This Privacy Policy explains how Harel Levy, doing business as OTRERA ("OTRERA," "we," "us," or "our") collects, uses, shares, and protects personal information when you visit our website, take our quiz, read our emails, or use any related features (together, the "Service"). It also explains your choices and rights.
Health data has its own policy. Your answers about pain, nagging issues, and past injuries are "consumer health data." Our separate Consumer Health Data Privacy Policy explains in detail how we handle that data. If the two policies differ on consumer health data, the Consumer Health Data Privacy Policy controls.
The short version
- OTRERA is a strength program for women who train hard. It is not available yet. Right now we run a short online quiz to learn whether people want it.
- After the quiz you may see a price page. If you click to pay, we tell you that your plan isn't ready yet and that you have not been charged. We do not collect card or payment details at this stage.
- We collect your email address and your quiz answers. We ask for your separate consent before we ask about pain or nagging issues.
- We do not sell your personal information. We never share your quiz answers or health data with advertisers, and we never use health data for targeted advertising.
- Advertising and analytics cookies load only if you accept them in our cookie banner. We honor Global Privacy Control.
- You can unsubscribe, access your data, or have it deleted at any time by emailing [email protected].
1. Information we collect
1.1 Information you give us
| Information | Examples | Required? |
|---|---|---|
| Email address | The email you enter to get your plan | Yes, to receive your plan and updates |
| Age range | 18–29, 30–39, 40–49, or 50+ | Yes |
| Training information | Your sport, how often and how long you train, how your program looks, the time you can give each session | Yes |
| Goals and preferences | Your 12-week goal, race date (if you have one), what helps you stay consistent, what you don't want to give up, what worries you about starting | Yes |
| Consumer health data (sensitive) | Whether something nags you now or did in the past, the body area, how long it has lasted, when you notice it, how it affects your training, and what you have tried | Only with your separate consent (see Section 2) |
| Price page interaction | Whether you reached the price page and clicked to pay | Collected automatically. No payment details are collected |
| Messages to us | Anything you send when you contact us | Only if you contact us |
When paid subscriptions launch, we will also collect the information needed to manage your subscription, such as your plan, billing dates, subscription status, and records of your consent to automatic renewal. Payments will be processed by our payment processor (Stripe). We will not receive or store your full card number. We may receive limited payment details from the processor, such as card type, the last four digits, and the expiration date.
1.2 Information collected automatically
- Device and connection data: IP address, browser type, device type, operating system, and approximate location (city or region) derived from your IP address. We do not collect precise geolocation.
- Usage data: pages viewed, clicks, time on page, where you stop in the quiz, and the link or ad that brought you to us.
- Cookies and similar technologies: described in Section 6 and in our Cookie Policy. Non-essential cookies load only if you accept them.
1.3 Information from others
- Service providers that run the quiz, our emails, hosting, and (in the future) payments, which collect data for us.
- Advertising platforms such as Meta, which give us aggregated reports about how our ads performed.
- Our own inferences from your answers, such as which focus area or plan type may suit you.
2. Sensitive personal information and consumer health data
Your answers about pain, nagging issues, and past injuries, and anything we infer from them, are sensitive personal information and consumer health data under several state laws.
- Consent first. Before you answer any question about pain or nagging issues, we ask you to agree in a separate checkbox that is not pre-checked. If you do not agree, we do not collect those answers.
- Limited use. We use this data only to show your quiz results, tailor your plan, send you emails about your plan, measure interest in OTRERA in aggregated or de-identified form, keep the Service secure, and comply with the law. Because we use sensitive personal information only for these purposes, we do not offer a separate "Limit the Use of My Sensitive Personal Information" link. If that changes, we will add one.
- No sale, no ads. We never sell this data, never share it with advertising or social media platforms, and never use it for targeted advertising or to build advertising profiles.
- You can withdraw consent at any time, and we will delete this data.
Full details are in our Consumer Health Data Privacy Policy.
3. How we use personal information
- To run the quiz, show your results, and build and tailor your plan.
- To send you emails about your plan, early access, and (when available) your subscription.
- To measure interest in OTRERA and decide whether and how to build it, mostly using aggregated or de-identified numbers.
- To improve the quiz and the website, for example by fixing confusing questions.
- To measure whether our ads work, using only generic events that never include your email, quiz answers, or health data (see Section 6).
- When subscriptions launch: to process payments, manage renewals, send required notices and reminders, and handle cancellations.
- To keep the Service secure, prevent fraud and abuse, enforce our Terms of Use, and comply with the law.
We will not use personal information for purposes that are materially different from these without telling you and, where the law requires, getting your consent.
4. How we disclose personal information
We do not sell personal information, and we have not sold any in the past 12 months. We disclose personal information only as follows:
| Recipient | What they receive | Why |
|---|---|---|
| Quiz platform (service provider) | Quiz answers, including consumer health data if you consent; email; device and usage data | To run the quiz and store your answers |
| Email service provider (service provider) | Email address and the plan details needed to personalize emails | To send our emails |
| Hosting and cloud providers (service providers) | Data stored on their systems | To host the website and store data |
| Analytics and session-recording tools (service providers), only if you accept analytics cookies | Usage, device, and connection data. Quiz answers are masked | To understand and improve the quiz and website |
| Payment processor (service provider), when subscriptions launch | Billing and payment data | To process payments and manage subscriptions |
| Meta (Facebook and Instagram), only if you accept advertising cookies | A generic page-view event, a generic sign-up ("Lead") event with no details, cookie identifiers, IP address, and browser information. Never your email, quiz answers, or health data | To measure our ads and show our ads to people who may be interested |
| Professional advisers | Only what they need | Legal, accounting, and similar advice |
| Authorities and others when legally required | Only what is required | To comply with law and protect rights and safety |
| A buyer or successor in a merger, acquisition, or sale of assets | Information needed to continue the Service | Business transfer. Any successor must honor this policy and must ask for your consent before using consumer health data in new ways |
Our service providers may use personal information only to provide services to us, under contracts that limit their use and require them to protect it.
About Meta and "sharing." Under California law, giving an advertising platform cookie identifiers and website activity for cross-context behavioral advertising can count as "sharing," even when no money changes hands. Other states treat this as "targeted advertising." If you accepted advertising cookies, we may have shared identifiers (cookie IDs and IP address) and internet activity (the generic page-view and sign-up events) with Meta in the past 12 months. We have never shared any other category, and we have never shared quiz answers or health data. You can opt out at any time (see Section 7).
California categories
In the past 12 months we collected the following categories of personal information. Sources, purposes, and recipients are described in Sections 1 through 4.
| Category | Collected? | Disclosed for a business purpose to | Sold? | Shared for cross-context behavioral advertising? |
|---|---|---|---|---|
| Identifiers (email, IP address, cookie IDs) | Yes | Service providers; Meta, only with advertising consent | No | Cookie IDs and IP address to Meta, only with advertising consent |
| Customer records under Cal. Civ. Code § 1798.80(e) (email) | Yes | Service providers | No | No |
| Characteristics of protected classifications (age range) | Yes | Service providers | No | No |
| Commercial information (interest in a plan, price page clicks) | Yes | Service providers | No | No |
| Internet or other electronic network activity | Yes | Service providers; Meta (generic events only), only with advertising consent | No | Generic events to Meta, only with advertising consent |
| Approximate geolocation (from IP address) | Yes | Service providers | No | No |
| Inferences (plan focus, preferences) | Yes | Service providers | No | No |
| Sensitive personal information (consumer health data) | Only with your consent | Service providers only | No | No, never |
| Precise geolocation, biometric, financial account, government ID, professional, or education information | No | Not applicable | Not applicable | Not applicable |
5. How long we keep personal information
- Quiz data. We keep your email and quiz answers until you ask us to delete them or until we no longer need them for the purposes above, whichever comes first. If OTRERA does not launch, we will delete all personal information collected through the quiz by March 31, 2027. If we decide to launch before then, we will email you first and give you an easy way to have your data deleted.
- Subscription records. When subscriptions launch, we keep records of your consent to automatic renewal, the terms you agreed to, and your cancellation for at least three years, or one year after your subscription ends, whichever is longer. We keep billing records as long as tax and accounting laws require.
- Backups. Deleted data is removed from backups within six months.
6. Cookies, the Meta Pixel, and Global Privacy Control
We use three kinds of cookies and similar technologies. Details are in our Cookie Policy.
- Strictly necessary: needed for the website and quiz to work, such as remembering your progress and your cookie choices. These are always on.
- Analytics: help us understand how people use the website and quiz. If we use a session-recording tool, it records clicks and scrolling with quiz answers masked. These load only if you accept analytics cookies.
- Advertising (Meta Pixel): loads only if you accept advertising cookies. It sends Meta only a generic page-view event, a generic sign-up ("Lead") event with no parameters, and standard browser data such as IP address, cookie IDs, and the page address. Our page addresses do not contain health terms. We do not use Meta's Conversions API or Advanced Matching, and we never send Meta your email, quiz answers, or health data. Meta handles this data under its own privacy policy.
You can change your choices at any time through the "Cookie Settings" link at the bottom of every page.
Global Privacy Control (GPC). If your browser sends a GPC signal, we treat it as a request to opt out of the sale and sharing of your personal information and of targeted advertising. We will not load advertising cookies or send events to Meta from that browser, even if you click Accept. If we know who you are, for example because you gave us your email, we will also apply the opt-out to your email.
Do Not Track. There is no common standard for browser "Do Not Track" signals, so we do not respond to them. We do honor GPC.
7. Your privacy rights
We give these rights to everyone in the United States, wherever you live. Residents of California, Colorado, Connecticut, Virginia, Texas, Oregon, and a growing number of other states have some or all of these rights by law.
- Know and access: learn what personal information we have about you, where it came from, why we use it, and who we have disclosed it to, and get a copy.
- Delete: have your personal information deleted.
- Correct: have inaccurate personal information fixed.
- Portability: get your data in a commonly used, machine-readable format.
- Opt out of sale, sharing, and targeted advertising: we do not sell personal information. To stop the sharing with Meta described in Section 4, use the "Your Privacy Choices" link at the bottom of every page, turn on GPC, change your cookie settings, or email us.
- Withdraw consent for consumer health data or any other processing based on consent.
- List of recipients: on request, we will tell you the specific third parties we have disclosed your personal information to.
- No significant automated decisions: we do not use your data for profiling that produces legal or similarly significant effects.
- No retaliation: we will not deny you the Service, charge you a different price, or treat you differently for using your rights.
How to make a request. Email [email protected], or use the delete link in our emails or on the quiz's final screen.
Verification. We will confirm the request comes from you, usually by asking you to confirm from the email address you used. We will ask only for what we need to verify you.
Authorized agents. Someone you authorize may make a request for you. We may ask for proof of their authority and may ask you to confirm your identity directly with us.
Timing. We respond within 45 days. If we need more time, we may extend this once by up to 45 more days, and we will tell you why.
Deletion reaches our providers. When we delete your data, we also instruct our service providers to delete it. Browser data that Meta collected through the Pixel is handled under Meta's terms, and you can manage it in your Meta account settings.
Appeals. If we deny your request, you can appeal by emailing [email protected] with the subject "Privacy Appeal." We will respond in writing within 45 days. If you are not satisfied, you may contact your state attorney general. California residents may also contact the California Privacy Protection Agency at cppa.ca.gov.
California "Shine the Light." We do not disclose personal information to third parties for their own direct marketing purposes.
Nevada residents. We do not sell covered information as defined under Nevada law.
8. Emails
When you enter your email, we send you an email right away explaining that your plan isn't ready yet and that you have not been charged. We may also email you about your plan and early access.
- Every marketing email includes an unsubscribe link, and we honor unsubscribes within 10 business days.
- Our emails identify OTRERA as the sender, use honest subject lines, and include our postal address.
- Unsubscribing stops marketing emails but does not by itself delete your data. To delete your data, use the delete link in our emails or write to [email protected].
- When subscriptions launch, we will send transactional emails, such as purchase confirmations, renewal and trial reminders, and cancellation confirmations, even if you unsubscribe from marketing emails.
9. Children
The Service is for adults 18 and older. It is not directed to children, and we do not knowingly collect personal information from anyone under 18. If we learn that someone under 18 has given us personal information, we will delete it. If you believe this has happened, email [email protected].
10. Security
We use reasonable administrative, technical, and physical safeguards to protect personal information, including access limits, encryption in transit, and contracts with our service providers. No method is completely secure. If a security breach affects your information, we will notify you as the law requires.
11. Where we process information
The Service is intended for users in the United States. Our team and service providers may process personal information in the United States, Israel, and other countries. Wherever it is processed, we protect it as this policy describes.
12. Changes to this policy
We will post any changes on this page and update the effective date. If we make a material change, especially to how we use or share consumer health data, we will email you before it takes effect and ask for your consent where the law requires.
13. Contact us
Harel Levy, doing business as OTRERA
Privacy requests: [email protected]
General questions: [email protected]