Privacy Policy
Effective Date: November 30, 2023
This Privacy Policy (“Policy”) describes the information collected by or on behalf of OTTO Homes, Inc. ("Milo," “OTTO,” “we,” “us,” or “our”) through our website and platform available via the website (collectively, “Site”) and how such information is used and disclosed. If you have questions or concerns about this Policy, please contact us as set forth below.
We may modify this Policy at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you.
Information We Collect
We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”) when you use our Site and otherwise interact with us. The information we collect falls into three categories: (a) information you provide to us; (b) information we collect through automated methods; and (c) information we collect from other sources. These are further detailed below.
You can visit the Site without opening an account. However, certain features of the Site require Personal Information. For example, we require Personal Information for you to create an account, contact us via email or phone, receive or request data from us, and respond to communications from you. In such circumstances, you may be unable to use those features unless you provide your Personal Information.
Information You Provide to Us
We collect Personal Information that you provide directly to us. If you elect to provide your Personal Information, we will collect, use, and disclose such Personal Information pursuant to this Policy and applicable law.
Online Accounts. If you create an online account, you we will collect your name, phone number, and email address, and the password you create. This data is used to populate a profile within your account and manage your account. We may collect additional information if you choose to list your property on the Site or utilize additional services.
Communications With Us. If you communicate with us, we will receive your phone number and/or email address and your message’s content.
Marketing Communications; Email Opt-Out. If you provide your email address, we may send you marketing communications from us, including home updates. We may use third party service providers to deliver such communications to you. You may opt-out of marketing emails by using the unsubscribe link in the email or contacting us at hello@opentotheoffer.com with “Unsubscribe” in the subject line. Opting out of marketing communications does not opt you out of non-marketing communications, such as emails about your account or home updates you request.
Live Chat Conversations. The Site contains a chat feature provided by a third-party service provider, Freshworks. Use of the chat feature is subject to the Freshworks privacy policy, available here. If you use the chat feature, we may collect all text and other data that you submit via that chat feature. If you use a chat feature while signed into your OTTO account, we may link the chat information to your account.
Data Automatically Collected
We may use automated technologies to collect Personal Information from your computer system or mobile device. This may include the following:
Account Activity. We may collect data about how you use (i) your online account, and (ii) the Site when you are logged into your account. We may combine data automatically collected from you with other Personal Information about you.
Maps. The Site contains maps provided by third party service providers for your convenience. OTTO and such other third-party map companies may collect data about how you interact with the maps.
Cookies & Other Tracking Technologies.
Our Site may use cookies, web beacons, pixel tags and other tracking technologies (collectively "Cookies"). A cookie is a small text file that our Site saves onto your computer or device when you use the Site that provides us certain information about your activities. Cookies allow the Site to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Site and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a website that has implemented a persistent Cookie, the persistent Cookie is renewed, and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual website that you are visiting (i.e., this Site). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We may not have control over how a third-party uses information collected through third-party Cookies.
Most browsers automatically accept Cookies. You can disable this function by changing your browser settings but disabling cookies may impact your use and enjoyment of the Site. Not all features or functions of the Site may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Site.
The Cookies on our Site may collect information such as:
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IP addresses assigned to the computers and other devices you use;
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your internet service provider;
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device ID number;
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approximate geographic location;
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browser type;
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Site pages visited;
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websites you access before and after visiting the Site, and
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data related to how and when you use the Site.
California's "Do-Not-Track" Requirement. we currently do not honor “do not track” requests.
Data from Other Sources.
We obtain data about individuals from various third-party companies and service providers, such as mortgage lenders, real estate agents, or other industry professionals who referred you to OTTO or with whom you have otherwise had a previous relationship. We also may obtain data from you from public sources,. Any of this data from other sources we may combine with other Personal Information about you and/or your property.
How We Use Your Information.
We use Personal Information that we collect for the following purposes:
As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to fulfill your requests for more information, respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you. This may include connecting you with industry professionals and service providers that you may request.
Administration. We use Personal Information for administrative purposes, such as managing your account, to inform our business strategies, and to understand the demographics and user preferences of the Site.
Management of the Site. We use Personal Information for management of the Site, such as troubleshooting problems, improving content, functionality, and user experiences, performing statistical and other analyses, optimizing the Site, and customizing the Site to users.
Business Analytics. We use Personal Information for business analytics purposes, including consumer and operations research, to assess the effectiveness of our online Site, marketing, and advertising, and to analyze market trends.
Advertising and Communications. We may use Personal Information to send you marketing communications, advertisements, to perform targeted advertising, to notify you of new services or features, to notify you of changes to our Terms of Use or this Policy, and for other similar communications.
To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests.
To Create Aggregate Data. We may process Personal Information to create anonymous and aggregated data regarding our Site and customers. OTTO may collect, use, disclose, transfer, and otherwise process such aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. OTTO is the sole and exclusive owner of such aggregated information, including if OTTO anonymizes Personal Information so that it no longer considered Personal Information under applicable laws.
How We Use Data Collected by Automatic Technologies.
We use Cookies to: (i) make our Site function properly; (ii) provide personalized experiences; (iii) tailor our interactions with you; (iv) help with our marketing efforts; (v) provide us with valuable data and statistics about the usage and effectiveness of our Site and to help us improve our Site; and (vi) help us improve our Site.
Google Analytics. We use Google Analytics to collect and process information about your use of the Site. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site.
Additionally, we may have enabled and implemented the following Google Analytics Advertising Features: Remarketing with Analytics, Demographics and Interest reporting, Campaign Manager integration, Display & Video 360 integration, Google Display Network (GDN) Impression Reporting, and Segments. Remarketing with Analytics uses Google Analytics cookies to serve advertisements to you across the Internet based on your visits to the Site. Demographics and Interest reporting uses a third-party cookie to collect information about our Site traffic by tracking users across websites and across time, which generates a report for us to better understand Site users. Campaign Manager integration allow us to view, analyze, and create remarketing lists using our Campaign Manager data in Google Analytics. Display & Video 360 integration allows us to create remarketing lists in Google Analytics and have those lists available in Display & Video 360. Google Display Network (“GDN”) Impression Reporting allows us to measure the impact of unclicked GDN Display ad impressions on website behavior and conversions. Segments allows us to isolate and analyze subsets of Site users by sorting our Google Analytics data. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.
To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
Online Behavioral Advertising. We use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including the Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites and may be sent to you via email.
We use Google Ads to serve ads across various websites. Google uses Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.
To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.
Retention of Personal Information
We will keep Personal Information for the period necessary to fulfil the purposes described in this Policy, unless a longer retention period is permitted or required by law.
Disclosure of Personal Information
We do not sell, rent or lease Personal Information to any third party for money without your knowledge. We may disclose Personal Information with the following categories of parties:
Employees. We may disclose Personal Information with our employees and affiliates who have a need to know the information for our business purposes.
Third-Parties and/or Service Providers. We may disclose Personal Information with third party service providers that provide services for us. For example, we may disclose Personal Information to vendors to help us host and manage the Site, provide targeted advertising and other marketing, improve the content and functionality of the Site, perform data analysis and statistical analysis, troubleshoot problems with the Site, and support or provide the security of the Site. We may also disclose Personal Information to third parties with whom you have a preexisting business relationship, such as real estate or mortgage professionals that referred you to the Site. Those professionals may also have their own third party relationships that may receive access to your Personal Information. You should check with your real estate and mortgage professional to understand their privacy practices. We will also disclose your Personal Information to third parties at your request and direction, such as for referrals to mortgage and other professionals that we may offer from time to time. We may earn a commission or referral fee from those professionals if and as applicable rules of professional conduct may permit.
Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, OTTO or any other party.
Professional Advisors. We may disclose Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to OTTO.
Change in Ownership. In the event OTTO is the subject of a change of control or in the event the Site changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information as part of the transaction and to the subsequent owner(s).
Other. We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
Children's Information.
The Site is not directed at children under 18 years of age. We do not knowingly collect, sell, use, or share Personal Information from children under 18. If we obtain actual knowledge that any Personal Information has been provided by a child under the age of 18, we will promptly delete that information. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.
Data Security
We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.
You understand that no data transmission over the internet or device can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide Personal Information at your own risk.
Social Media
We are active on social media, including Facebook and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on Social Media pages. Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
Access from Outside the United States
Our Site is solely intended for use within the United States and those markets we service within the United States. If you access the Site from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.
Third-Party Websites
The Site may link to websites not controlled by us. We are not responsible for third parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.
Contact Us
If you have questions or concerns regarding this Policy, contact us at:
OTTO
185 Plains Rd.
Milford, CT 06461
(857) 288-8986