Privacy Policy
Last updated: September 17, 2026
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal Data to provide and improve the Service. We collect, use, and disclose Your information as described in this Privacy Policy and, where required by applicable law, only where We have a valid legal basis to do so, including Your consent where consent is required.
Interpretation and Definitions
Interpretation
The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You to access Our Service or parts of Our Service. Affiliate means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority. Application refers to Fusion, the software program provided by the Company.
Business, for the purposes of the CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ personal information, or on behalf of which such information is collected, and that alone, or jointly with others, determines the purposes and means of the processing of Consumers’ personal information, and that does business in the State of California. CCPA and/or CPRA refers to the California Consumer Privacy Act as amended by the California Privacy Rights Act of 2020.
Company, referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy Policy, refers to Wagner Media Group LLC, 24 Valley Rd, Norwalk CT, 06854. For the purposes of the GDPR, the Company is the Data Controller. Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident includes every individual in California for other than a temporary or transitory purpose, and every individual domiciled in California who is outside the state for a temporary or transitory purpose.
Cookies are small files placed on Your computer, mobile device or other device by a website, containing the details of Your browsing history on that website, among its many uses. Country/State refers to Connecticut, United States. Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. Device means any device that can access the Service, such as a computer, a cell phone or a digital tablet.
Do Not Track (DNT) is a concept promoted by U.S. regulatory authorities, in particular the Federal Trade Commission, for the Internet industry to develop and implement a mechanism allowing Internet users to control tracking of their online activities across websites. GDPR refers to the EU General Data Protection Regulation. Personal Data, or Personal Information, is any information that relates to an identified or identifiable individual. We use “Personal Data” and “Personal Information” interchangeably unless a law uses a specific term.
For the purposes of GDPR, Personal Data means any information relating to You such as a name, identification number, location data, online identifier, or factors specific to physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of CCPA/CPRA, Personal Data means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
Service refers to the Application or the Website or both. Service Provider means any natural or legal person who processes data on behalf of the Company, including third-party companies or individuals employed to facilitate the Service, provide it on Our behalf, perform related services, or assist in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered Data Processors.
Usage Data refers to data collected automatically, either generated by use of the Service or from the Service infrastructure itself, for example the duration of a page visit. User means any individual who accesses or uses the Service. Website refers to OTT Advisors, accessible from https://www.ottadvisors.com/. You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service. Under GDPR, You may be referred to as the Data Subject.
Collecting and Using Your Personal Information
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to, Your email address, first and last name, and phone number.
Usage Data
Usage Data is collected automatically when using the Service. It may include Your device’s Internet Protocol address, browser type and version, pages You visit, the time and date of Your visit, time spent on pages, unique device identifiers, and other diagnostic data. When You access the Service through a mobile device, We may also collect the type of device, its unique ID, IP address, operating system, mobile browser type, unique device identifiers, and other diagnostic data. We may also collect information Your browser sends whenever You visit Our Service.
Tracking Technologies and Cookies
We use tracking technologies, such as cookies, to track activity and improve Our Service. Cookies are small files placed on Your Device; You can instruct Your browser to refuse all Cookies or indicate when one is being sent, though You may not be able to use some parts of Our Service. Certain sections may also contain web beacons, clear gifs, pixel tags, or single-pixel gifs, allowing the Company to count visitors and compile related website statistics.
Cookies can be Persistent or Session Cookies. Persistent Cookies remain on Your computer or mobile device when You go offline, while Session Cookies are deleted when You close Your web browser. Where required by law, We use non-essential cookies only with Your consent. You can withdraw or change Your consent at any time using Our cookie preferences tool, where available, or through Your browser or device settings. Withdrawing consent does not affect processing based on consent before its withdrawal.
We use Session and Persistent Cookies for the following purposes: Necessary / Essential Cookies are session cookies administered by Us to provide services available through the Website, authenticate users, prevent fraudulent use of accounts, and enable features You request. Cookies Policy / Notice Acceptance Cookies are persistent cookies administered by Us to identify whether users have accepted cookies and to record their consent choices. Functionality Cookies are persistent cookies administered by Us to remember choices such as Account login details or language preference, providing a more personal experience and avoiding repeated entry of preferences.
Use of Your Personal Data
The Company may use Personal Data to provide and maintain Our Service, including monitoring its usage; manage Your Account and registration; perform contracts for products, items, or services You purchase; contact You by email, calls, SMS, push notifications, or equivalent electronic communications about updates, functionality, products, contracted services, and security updates; and manage Your requests.
We may provide news, special offers, and general information about goods, services, and events similar to those You have purchased or inquired about. We send marketing communications only where permitted by applicable law: where prior consent is required, including under laws applicable in the EEA and UK, We will send them only with Your consent; otherwise, We may send them until You opt out. You may opt out or withdraw consent at any time using the unsubscribe link in a marketing email or by contacting Us.
We may use Personal Data for business transfers, such as a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all assets. We may also use information for data analysis, identifying usage trends, determining the effectiveness of promotional campaigns, and evaluating and improving Our Service, products, services, marketing, and Your experience. We may share Personal Data with Service Providers to monitor and analyze use of the Service and to contact You; with affiliates who must honor this Privacy Policy; in business transfers; with other users where public areas are offered; and for other purposes with Your consent.
Text Messages Privacy Notice
You have the option to receive text (SMS) messages from Us. If You opt in, We will send updates, notifications, and other communications. We will collect and store the information You provide in connection with text messaging, such as Your phone number, the date and method of consent, and message delivery and read information. No mobile information will be shared with or sold to third parties or affiliates for marketing or promotional purposes. Phone numbers and consent records are never shared except with Service Providers that technically handle them to deliver texts.
Consent to receive text messages is not a condition of any purchase or use of Our Service. If You consent to receive SMS from Us, You agree to receive customer care and support, account notifications, delivery notifications and updates, authentication messages, security alerts, and marketing or promotional offers. Reply STOP to opt out and HELP for support. Message and data rates may apply, messaging frequency may vary, and carriers are not liable for delayed or undelivered messages.
Retention of Your Personal Data
The Company retains Personal Data only as long as necessary for the purposes in this Privacy Policy, to comply with legal obligations, resolve disputes, and enforce agreements and policies. Where possible, We apply shorter retention periods or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the periods below are maximum periods, and We may delete or anonymize data sooner when it is no longer needed.
User Accounts are retained for the duration of the Account relationship plus up to 24 months after closure. Support tickets, correspondence, and chat transcripts may be retained up to 24 months from ticket closure for follow-up inquiries, quality assurance, training, and potential legal claims. Website analytics data, application usage statistics, and server logs may be retained up to 24 months for analysis, service improvement, security monitoring, and troubleshooting. Usage Data may be retained longer where necessary for security, fraud prevention, or legal compliance.
We may retain Personal Data beyond stated periods because of legal obligations, legal claims, Your explicit request, or technical limitations such as routine backup schedules. You may request information about retention by contacting Us. When periods expire, We securely delete or anonymize Personal Data. Residual copies may remain in encrypted backups for a limited period and are not restored except for security, disaster recovery, or legal compliance. Anonymous statistical data that cannot be linked to You may be retained indefinitely for research and analytics.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and other locations where the parties involved in processing are located. This may mean information is transferred to and maintained on computers outside Your state, province, country, or governmental jurisdiction, where data protection laws may differ. Where required by law, We ensure international transfers are subject to appropriate safeguards and supplementary measures. We take reasonably necessary steps to ensure data is treated securely and in accordance with this Privacy Policy, and no transfer will take place unless adequate controls are in place.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting Personal Data We have collected about You. Our Service may allow You to delete certain information from within the Service. You may update, amend, or delete information by signing in to Your Account and visiting its settings, if available, or contact Us to request access to, correction of, or deletion of Personal Data You provided. We may need to retain certain information where We have a legal obligation or lawful basis to do so.
Disclosure of Your Personal Data
If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred; We will provide notice before it is transferred and becomes subject to a different Privacy Policy. The Company may disclose Personal Data if required by law or in response to valid requests by public authorities, such as a court or government agency. We may also disclose it in good faith where necessary to comply with a legal obligation, protect Company rights or property, prevent or investigate wrongdoing, protect personal safety, or protect against legal liability.
Security of Your Personal Data
The security of Your Personal Data is important to Us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Personal Data, We cannot guarantee its absolute security.
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data based on consent; performance of a contract; legal obligations; vital interests; public interests; or legitimate interests. The basis depends on the purpose: contract performance supports Accounts, Service delivery, and support; legitimate interests support security, fraud prevention, service monitoring and improvement, non-marketing communications, enforcement, legal claims, and business transfers; consent supports marketing where required and non-essential cookies where required; and legal obligations support transaction, tax, accounting records, and lawful requests. Where providing Personal Data is a statutory or contractual requirement, or necessary to enter a contract, We will make this clear at or before collection.
International Transfer of Personal Data
We may transfer, store, and process Personal Data in countries outside the EEA and UK where data protection laws may differ. Where We transfer data to a country not recognized as adequate, We rely on appropriate safeguards such as adequacy decisions, the EU Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, and supplementary measures such as encryption, access controls, data minimization, and vendor security reviews. Transfers occur only as needed to provide the Service and work with Service Providers. You may contact Us for information about safeguards, including copies of relevant contractual protections where appropriate.
Your Rights under the GDPR
Where GDPR or UK GDPR applies, You may request access to, correction of, restriction of processing of, transfer of, or erasure of Your Personal Data; object to processing based on legitimate interests or for direct marketing; and withdraw consent at any time. Where possible, You may access, update, or request deletion directly in Account settings. You may exercise these rights by contacting Us. We may ask You to verify identity before responding and generally respond within one month, with an extension of up to two further months where permitted. You also have the right to complain to a supervisory authority in the EEA or the UK Information Commissioner’s Office. We do not make solely automated decisions, including profiling, that produce legal or similarly significant effects concerning You.
CCPA/CPRA Privacy Notice (California Privacy Rights)
Categories of Personal Information Collected
This notice supplements Our Privacy Policy for California residents. We may collect the following CCPA/CPRA categories: Category A, Identifiers, such as name, address, online identifier, IP address, email address, or account name — collected: Yes; Category B, California Customer Records information, such as name, address, phone number, education, employment history, or financial information — collected: Yes; Category F, Internet or similar network activity, such as browsing history and website interactions — collected: Yes. Categories C through E and G through L, including protected characteristics, commercial information, biometric information, geolocation, sensory data, professional information, education information, inferences, and sensitive personal information — collected: No.
Personal Information under CCPA/CPRA does not include publicly available information, deidentified or aggregated consumer information, or information excluded from scope such as HIPAA or CMIA health information, clinical trial data, information covered by FCRA, GLBA, FIPA, or the Driver’s Privacy Protection Act. We obtain information directly from You, indirectly from observing activity, automatically through cookies, and from Service Providers.
Use and Disclosure of Personal Information
We may use or disclose Personal Information for business or commercial purposes including operating and providing the Service, providing support and responding to inquiries, fulfilling the reason You provided information, responding to lawful requests, internal administration and auditing, detecting security incidents, and protecting against malicious, deceptive, fraudulent, or illegal activity. In the preceding 12 months, We may have disclosed Categories A, B, and F for business or commercial purposes to Service Providers, affiliates, and third-party vendors You authorize. We contractually require Service Providers and contractors to keep Personal Information confidential and use it only for limited, specified purposes.
Sale or Sharing of Personal Information
We have not sold or shared Personal Information of California residents in the preceding 12 months, and We do not sell or share Personal Information as those terms are defined in CCPA/CPRA. We disclose Personal Information only to Service Providers and contractors under written restrictions, or as otherwise described in this Privacy Policy and permitted by CCPA/CPRA. California residents’ Personal Information is retained for as long as reasonably necessary for the purposes described here, considering Service and Account needs, deletion requests, legal, tax, accounting, regulatory, security, fraud prevention, dispute resolution, and enforcement needs.
Personal Information of Minors Under 16 Years of Age
We do not knowingly collect Personal Information from minors under 16 through Our Service. We do not sell Personal Information of Consumers We actually know are under 16 unless We receive affirmative authorization from a parent or guardian. If You believe a child under 16 provided Us information, please contact Us with sufficient detail to allow deletion.
Your Rights under the CCPA/CPRA
California residents have the right to notice; know and access information about collection, use, sale, disclosure, and sharing; opt out of sale or sharing; correct inaccurate information; limit use or disclosure of certain sensitive Personal Information where applicable; request deletion subject to exceptions; and not be discriminated against for exercising these rights. We may deny deletion where retaining information is necessary to complete a transaction, maintain security, debug products, exercise free speech or other legal rights, comply with law, conduct permitted research, enable expected internal uses, or make other lawful compatible uses.
Exercising Your CCPA/CPRA Data Protection Rights
To exercise these rights, contact Us at chris.atwood@ottadvisors.com. We may verify identity for requests to know, delete, or correct, but will not require a verifiable request to opt out of sale or sharing or limit sensitive information. Requests must provide sufficient information to verify identity or authority and enough detail to understand and respond. We confirm receipt within 10 business days unless already granted or denied, and respond within 45 calendar days, with one possible 45-day extension where reasonably necessary. Requests to know generally cover the preceding 12 months, unless You request a longer period permitted by law. We provide portable information in a readily usable format.
Do Not Sell or Share My Personal Information
We have not sold or shared Personal Information of California residents in the preceding 12 months and do not sell or share Personal Information as defined by CCPA/CPRA. If Our practices change, We will update this Privacy Policy, provide the required opt-out link and methods, and honor opt-out preference signals such as the Global Privacy Control.
Limit the Use or Disclosure of My Sensitive Personal Information
We do not collect or use sensitive Personal Information for purposes other than those specified in CCPA/CPRA and its implementing regulations, and We do not process sensitive Personal Information to infer characteristics about consumers. Accordingly, We are not required to provide a method for requests to limit its use or disclosure. If Our practices change, We will update this Privacy Policy and provide the required means to exercise this right.
“Do Not Track” Policy as Required by CalOPPA
Our Service does not respond to Do Not Track signals. Some third-party websites may track Your browsing activities; when visiting such websites, You can set browser preferences to indicate that You do not want to be tracked. You can enable or disable DNT by visiting Your browser’s preferences or settings page.
Your California Privacy Rights
Under California Civil Code § 1798.83, California residents with an established business relationship with Us may request information once a year about sharing Personal Data with third parties for their direct marketing purposes. We do not disclose California customers’ Personal Information to third parties for those third parties’ own direct marketing purposes. California residents under 18 who are registered users may request removal of content or information they have publicly posted; contact Us with the email associated with Your Account. Such requests do not guarantee complete removal where the law does not permit or require it.
Children’s and Minors’ Privacy
The Service is not directed to, and We do not knowingly collect Personal Information from, anyone under 16. If You are a parent or guardian and believe Your child has provided Us Personal Information, please contact Us. If We become aware We collected Personal Information from anyone under 16, We will remove it from Our servers as soon as reasonably possible. Some countries and states set a higher age for consent; where We rely on consent and applicable law requires it, We may require a parent or guardian’s consent before collecting and using a User’s Personal Information.
Links to Other Websites
Our Service may contain links to websites not operated by Us. If You click a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of third-party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service before the change becomes effective and will update the “Last updated” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically. Changes are effective when posted on this page.
Contact Us
If You have any questions about this Privacy Policy, You can contact Us by email at chris.atwood@ottadvisors.com.