Legal
Privacy Policy
Last updated: 3 October 2026
Who we are
OTO Careers is a product of Archema Labs Ltd, a company registered in Scotland under company number SC879076. Our registered office is in Glasgow, Scotland, United Kingdom. We are registered with the Information Commissioner's Office under reference ZC161034. We operate the career growth platform at otovios.com and its associated subdomains.
If you have any questions about this policy or how we handle your data, write to us at privacy@otovios.com. We will respond within five working days.
What data we collect
We collect only what we need to provide the service.
When you create an account, our authentication provider processes your email address and password. OTO does not store your password in plain text.
When you complete onboarding, we collect the information you provide or that we extract from your uploaded documents. This may include your name, professional headline, location (city and country only, never a full address), work experience, education, skills and professional summary. You review and confirm everything before it is saved.
When you use the platform, we collect data you add directly. This includes CPD events, PDP goals, skill ratings, mood check-ins and coaching session responses. This data is yours and is used only to power your dashboard and reports.
When you visit your public CV page or someone else visits it, we log the visit with a country code and referring domain. We do not store IP addresses. We do not use third-party analytics services on CV pages.
When you upload a CV or LinkedIn export, the file is stored in a private, access-controlled storage bucket. If you choose automated document analysis, the selected file is sent securely to Anthropic so that a draft profile can be extracted for your review. Free onboarding includes one successful automated document analysis, with a small number of retry attempts for failed processing. You can delete an uploaded file from your settings.
What we never collect
You may save an optional CV email address, mobile number and referee details in Profile under Private CV details. These are stored separately from your shared profile. They are never displayed on your public, link-only or private web CV and are not included in AI coaching or Pathways requests. You choose whether to include them in each downloaded CV. Only add another person's referee details with their permission. You can clear these fields and save to remove their stored values, or include them in your account data export.
We do not collect payment card details. Payments are processed by Stripe, who handle card data directly. We receive the customer, subscription and payment-status information needed to provide and administer your plan.
We do not collect information about your browsing behaviour across other websites. We do not use advertising trackers, Facebook pixels, or any third-party marketing cookies.
We process the coaching question you deliberately submit only to generate and save your private coaching response. Coaching content is never included in your public profile. Saved goals, CV content, wellbeing records and connected-service data are not added to a coaching request.
How we use your data
We use your data to provide the service you signed up for. This includes building and displaying your profile, generating your OTO Pathways report, calculating your OTO Score, sending you transactional emails (account confirmation, password reset), and processing your subscription via Stripe.
We send product news and marketing messages only where you have opted in or where another lawful permission applies. You can withdraw your choice or unsubscribe at any time. Transactional emails, such as account confirmation, password reset and essential service notices, are sent where necessary to operate your account and are not marketing.
We do not sell your data. We do not share your data with advertisers. We do not use your data to train machine learning models operated by third parties.
If you choose automated document analysis, the CV or selected LinkedIn export you upload is sent to Anthropic to extract a draft profile. You must review that draft before saving it. The OTO Pathways report is then generated by sending a structured summary of your confirmed profile to Anthropic. The summary includes your experience, skills and OTO target. It is not intended to include your email address, phone number, coaching responses or wellbeing data. Do not upload information that you do not want processed for this purpose.
Anthropic acts as our service provider for these requests. If a Flourish member chooses to use coaching, the question entered for that session is sent to OpenAI with response storage disabled. Career context is off by default. If the member explicitly selects it for that session, OTO also sends a compact summary of up to five recent CPD, PDP and goal records in each area. Notes, attachments, CV content, wellbeing records, email, calendar and file data are excluded. OTO records a content-free consent receipt containing only the categories, record counts and a digest. The question and generated response are saved privately in the member's OTO coaching history. We do not use your profile, uploaded documents or coaching question to train general-purpose AI models.
Google and Microsoft connections
Connecting a Google or Microsoft account is optional. We request permissions separately for calendar reading, user-confirmed calendar writes, email metadata and file metadata. We use account details to label your connection; calendar data to show schedules, availability and conflicts; email metadata to show a bounded inbox summary; and file metadata to show a bounded file list.
Connected calendar events are synchronised into a separate private OTO projection. Google or Microsoft remains the source of truth, and OTO retains provider identifiers so later changes and deletions can be reconciled. Imported events are not silently converted into native OTO events. When you select availability-only mode, OTO excludes event titles and provider links.
The Gmail connector does not read message bodies, snippets, recipients or attachment content. The Drive connector does not download file content or collect sharing and permission lists.
Connected-service data is stored in your private, access-controlled OTO account. OAuth tokens and sync cursors are encrypted and handled only by server-side connector code. OTO does not sell connected-service data, use it for advertising, or use it to train or improve general-purpose AI models. In the current implementation, Google Calendar, Gmail, Drive, Microsoft Outlook and OneDrive records are not sent to OpenAI, Anthropic or another LLM provider. OTO uses connected calendar projections deterministically for calendar display, agenda, availability and conflict checks.
When you disconnect Google or Microsoft, OTO attempts provider revocation where supported, deletes its local encrypted credentials, permission grants, synchronisation state and imported calendar, email and file metadata, and stops further synchronisation. We retain only a minimal disconnect audit record without imported content. Deleting your OTO account removes the remaining owner-linked connector records.
The use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. A detailed Google data-use notice is available at /google-data-use.
Your public profile and visibility
Your profile is private by default after onboarding. No one else can view it unless you choose to publish it. You can change its visibility to link-only, public, private or off from your settings.
When your profile is link-only, anyone with its URL can view it, but we add instructions intended to prevent search engines from indexing it.
When your profile is set to public, we add appropriate meta tags to allow search engines to index it. When you switch away from public, we change those tags to prevent further indexing. Search engines control when previously indexed results disappear, so removal may not be immediate.
We log every visibility change with a timestamp and an anonymised identifier for compliance purposes. This log is accessible to you from your settings page.
Email addresses and phone numbers are never shown on your public profile regardless of your visibility setting. Coaching and wellbeing data is never shown publicly.
Your rights under UK GDPR
You have the right to access all data we hold about you. You can export your profile data as JSON from your settings page at any time. For a full data export including logs and metadata, write to privacy@otovios.com.
You have the right to correct any data we hold that is inaccurate. All profile fields are editable from your dashboard.
You have the right to delete your account and all associated data. Go to Settings, then Account, then Delete Account. Deletion is processed immediately. Your data is removed from our live systems within 24 hours and from backups within 30 days.
You have the right to restrict or object to processing. If you have concerns about how we use your data, write to us at privacy@otovios.com and we will address them within five working days.
You have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe we have not handled your data correctly. The ICO can be reached at ico.org.uk.
Our legal basis for core account and service processing is the performance of the contract between you and Archema Labs Ltd. We rely on consent where we ask you to opt in to marketing or optional data uses, on legitimate interests where necessary to keep the service secure and improve it in a proportionate way, and on legal obligations where records must be retained. You can withdraw consent at any time without affecting processing already carried out.
Where your data is stored
Core OTO account data is stored in Supabase, with servers located in London (eu-west-2). Some optional processing and service-provider operations may take place outside the United Kingdom or European Economic Area as described below. Where required, we use appropriate transfer safeguards.
Files you upload (CV documents, profile photos) are stored in Supabase Storage, also in the London region.
If you choose automated CV or LinkedIn analysis, the selected document is sent to Anthropic to extract a draft profile. After you review and confirm your profile, we send a structured summary to Anthropic to generate your OTO Pathways report. The report request is not intended to contain raw documents, email addresses, phone numbers, coaching responses or wellbeing data.
If you choose Flourish coaching, the question you type is sent to OpenAI to generate one structured coaching response. The request is made with response storage disabled. You can separately choose to include a compact summary of recent CPD, PDP and goal records for that session. This is off by default and excludes notes, attachments, your CV and connected-service data.
We use Stripe for payment processing. Card details are never transmitted to our servers. They go directly to Stripe. Stripe's data is processed in the United States under standard contractual clauses.
We use Resend to send transactional emails. Email addresses are transmitted to Resend for delivery purposes only.
How long we keep your data
We keep your data for as long as you have an active account. If you delete your account, your data is removed from our live systems within 24 hours. Encrypted backups are purged within 30 days.
Consent logs and visibility change records are retained for seven years for legal compliance purposes, even after account deletion. These logs contain only timestamps and anonymised identifiers, not personal profile content.
Stripe retains payment records for seven years in accordance with financial regulation. We do not control this retention period.
Cookies
We use a single authentication cookie to keep you signed in. This cookie is strictly necessary for the service to function and cannot be disabled.
We do not use advertising cookies. We do not use analytics cookies from third-party providers such as Google Analytics. We do not use cookies to track your behaviour across other websites.
If you are in the UK or EU, you will not see a cookie banner from us because we do not set any cookies that require consent.
Changes to this policy
If we make changes to this policy that affect how we use your data, we will notify you by email at least 14 days before the changes take effect. The updated policy will always be available at otovios.com/privacy.
Minor changes, such as correcting a typo or clarifying existing practices without changing them, may be made without advance notice. The date at the top of this page always reflects when the policy was last updated.