ad, you are consenting to the possibility that the advertiser will make the assumption that you meet the targeting criteria used to display the ad.
   3. Our advertisers may include financial service providers (such as banks, insurance agents, stock brokers, and mortgage lenders), as well as non-financial companies (such as stores, airlines, or software companies).

1. We take appropriate security measures to protect against unauthorized access to and/or unauthorized alteration, disclosure, or destruction of date. These include (but may not be limited to):
   1. Internal reviews of our data collection, storage, and processing practices and security measures; and
   2. Physical security measures to guard against unauthorized access to systems where we store personal data.
2. We limit or restrict access to personal information about you to our employees (including our contractors or agents) who we believe reasonably need to know that information to provide or develop services or to do their jobs.
3. We have physical, electronic, and procedural safeguards that comply with federal regulations to protect personal information about you.

1. You can edit your account information at any time.
2. We reserve the right to send you communications relating to our service, such as announcements, administrative messages, and any periodic newsletters that may be published, without offering you the opportunity to opt out of receiving them.
3. You can delete your account at any time by emailing oti@oceantomo.com.

1. We reserve the right to update and/or change this policy from time to time.
2. For any minor changes, will not reduce your rights without your explicit consent.
3. For any major or significant changes which do not reduce your rights and therefore do not require explicit consent, we will place a prominent notice on our site.
4. For any major or significant changes which require your consent, such as the way we treat your personal information, we will send a notice to the primary email address listed on your account.