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IMPORTANT — PLEASE READ CAREFULLY

Your privacy matters to us. This Privacy Policy explains how TeleVet, Inc, d/b/a Otto. (“Otto,” “We,” “Us,” or “Our”) collects, uses, stores, and shares personal information about visitors to the Otto website at www.otto.vet (the “Site”) and users of the Otto platform, including veterinary clinic staff and other authorized account users (collectively, the “Services”). This Privacy Policy also explains your rights in relation to your personal information and how to contact Us.

Scope. This Privacy Policy applies to personal information We collect about you in your capacity as a Site visitor, prospective customer, Account holder, or authorized user of the Otto platform. It does not cover the personal information of a veterinary clinic’s customers (“Consumers,” including pet owners) that a veterinary clinic (a “Clinic”) submits to, or generates through, the Services — such as customer contact records, pet information, appointment history, and the content of messages sent to Consumers. Otto processes that Consumer data as a service provider on behalf of the Clinic, and Our handling of it is governed by Our Services Agreement with the Clinic (and any applicable Data Processing Addendum). Clinics are solely responsible for providing privacy notices to, and obtaining any required consent from, the Consumers whose data they submit — including any consent required to send text messages under the Telephone Consumer Protection Act (TCPA) and applicable state law. Messages sent to Consumers are also subject to Our Consumer Messaging Terms.

By accessing or using the Services, you agree to the practices described in this Privacy Policy. Your use of the Services is also governed by Our Services Agreement and Terms of Service.

You must be at least 18 years old to use the Services.

1. Contact Information

If you have any questions or concerns regarding your privacy rights, this Privacy Policy, or Our data practices, you may contact Us at:

Email: privacy@otto.vet

Mail: Otto, 2400 E Cesar Chavez St, Suite #320, Austin, TX 78702

2. Personal Information We Collect

We collect personal information from the following sources:

2.1 Information You Provide Directly

• Account Registration: When you register for an Account, We collect your email address. You may optionally provide additional profile information, such as your name, clinic or company name, and role, through your user profile.
• Billing Information: When you configure billing or payment methods, We collect billing contact details and payment method references (processed by Our third-party payment processor, Stripe — We do not store full payment card numbers).
• Customer Support: When you contact Us or request support, We collect the information you submit, including your name, email address, and the content of your communications.
• Demo and Marketing: When you request a demo or submit a form on Our Site, We collect the business contact information you provide (such as name, clinic name, email, and phone number).

2.2 Information Collected Automatically

When you interact with the Services, We automatically collect:

• Usage Data: Information about how you access and use the platform, including pages visited, features used, and actions taken.
• Device and Connection Data: IP address, browser type, operating system, and device identifiers.
• Session Data: Login timestamps, session duration, and user-agent information, captured at the time of account activity (including policy acceptance) for security and audit purposes.
• Cookies and Tracking Technologies. We use cookies and similar technologies in three categories: (i) strictly necessary cookies required for platform operation, including authentication, session management, security, and fraud prevention; (ii) functional cookies that remember your preferences and settings; and (iii) analytics cookies that help Us diagnose issues, measure performance, and improve the Services. Some cookies are set by third-party service providers that support platform operation (such as security and content-delivery services) and are subject to those providers’ own policies. We do not use cookies for cross-context behavioral advertising or third-party marketing. You may configure your browser to refuse or delete cookies at any time; however, blocking strictly necessary cookies will prevent the Services from functioning correctly.
• Browser Privacy Signals. The Services honor the Global Privacy Control (GPC) signal and the Do Not Track (DNT) browser setting. Because We do not sell your personal information or use it for cross-context behavioral advertising, enabling these signals does not affect Our collection of information necessary to operate the Services (such as session and security cookies). Where Applicable Law requires these signals to be treated as opt-out requests, We will treat them accordingly.

2.3 Information From Third Parties

• Payment Processor: Our third-party payment processor returns transaction statuses, tokenized payment method references, and related billing information when you fund or update your Account.
• Analytics and Marketing Providers: We may receive limited usage and engagement information from analytics and email-delivery providers that support the Site and Account communications.

Sensitive Personal Information. The only sensitive personal information We process is your Account log-in credentials, which We use solely to authenticate you and secure your Account. We do not use or disclose this information to infer characteristics about you, and We do not sell or share it. Accordingly, no separate right to limit its use applies.

3. How We Use Your Information

We use the personal information We collect to:

• Provide and operate the Services, including authenticating you, maintaining your Account, and enabling you to access platform features.
• Process payments, including charging your payment method and managing your Account balance and billing.
• Send transactional communications, including billing notifications, payment alerts, policy update notices, security alerts, and password reset messages.
• Maintain security and audit trails, including recording IP addresses and user-agent information at the time of consent acceptance and other significant account actions.
• Provide customer support and respond to inquiries.
• Improve the Services, including analyzing usage patterns, debugging errors, and developing new features.
• Comply with legal obligations, including responding to lawful requests from law enforcement or regulatory authorities.
• Detect and prevent fraud, security incidents, and other malicious or illegal activity.

4. How We Share Your Information

We may share your personal information in the following circumstances:

• Service Providers: We share information with third-party service providers who assist in operating the Services, including Our payment processor, email and SMS delivery providers, cloud infrastructure providers, and analytics providers. These providers are contractually obligated to use your information only to provide services to Us.
• Affiliates: We may share information with Our parent, subsidiary, and affiliated companies for internal business purposes.
• Legal Requirements: We may disclose information when required by law, court order, or governmental authority, or when We believe disclosure is necessary to protect Our rights, your safety, or the safety of others.
• Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity. In insolvency proceedings, personal information may be disposed of in a transaction approved by the court.

We do not sell your personal information, and We do not share it for cross-context behavioral advertising or third-party marketing purposes.

5. Data Retention

• Active Accounts: We retain your personal information for as long as your Account remains active and as needed to provide the Services.
• Billing and Transaction Records: We retain billing and transaction records as required by applicable tax and financial recordkeeping laws, generally up to seven (7) years.
• After Termination: Following Account termination, We retain personal information for a reasonable period as necessary to comply with legal obligations, resolve disputes, enforce agreements, and maintain audit trails.
• Inactive Accounts: For accounts inactive for more than twelve (12) consecutive months, We may delete or anonymize associated personal information.
• De-identified Data: We may retain de-identified, aggregated usage data indefinitely for analytics and platform improvement.

6. Data Security

We implement commercially reasonable technical and organizational security measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption in transit and at rest, role-based access controls, and regular audits and system monitoring.

However, no method of transmission over the Internet or method of electronic storage is fully secure. While We strive to protect your information, We cannot guarantee absolute security, and you acknowledge the inherent security and privacy limitations of the Internet that are beyond Our control.

Breach Notification. In the event of a data breach affecting your personal information, We will notify you and the appropriate regulatory authorities where required by Applicable Law, without undue delay and within the time periods required by Applicable Law. Such notification will describe the nature of the breach, the categories of personal information affected, the measures taken to address it, and steps you may take to mitigate potential harm.

7. Transfer, Processing, and Storage

Otto is based in the United States, and We store and process personal information in the United States. Your personal information may be transferred to, processed, and stored in the United States or other jurisdictions where data protection laws may differ from those of your jurisdiction. We take reasonable steps to ensure your personal information is treated securely and in accordance with this Privacy Policy regardless of where it is processed. Your use of the Services following the posting of this Privacy Policy constitutes your agreement to such transfers.

8. Third-Party Links

The Services may contain links to third-party websites or services. We are not responsible for the privacy practices or content of any third party. This Privacy Policy applies only to information collected by Us through the Services. We encourage you to review the privacy policies of any third-party websites or services you visit.

9. Children

The Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from anyone under 13 years of age. Consistent with the Children’s Online Privacy Protection Act (“COPPA”), if We become aware that a child under 13 has provided Us with personal information, We will promptly delete it. If you believe a child under 13 has provided Us with personal information, please contact Us at privacy@otto.vet.

10. Your Privacy Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal information We hold about you.
• Correct inaccurate or incomplete personal information.
• Delete your personal information, subject to legal retention requirements.
• Opt out of the sale or sharing of personal information, or of processing for targeted advertising. As stated above, We do not sell or share personal information or engage in targeted advertising.
• Restrict or object to certain processing of your personal information.
• Data portability — receive your personal information in a structured, machine-readable format.

How to exercise your rights. To exercise any of these rights, contact Us at privacy@otto.vet. We may need to verify your identity before responding, using the email address associated with your Account. You may use an authorized agent to submit a request; We may require written, signed permission and verification of your identity. We will respond to verified requests within forty-five (45) days of receipt. If We need additional time, We may extend the period by up to an additional forty-five (45) days and will notify you of the extension and the reason within the initial 45-day period.

Right to Appeal. If We decline to act on your request, you may appeal by emailing privacy@otto.vet with the subject line “Privacy Request Appeal.” We will respond to your appeal in writing within the time required by Applicable Law (generally sixty (60) days), including the reasons for Our decision. If your appeal is denied, you may contact your state Attorney General to submit a complaint.

Non-Discrimination. We will not discriminate or retaliate against you for exercising any of your privacy rights. We will not deny you services, charge different prices, or provide a different level of service because you exercised your rights.

11. State Privacy Rights

Residents of certain states — including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia — have the rights described in Section 10, subject to the exceptions and limitations in their state’s law. To exercise these rights, contact Us at privacy@otto.vet.

12. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides additional rights, including the right to know the categories and specific pieces of personal information We collect, use, and disclose; the right to delete; the right to correct; the right to opt out of the sale or sharing of personal information; and the right to limit the use of sensitive personal information. We do not sell or share personal information, We do not use personal information for cross-context behavioral advertising, and We use sensitive personal information (Account credentials) only to authenticate and secure your Account. We will not discriminate against you for exercising your rights. To exercise your California privacy rights, contact Us at privacy@otto.vet. You may also designate an authorized agent to make a request on your behalf as described in Section 10.

California “Shine the Light.” California Civil Code § 1798.83 permits California residents to request information about disclosures of personal information to third parties for those third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing.

13. Changes to This Privacy Policy and Continued Use

We may update this Privacy Policy from time to time. When We make material changes, We will notify you via email at the address associated with your Account or through a notice within the Services. Your continued use of the Services after receiving notice of an updated Privacy Policy constitutes acceptance of those changes. If you do not agree to the updated Privacy Policy, you must discontinue use of the Services and terminate your Account in accordance with the Services Agreement. We encourage you to review this Privacy Policy periodically.