Privacy Policy

OTIUM CREATIONS (PTY) LTD

Effective Date: 01 November 2025

1. INTRODUCTION

1.1 Our Commitment to Privacy

Otium Creations (Pty) Ltd ("Otium," "we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use Atlas and our related services (collectively, the "Services").

1.2 Scope of This Policy

This Privacy Policy applies to all information collected through:

1.3 Data Controller

Otium Creations (Pty) Ltd, registered in South Africa (registration number 2025/557746/07), is the data controller responsible for your personal information.

1.4 Agreement to Policy

By using our Services, you consent to the data practices described in this Privacy Policy. If you do not agree, please do not use our Services.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Account Information

Profile Information

Content and Inputs

Communications

2.2 Information Collected Automatically

Usage Information

Device Information

Location Information

Analytics Data

2.3 Information from Third-Party Services

Payment Information (via FastSpring)

3. HOW WE USE YOUR INFORMATION

3.1 Providing and Improving Services

3.2 Account Management

3.3 Service Development

3.4 Safety and Security

3.5 Communications

3.6 Legal Compliance

4. HOW WE SHARE YOUR INFORMATION

4.1 We Do Not Sell Your Personal Information

We never sell, rent, or trade your personal information to third parties for their marketing purposes. We also do not use your personal data for targeted advertising.

4.2 Service Providers

We share information with trusted service providers who assist us in operating our Services:

Essential Service Providers

These providers are contractually obligated to protect your information and use it only for providing services to us.

4.3 Legal Requirements

We may disclose information when required by law or in response to:

4.4 Aggregated and De-identified Data

We may share aggregated or de-identified data that cannot reasonably identify you for research, marketing, or other purposes.

4.5 With Your Consent

We may share your information for other purposes with your explicit consent.

5. DATA RETENTION

5.1 Retention Periods

We retain your information for as long as necessary to provide Services and fulfill the purposes described in this Policy:

Active Accounts

After Account Deletion

5.2 Deletion Requests

You may request deletion of your personal information. We will comply except where retention is necessary for:

6. DATA SECURITY

6.1 Security Measures

We implement industry-standard security measures including:

6.2 Sensitive Data Protection

Enhanced protections for sensitive data include:

6.3 No Absolute Security

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and limiting access to your devices.

6.4 Breach Notification

If a data breach occurs that may compromise your personal information, we will notify affected users as required by applicable law.

7. YOUR RIGHTS AND CHOICES

7.1 Access and Portability

You have the right to:

7.2 Correction and Update

You may update or correct your information through:

7.3 Deletion

You can request deletion of your account and personal information, subject to legal retention requirements.

7.4 Opt-Out Rights

You may opt out of:

7.5 Restriction and Objection

You may request that we:

7.6 Consent Withdrawal

Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

7.7 Regional Rights

European Union (GDPR)

EU residents have additional rights including:

California (CCPA/CPRA)

California residents have rights including:

South Africa (POPIA)

South African residents have rights under the Protection of Personal Information Act, including:

8. INTERNATIONAL DATA TRANSFERS

8.1 Cross-Border Transfers

Your information may be transferred to and processed in countries other than your country of residence, including:

8.2 Transfer Safeguards

We ensure appropriate safeguards for international transfers through:

Nothing in this Policy affects your mandatory rights under applicable consumer protection or data protection laws.

8.3 Your Consent

By using our Services, you consent to the transfer of your information to countries that may have different data protection laws than your jurisdiction.

9. CHILDREN'S PRIVACY

9.1 Age Requirements

Our Services are not intended for users under 18. We do not knowingly collect information from users under 18. If you are under 18, please do not use our Services. Parents who believe we have collected such data should contact us immediately.

9.2 Parental Controls

Parents or guardians who believe we have collected information from their child should contact us immediately for removal.

10. THIRD-PARTY SERVICES AND LINKS

10.1 Third-Party Privacy Practices

This Policy does not apply to third-party services. We encourage you to review the privacy policies of:

10.2 No Liability

We are not responsible for the privacy practices of third parties. Your interactions with third-party services are governed by their privacy policies.

11. AI-SPECIFIC PRIVACY CONSIDERATIONS

11.1 AI Processing

Your conversations and inputs are processed using AI models from trusted providers including Anthropic, OpenAI, and others we may integrate in the future. This processing involves:

11.2 Model Training

We do not use your personal conversations to train base AI models. Your data may be used to:

11.3 AI Limitations

Our AI systems:

12. DATA PROTECTION OFFICER

12.1 Contact for Privacy Matters

For privacy-related questions or to exercise your rights, contact:

Email: support@otiumcreations.com
Address: Sandton, Gauteng, 2169, South Africa

12.2 Response Timeline

We aim to respond to privacy requests within:

13. COOKIES AND TRACKING TECHNOLOGIES

13.1 What Are Cookies?

Cookies are small text files stored on your device that help us provide and improve our Services. We use cookies and similar tracking technologies such as pixels, beacons, and local storage.

13.2 Types of Cookies We Use

Essential Cookies (Always Active)

Analytics Cookies (Optional - You Control)

Marketing Cookies (Optional - You Control)

13.3 How We Use Cookies

We use cookies to:

13.4 Third-Party Cookies

Some cookies are placed by third-party services:

Google Analytics

Meta Pixel

Google Search Console

13.5 Managing Your Cookie Preferences

You can control cookies through:

Our Cookie Settings

Browser Settings

Note: Disabling essential cookies may prevent you from using certain features.

Mobile App Settings

13.6 Cookie Lifespan

Our cookies have the following lifespans:

13.7 Do Not Track

Some browsers offer a "Do Not Track" (DNT) signal. We respect DNT signals for non-essential cookies. When DNT is enabled:

13.8 Updates to Cookie Practices

We may update our use of cookies. Material changes will be communicated through:

13.9 Cookie Consent

For EU/EEA Users: We obtain explicit consent before placing non-essential cookies. You can withdraw consent at any time through cookie settings.

For Other Jurisdictions: By continuing to use our Services, you consent to our use of cookies as described. You may opt out at any time.

13.10 More Information

For questions about our cookie practices, contact: support@otiumcreations.com

For detailed information, see our Cookie Policy at: https://otiumcreations.com/cookie

14. MARKETING AND COMMUNICATIONS

14.1 Marketing Preferences

You can manage marketing preferences through:

14.2 Transactional Communications

We may send non-marketing communications about:

These essential communications cannot be opted out of while maintaining an account.

15. SPECIAL PROVISIONS FOR SPECIFIC FEATURES

15.1 Voice Features

When using voice features:

16. CHANGES TO THIS PRIVACY POLICY

16.1 Updates

We may update this Privacy Policy to reflect changes in:

16.2 Notification

We will notify you of material changes through:

16.3 Effective Date

Changes become effective 30 days after notification unless otherwise specified. Continued use after changes constitutes acceptance.

17. CONTACT INFORMATION

Otium Creations (Pty) Ltd

Address: Sandton, Gauteng, 2169, South Africa
Privacy Inquiries: support@otiumcreations.com
Website: https://otiumcreations.com

By using our Services, you acknowledge that you have read and understood this Privacy Policy.