Privacy Policy

1. Who we are

This Privacy Policy explains how OTRG Solutions Ltd ("OTRG Solutions," "we," "us," or "our") collects, uses, discloses, and protects personal data when you visit otrgsol.com (the "Site") or otherwise interact with us, for example by emailing us or submitting a contact form. We are the data controller for the personal data described in this policy.

If you have any question about this policy or how we handle your data, contact us at support@otrgsol.com.

2. Data we collect

We collect personal data in the following ways:

• Information you give us directly. When you email us or submit a contact form on the Site, we collect what you provide, typically your name, email address, company name, and the content of your message.
• Information collected automatically. The Site uses Vercel Web Analytics, which records aggregate page views, referring site, approximate country, and device type. It sets no cookies, creates no persistent identifier, and stores no IP address: visitors are counted from a temporary one-way hash of the request that is discarded within 24 hours. We also use the Meta advertising pixel to measure our advertising. It sets a cookie and may allow Meta to recognise a device across sites. In the EU, the EEA and the UK it is loaded only if you accept it on the consent banner, and never before; declining means it is not loaded at all. Elsewhere it loads with the page and a notice on the page tells you so, with a button that stops it, withdraws consent with Meta and deletes the cookies it set. Which applies is decided from the country your connection resolves to; we do not store that country, and a connection we cannot place is treated as European and asked first. See the Cookie Notice for the detail.

We do not knowingly collect special categories of personal data (such as health, religious, or biometric data) through the Site.

3. How we use your data

We use personal data to:

• Respond to your enquiries and correspond with you about our services;
• Operate, maintain, and improve the Site and understand how visitors use it, where analytics tools are enabled;
• Detect, prevent, and address technical issues, fraud, or misuse of the Site;
• Comply with our legal obligations.

We do not sell personal data, and we do not use it for automated decision-making that produces legal or similarly significant effects on you.

4. Legal basis for processing

Where the EU General Data Protection Regulation ("GDPR") applies, we rely on the following legal bases:

• Legitimate interests: to respond to enquiries, maintain the security of the Site, and understand aggregate usage of the Site, provided these interests are not overridden by your rights;
• Consent: for non-essential cookies and similar tracking technologies (such as analytics or behavioural tracking), where required by law. You may withdraw consent at any time as described in our Cookie Notice;
• Contract: where processing is necessary to take steps at your request before entering into a services agreement with us, or to perform such an agreement;
• Legal obligation: where we must retain or disclose data to comply with the law.

5. Sharing your data

We do not sell or rent personal data. We may share personal data with:

• Service providers who help us operate the Site and our business, such as email providers and our hosting and analytics provider Vercel Inc. Where you have accepted advertising cookies, Meta Platforms Ireland Limited also receives data about your visit as a controller in its own right for advertising measurement, as described in our Cookie Notice. These providers process data on our behalf under contractual data protection terms, except where they act as a separate controller as noted;
• Professional advisers such as lawyers or accountants, where necessary;
• Authorities, where required to comply with a legal obligation, court order, or governmental request;
• A successor entity, in the event of a merger, acquisition, or sale of assets, subject to the protections described in this policy.

6. International transfers

OTRG Solutions is based in Cyprus (EU/EEA). Some of the service providers referenced above, including Vercel Inc. and Meta, may process data outside the EU/EEA, including in the United States. Where this occurs, we rely on appropriate safeguards recognised under GDPR, such as the European Commission's Standard Contractual Clauses, or the provider's participation in an approved data transfer framework.

7. Data retention

We keep personal data only as long as necessary for the purposes described in this policy: enquiry and correspondence data is generally retained for as long as needed to respond to you and for a reasonable period afterwards for record-keeping, unless a longer period is required by law. Analytics data, where collected, is retained according to the retention settings of the relevant tool (for example, Google Analytics' default retention periods), which we will disclose in an updated Cookie Notice once such tools are enabled.

8. Your rights

If GDPR applies to you, you have the right to:

• Access the personal data we hold about you;
• Request correction of inaccurate or incomplete data;
• Request erasure of your data, in certain circumstances;
• Request restriction of, or object to, our processing of your data;
• Request a portable copy of data you provided to us;
• Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal;
• Lodge a complaint with a supervisory authority (in Cyprus, the Office of the Commissioner for Personal Data Protection) or with the data protection authority in your own EU/EEA member state.

To exercise any of these rights, contact us at support@otrgsol.com. We will respond within the timeframes required by applicable law.

9. Cookies

Details of the cookies and similar technologies we use, or plan to use, are set out in our Cookie Notice, which forms part of this Privacy Policy.

10. Children's privacy

The Site is intended for business audiences and is not directed at children. We do not knowingly collect personal data from anyone under the age of 16. If you believe a child has provided us with personal data, contact us and we will delete it.

11. Changes to this policy

We may update this Privacy Policy from time to time, for example as we introduce new tools such as a contact form or analytics. We will update the "Last updated" date above when we do, and where changes are material, we will provide a more prominent notice.

12. Contact us

OTRG Solutions Ltd
Email: support@otrgsol.com
Registered address: 45, Taxiarchon, 8036 Paphos, Cyprus