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PRIVACY POLICY

Revised: October 15, 2026

Your privacy is important to us. This Privacy Policy (“Privacy Policy”) describes how Othelia Technologies, Inc. (“Othelia”, “we”, “us”, or “our”) may collect, use, store, disclose, process, and transfer your personal information through your access to or use of Othelia products and services, including those at https://othelia.com/ and https://app.othelia.com/ as well as any subdomains, website of ours that links to this Privacy Policy, related websites, and other offerings (collectively, the “Services”). By using the Services or, if required by laws applicable to you, opting into this Privacy Policy, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services. Othelia may change this Privacy Policy from time to time by posting changes at https://app.othelia.com/privacy-policy. Your continued use of the Services following the posting of such changes will be deemed your acceptance of those changes, unless additional consent is required.

Privacy Policy Applicability

This Privacy Policy applies when you use or access the Services or share information with Othelia. By accessing or using the Services and/or opting into this Privacy Policy (as applicable in your jurisdiction), you consent to this Privacy Policy. Othelia may update this Privacy Policy at any time. If you do not consent to this Privacy Policy for any reason, please do not access or use the Services or share your information with us. Please note that this Privacy Policy applies only to the Services and not to any other third-party website linked to or from it, or any third-party website in which Othelia’s content or functionality is embedded. We do not control the privacy policies or practices of others.

Information We Collect from You

In general, we receive and collect all information you provide via the Services, including through website input fields, advertisements, phone, email (including email campaigns), or other such ways. This includes personal information that can identify or relates to you, including, but not limited to:

Category of Personal Information Examples of Personal Information We Collect Sources from which such Personal Information is Collected Third Parties to whom we share such Personal Information
Profile or Contact Data Examples may include:
First and last name
Postal address
Zip code
Telephone number
Email address
Unique identifiers, such as usernames and passwords
Information or other similar identifiers		 You
Service providers
Othelia’s customers
Othelia’s affiliated entities, partners, etc.
Other independent third-party sources		 Advertising networks
Data analytics providers
Service providers
Partners you authorize, access, or authenticate
Demographic Data Examples may include:
Age
Birthday
Gender		 You
Service providers
Othelia’s customers
Othelia’s affiliated entities, partners, etc.
Other independent third-party sources		 Advertising networks
Data analytics providers
Service providers
Partners you authorize, access, or authenticate
Commercial Data Examples may include:
Consumer profiles
Records of products or services sold, used, or purchased
Other purchasing histories or tendencies		 You
Service providers
Othelia’s customers
Othelia’s affiliated entities, partners, etc.
Other independent third-party sources		 Advertising networks
Data analytics providers
Service providers
Partners you authorize, access, or authenticate
Device/IP Data Examples may include:
IP address
Device ID
Domain server
Browser type
Search history
Type of device
Information regarding your interaction with the Services or any advertisement
Information collected automatically through cookies and similar technology, device type, domain names, and access time/logs		 You
Service providers
Othelia’s customers
Othelia’s affiliated entities, partners, etc.
Other independent third-party sources		 Advertising networks
Data analytics providers
Service providers
Partners you authorize, access, or authenticate
Web Analytics Examples may include:
Web page interactions
Referring webpage/source through which you accessed the Services
Browsing activity, including the addresses of websites that you visit
Non-identifiable request IDs
Statistics associated with the interaction between device or browser and the Services		 You
Service providers
Othelia’s customers
Othelia’s affiliated entities, partners, etc.
Other independent third-party sources		 Advertising networks
Data analytics providers
Service providers
Partners you authorize, access, or authenticate
Geolocation Data Examples may include:
General physical location
Precise physical location
Movements
IP-address-based location information
Cookie ID		 You
Service providers
Othelia’s customers
Othelia’s affiliated entities, partners, etc.
Other independent third-party sources		 Advertising networks
Data analytics providers
Service providers
Partners you authorize, access, or authenticate
Financial and Payment Data Examples may include:
Payment card type
Last 4 digits of payment card and expiration date
Billing address
Account number		 You
Service providers
Othelia’s customers
Othelia’s affiliated entities, partners, etc.
Other independent third-party sources		 Advertising networks
Data analytics providers
Service providers
Partners you authorize, access, or authenticate
Social Network Data Examples may include:
Usernames and passwords
Data, information, or materials accessible through your social media
Email, phone number, and social media ID associated with your social media accounts		 You
Service providers
Othelia’s customers
Othelia’s affiliated entities, partners, etc.
Other independent third-party sources		 Advertising networks
Data analytics providers
Service providers
Partners you authorize, access, or authenticate
Inferences Drawn from Other Personal Data Collected Examples may include:
Profiles reflecting user attributes
Profiles reflecting user behavior		 You
Service providers
Othelia’s customers
Othelia’s affiliated entities, partners, etc.
Other independent third-party sources		 Advertising networks
Data analytics providers
Service providers
Partners you authorize, access, or authenticate
Other Identifying Information that You Voluntarily Decide to Provide Examples may include:
Identifying information in emails, phone calls, texts, letters, or other communications you send us
Identifying information you post to blogs, competitions, live chats, forums, or message boards		 You
Service providers
Othelia’s customers
Othelia’s affiliated entities, partners, etc.
Other independent third-party sources		 Advertising networks
Data analytics providers
Service providers
Partners you authorize, access, or authenticate

You have the choice regarding what information you share and the Services you want to engage. You can choose not to provide information to us, but in general, some information about you is required in order for you to access certain functionalities of the Services.

We may periodically obtain information about you from customers, affiliated entities, partners and other independent third-party sources and will add it to our database of information, including any information that you provide to third parties that are associated with or whose products or services are integrated with the Services.

When you use the Services, we collect the text, content, information, data, and other materials that you submit, upload, email, transmit, or otherwise make available through the Services, such as scripts and documents, together with the conversational responses, summaries, extracts, and other output generated by the Services from those materials, including through Ask Othelia and other AI features (collectively, “Your Content”). When you use Ask Othelia, our AI-powered conversational feature, we also collect the questions you ask, the history of each conversation thread, the responses generated, and any feedback you provide (“AI Interaction Data”). To provide the Services, we also create text embeddings, search indexes, and other derived data from Your Content. Your Content and AI Interaction Data may contain personal information about you and about other individuals (for example, names or contact details of people referenced in your scripts or documents). We collect this information from you, and we share it with our AI Service Providers as described in the “AI Features and AI Service Providers” section below.

We may use cookies, heat mapping, log files, web beacons, device identifiers, advertising identifiers, session replay technologies, and similar tracking technologies, including those from third-party service providers like Google Analytics, Google Tag Manager, HubSpot, and other cloud-based tools, to automatically collect your preferences, performance data, and information about your web usage when you visit the Services. For example, we may collect your IP address, device and Internet service provider information, Web browser details and the address of any referring website. We may also collect information about your online activity, such as pages viewed and interactions with other users. This may include collecting geolocation signals from your IP address or device settings to determine your location. By collecting and using this information, we may operate and personalize the Services for you and may also combine this data with other information we have collected about you. For more information on how we use cookies, please see the “Cookies” section below.

The Services are not designed to recognize or respond to “do not track” signals received from browsers. You can control the information collected by such tracking technologies or be alerted when cookies are sent by adjusting the settings on your Internet browser or devices, but such adjustments may affect or disable certain functionality of the Services. You can learn more about targeted ads and your ability to opt out of receiving interest-based ads at optout.aboutads.info and www.networkadvertising.org/choices.

Sensitive Information. Othelia does not request or intentionally collect any sensitive personal information through our Services. Sensitive personal information, as defined by applicable data protection laws, includes information relating to your race, ethnicity, religious beliefs, moral beliefs, philosophical beliefs, sex life, sexual orientation, gender identity, political opinions, trade union membership, citizenship status, national origin, status as a victim of crime, medical information (including mental health), genetic data, biometric data, or financial information (such as account numbers). We also do not request or intentionally collect any information about criminal convictions or offenses. However, Your Content and AI Interaction Data may include sensitive personal information if you choose to include it, and that information will be processed in the same way as the rest of Your Content, including by our AI Service Providers. Please do not upload sensitive personal information about yourself or others unless you have the right to do so and it is necessary for your use of the Services.

Cookies

Cookies, also known as tracking cookies or browser cookies, and similar technologies such as web beacons, clear GIFs, pixel tags, and JavaScript (collectively, “Cookies”) are small pieces of data, usually text files, placed on a computer, tablet, phone, or similar device when you use that device to access the Services. We use the following types of Cookies:

You have the option to decide through your internet browser’s settings whether or not to accept Cookies. Most browsers allow users to choose whether to turn off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the browser) allow you to toggle whether to accept each new Cookie. You can also clear all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit the Services and some functionalities may not work. To explore what Cookie settings are available to you, look in the “settings”, “preferences” or “options” section of your browser’s menu.

To find out more information about Cookies, including information about how to manage and delete Cookies generally, please visit http://www.allaboutcookies.org/.

How We Use Your Information

We process your personal information with your consent or as needed to provide you the Services. We may also use your personal information to comply with legal obligations, operate our business, protect the vital interests of you, our customers, or the public, or for other legitimate interests of Othelia as described in this Privacy Policy.

More specifically, we may use your personal information to:

We may use any aggregated information (as described below) for any purpose. For the avoidance of doubt, Othelia does not have its own AI model and does not use Your Content, AI Interaction Data, or your personal information to train or fine-tune any AI model, and our agreements with our AI Service Providers prohibit them from using that information to train their models.

How We Share Your Information

We share your information with our partners, service providers, contractors, agents, and third-party vendors indicated in the “Information We Collect from You” section as needed to fulfill the Services, including our AI Service Providers as further discussed below. Please note that our partners may contact you as necessary to obtain additional information about you, facilitate any use of the Services, or respond to a request you submit.

Third-party vendors who provide products, services or functions on our behalf may include AI Service Providers, cloud hosting and database providers, data analytics companies, customer service vendors, communications service vendors, logistics service providers, marketing vendors, and security vendors. Third-party vendors have access to and may collect personal information only as needed to perform their functions, may only use personal information consistent with this Privacy Policy and other appropriate confidentiality and security measures, and are not permitted to share or use the information for any other purpose.

We also may share your information:

Other than as set out above, we will attempt to notify you when your personal information will be shared with third parties.

Personal Information You Post in Public Areas or Share with Other Users. When you post a review or provide customer feedback, the information you post may be accessible to other users of the Services and the public. If you share Your Content with other users, those users can access it and may retain copies of it even if you later remove or delete it from the Services. If you post personal information anywhere on the Services that is accessible to other users or the public, you are advised that such personal information can be read, collected, used, or disseminated by others and could be used to send you unsolicited information or for other purposes. Accordingly, you assume full risk and responsibility for posting or sharing such information and agree that Othelia is not responsible in any way for personal information you choose to post in these public areas or share with other users.

Aggregated Information. We may use, publish, share, distribute, or disclose personal information that has been aggregated with information from other users and otherwise anonymized and de-identified in a manner that does not allow third parties, including Othelia partners, customers, and vendors, to de-identify the data or identify it as originating from you. This may include statistical, analytical, and performance information derived from Your Content, your use of the AI Features, and feedback you provide, but will not reproduce or disclose Your Content in any recognizable form. Such information may help Othelia identify and analyze usage, demographic, and psychographic trends and information and report to third parties how many people saw, visited, or clicked on certain content, areas of the Services, or other materials. We may also use such data for research purposes and optimizing the Services’ functionality.

AI Features and AI Service Providers. Certain features of the Services, including Ask Othelia, use artificial intelligence (the “AI Features”). The AI Features may be powered by models provided by third parties (“AI Service Providers”), which may change from time to time. Our current AI Service Providers are: (a) Anthropic, PBC’s Claude models, accessed through Amazon Web Services’ Bedrock service; (b) Google LLC’s Gemini models, accessed through Google Cloud Vertex AI; (c) OpenAI’s models, accessed through the OpenAI API[, which Othelia is in the process of phasing out]; and (d) text embedding models, accessed through Amazon Bedrock and the OpenAI API, which are used to identify the portions of Your Content relevant to your question. When you use the AI Features, your questions, conversation history, system instructions, and relevant portions of Your Content, including any personal information they contain, may be sent to AI Service Providers for processing. Othelia engages AI Service Providers under terms that prohibit them from using Your Content to train their models and limit their retention of it. Othelia does not use Your Content to train any artificial intelligence model. Othelia may select, change, or route requests among AI Service Providers and models at its discretion, and does not guarantee that any particular model will be used. We will update this list if we add or change AI Service Providers. Responses generated by the AI Features may be inaccurate, incomplete, or misleading, and may misstate or misattribute the contents of the materials you upload. You are responsible for reviewing and evaluating responses before relying on or using them.

AI Feature Records. Othelia may record, store, and review your questions and other inputs to the AI Features, the responses generated, any feedback you provide on those responses, and the portions of Your Content retrieved to generate them, and may use these materials to monitor, evaluate, test, troubleshoot, and improve the quality, safety, and performance of the Services.

How We Store and Secure Your Information

Personal information collected by Othelia, including Your Content and AI Interaction Data, is stored and processed in the USA. Othelia’s service providers may also process personal information in other countries where they operate facilities. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.

Othelia takes technological and organizational measures designed to protect your personal information against loss, theft, and unauthorized access, use, disclosure, or modification. For example:

We rely on the security policies of AWS’, to protect personal information while stored in their respective controlled facilities. For more information on AWS’ security practices and processes, please see https://aws.amazon.com/security/. Othelia complies with applicable data protection laws, including applicable security breach notification requirements.

Data Retention

Othelia will retain your information as long as necessary for the purposes outlined in this Privacy Policy, in a manner consistent with our data retention policy discussed in this section, and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection or audit purposes or as permitted by applicable law. Othelia will retain your personal information consistent with the original purpose of collection or as long as necessary to comply with our legal obligations; maintain accurate accounting, financial and other operational records; resolve disputes; and enforce our agreements. We will never retain your information for a period longer than permitted by law.

We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of the personal information being processed; the purpose for which it was collected; the potential risk of harm from unauthorized use or disclosure of the personal information; whether we can achieve the purposes of the processing through other means; and applicable legal requirements.

After expiration of the applicable retention periods, your personal information will be deleted. As discussed below, you may have the right to request we delete this information earlier.

Accessing and Updating Your Information

To the extent provided by the law of your jurisdiction, you may:

You may make these requests and any other inquiries about this Privacy Policy by emailing info@othelia.com. Any such requests are subject to the protection of other individuals’ rights and applicable law. Additionally, to help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the requested information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

Additional Privacy Information

Data Transfer. Our databases are currently located in the USA. Information sent to our AI Service Providers may be processed in the USA and in other countries as described in the “How We Store and Secure Your Information” section above. Othelia makes no claim that its Services are appropriate or lawful for use or access outside the USA. If you access the Services from outside the USA, you are consenting to the transfer of your personal information from your location to the USA and to any other country in which our AI Service Providers process it. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access to the Services. By providing us your information, you further consent to its storage within the USA.

Collection of Data from Children. The Services are not directed to children, and you may not use the Services or provide any personal information to Othelia if you are under the age of 13 (or the lowest age permitted by applicable law) or if you are not old enough to consent to the processing of your personal information in your country. We do not collect or process personal information of individuals under the age of 13 or the lowest age permitted by applicable law unless we receive all necessary consents from the individual’s parent or guardian.

California Resident Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us or contact us through the methods stated above.

Your Rights under State Law

Nebraska Resident Rights

If you are a Nebraska resident, you have the rights set forth under the Nebraska Data Privacy Act (“NDPA”). Please see the “Exercising Your Rights under State Law” section below for instructions regarding how to exercise these rights. If we are processing your personal information as a service provider, please contact the entity that collected your personal information to address your rights with respect to such information. Additionally, please note that certain conditions and exceptions as set forth under applicable law apply to these rights, which may permit or require us to deny your request.

If there is any conflict between this section and any other provision of this Privacy Policy applicable to you and you are a Nebraska resident, the portion more protective of your personal information shall control with respect to such conflict.

Your rights under the NDPA include:

Opt-Out of Certain Processing Activities.

You have the right to opt-out of Othelia processing your personal information for targeted advertising purposes. You also have the right to opt-out to the sale of your personal information. Under the NDPA, sharing your information through third-party Cookies for online marketing and advertising or user analytics may be a “sale” of information. Finally, you have the right to opt-out of Othelia processing your personal information for profiling purposes, which includes using your personal information in a way that produces a legal or similarly significant effect concerning you.

To opt-out of our processing of your personal information for the purposes discussed above, please see the “Exercising Your Rights under State Law” section below.

Appealing a Denial

If we refuse to take action on a request to exercise your rights described above within 45 days after receiving your request in compliance with this section, you may appeal our decision by emailing Othelia at info@othelia.com. In the appeal, you must: (a) provide sufficient information to identify the original request and to allow us to verify that you are the individual about whom the original request pertains; and (b) provide a description of the basis of your appeal. Please note that your rights and obligations granted to you under the NDPA will govern your appeal. Othelia will respond to your appeal within 60 days of receiving your request in accordance with this section. If Othelia denies your appeal, you have the right to contact the Nebraska Attorney General using the methods described at https://ago.nebraska.gov/constituent-complaint-form.

Texas Resident Rights

If you are a Texas resident, you have the rights set forth under the Texas Data Privacy and Security Act (“TDPSA”). Please see the “Exercising Your Rights under State Law” section below for instructions regarding how to exercise these rights. If we are processing your personal information as a service provider, please contact the entity that collected your personal information to address your rights with respect to such information. Additionally, please note that certain conditions and exceptions as set forth under applicable law apply to these rights, which may permit or require us to deny your request.

If there is any conflict between this section and any other provision of this Privacy Policy applicable to you and you are a Texas resident, the portion more protective of your personal information shall control with respect to such conflict.

Your rights under the TDPSA include:

Opt-Out of Certain Processing Activities.

You have the right to opt-out of Othelia processing your personal information for targeted advertising purposes. You also have the right to opt-out to the sale of your personal information. Under the TDPSA, sharing your information through third-party Cookies for online marketing and advertising or user analytics may be a “sale” of information. Finally, you have the right to opt-out of Othelia processing your personal information for profiling purposes, which includes using your personal information in a way that produces a legal or similarly significant effect concerning you.

To opt-out of our processing of your personal information for the purposes discussed above, please see the “Exercising Your Rights under State Law” section below.

Appealing a Denial

If we refuse to take action on a request to exercise your rights described above within 45 days after receiving your request in compliance with this section, you may appeal our decision by emailing Othelia at info@othelia.com. In the appeal, you must: (a) provide sufficient information to identify the original request and to allow us to verify that you are the individual about whom the original request pertains; and (b) provide a description of the basis of your appeal. Please note that your rights and obligations granted to you under the TDPSA will govern your appeal. Othelia will respond to your appeal within 60 days of receiving your request in accordance with this section. If Othelia denies your appeal, you have the right to contact the Texas Attorney General using the methods described at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.

Exercising Your Rights under State Law

You can request to exercise the rights granted to you under the NDPA or TDPSA, as applicable, as set forth below in the “How to Contact Us” section below. You may request to exercise these rights by yourself or via an authorized agent who meets the agency requirements of the applicable law or regulation. Once you submit a request to exercise your rights, you agree to receive communications from Othelia in order to verify your identity as the individual from whom we collected the personal information and to request other information as reasonably required to enable us to fulfill your request. We will not fulfill any request unless you have provided sufficient information for us as described in the previous sentence as well as sufficient details necessary to help us handle the request.

How to Contact Us. e-mail us at info@othelia.com

Depending on where you are located, you may also have a right to complain to your local data protection regulator.

European Union, United Kingdom, and Swiss Data Subject Rights

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Switzerland, Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation or the Swiss Federal Act on Data Projection (“FADP”) (collectively for the purposes herein, the “GDPR”), as applicable, with respect to your Personal Data. The following discusses these rights.

For this section, the GDPR definition of “Personal Data” and “processing” are used. Generally, “Personal Data” means information that can be used to individually identify a person, and “processing” relates to actions that can be performed in connection with collecting, using, storing, and disclosing such data. Othelia is the controller of your Personal Data processed in connection with the Services. Where Your Content contains Personal Data about other individuals (for example, people named in your scripts or documents), you, or the organization on whose behalf you use the Services, are the controller of that Personal Data, and Othelia processes it on your behalf as a processor. Requests from those individuals will be referred to you.

If a conflict exists between this this section and any other provision of this Privacy Policy, the more protective policy or portion shall govern to resolve such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at info@othelia.com

Personal Data We Collect. The “Information We Collect from You” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds. The “How We Use Your Information” section above explains how we use your Personal Data. We will only process your Personal Data as explained in this Privacy Policy and if we have a lawful basis for doing so. The lawful bases include receiving your consent, having a contractual necessity, and furthering our legitimate interests or the legitimate interest of others. The following sections describe these in greater detail.

Consent

We process Personal Data based on the consent you expressly grant to us at the time we collect the data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Contractual Necessity

We may process the Personal Data as a matter of “contractual necessity”. This means that we need to process the data to perform under our agreement with you and enable us to provide you with the Services, including processing Your Content and AI Interaction Data, and sharing them with our AI Service Providers, to provide Ask Othelia. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services.

Legitimate Interest

We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties providing products or services in connection with the Services:

We may also de-identify and anonymize Personal Data to further our legitimate interests.

Examples of these legitimate interests include (as described in more detail above in the “How We Use Your Information” section):

Other Processing Grounds

Occasionally, we may also need to process Personal Data to comply with legal obligations, to protect the vital interests of you or other data subjects, or to carry out a task necessary for the public’s interest.

Sharing Personal Data. The “How We Share Your Information” section above details how we share your Personal Data with third parties.

EU and UK and Swiss Data Subject Rights

EU and UK and Swiss data subjects have certain rights with respect to Personal Data. This is further set forth below. For more information about these rights or to submit a request, please email us at info@othelia.com. Please note that in some circumstances, Othelia may be unable to fully comply with your request, including if the request is frivolous, extremely impractical, jeopardizes other’s rights, or not required by law. In those circumstances, we will still notify you of such a decision. Generally, we may also need you to provide us additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Your rights include:

Transfers of Personal Data. The “Data Transfer” information in the “Additional Privacy Information” section above details how and where we transfer your data. Most significantly, our databases are currently located in USA, and you are consenting to Othelia transferring your Personal Data to USA.