Privacy Policy

At OTOMcomposite we deeply respect your privacy and are committed to protecting it. The purpose of this Privacy Policy is to inform you what personally identifiable information we may collect and how it may be used. This Privacy Policy applies to this Website (otomcomposite.eu) and to our browser-based applications hosted on it: the CFD tool (otomcomposite.eu/CFD/), the SPH tool (otomcomposite.eu/SPH/) and the AFP simulation tools (otomcomposite.eu/AFP_Demo/ and related AFP pages), together referred to as the “Applications”. The data controller is OTOMcomposite, Westerstraat, 7522 DJ Enschede, the Netherlands, reachable at info@otomcomposite.eu.

WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?

• Information You Voluntarily Submit to the Website: We may collect personal information from you such as your name or email address. For example, you may voluntarily submit information to the Website by leaving a comment, subscribing to a newsletter, submitting a contact, survey or feedback form, or posting in our forum. In addition, we may ask you to create a user profile, which would allow you to create a username and password. We will store the username, but your password will not be visible in our records.

• Information We Collect from Others: We may receive information about you from other sources. For example, if you use third-party software through the site, they may transfer information to us for fulfillment.

• Automatically-Collected Information: We automatically collect certain information about you and the device with which you access the Website. For example, when you use the Website, we will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. We may also collect information about actions you take when using the Website, such as links clicked.

• Cookies: We may log information using cookies, which are small data files stored on your browser by the Website. We may use both session cookies, which expire when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the Website.

HOW YOUR INFORMATION MAY BE USED

We may use the information collected in the following ways

• To operate and maintain the Website;
• To create your account, identify you as a user of the Website, and customize the Website for your account;
• To send you promotional information, such as newsletters. Each email promotion will provide information on how to opt out of future mailings;
• To send you administrative communications, such as administrative emails, confirmation emails, technical notices, updates on policies, or security alerts;
• To respond to your comments or inquiries;
• To provide you with user support;
• To track and measure advertising on the Website;
• To process payment for purchases you make through the Website;
• To protect, investigate, and deter unauthorized or illegal activity.

THIRD-PARTY USE OF PERSONAL INFORMATION

We may share your information with third parties when you explicitly authorize us to share your information.

Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies. The Website currently uses the following third-party service providers:

• Google Analytics – this service tracks Website usage and provides information such as referring websites and user actions on the Website. Google Analytics may capture your IP address, but no other personal information is captured by Google Analytics.
• Google Firebase Authentication (Google) – handles sign-in to the Applications (see “Our web applications” below).
• Meta (Facebook Login) – used only if you choose to sign in to an Application with Facebook.
• Google AdSense – shows advertisements on the SPH tool page and may use cookies to do so (see “Advertising”).
• Google Gemini, OpenAI and Anthropic – AI providers that process the text you send to an AI assistant on the Website or in the Applications (see “AI assistants”).
• Google Fonts, YouTube and public content-delivery networks (cdnjs, jsDelivr, unpkg) – deliver fonts, embedded videos and code libraries; your browser contacts their servers directly, which reveals your IP address to them.
• Akismet and Strato (our hosting provider) – spam filtering and hosting of the Website, the Applications and their server logs.

Apart from the providers listed in this Privacy Policy, your personal information is not shared with any other third-party applications. This list may be amended from time to time at the Website’s sole discretion.

Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

OUR WEB APPLICATIONS (CFD, SPH AND AFP)

The simulations themselves run entirely in your browser on your own device. The geometry, images, settings and results you work with are not uploaded to us. The Applications process personal data only as described below.

• Sign-in: to use an Application you sign in with a Google account, a Facebook account or an e-mail address and password. Sign-in is handled by Google Firebase Authentication. We receive your name, e-mail address and a unique account identifier, and Firebase records when your account was created and when you last signed in. If you use e-mail and password, Firebase stores your password in a form we cannot read and sends you verification and password-reset e-mails. Some AFP pages use a separate log-in managed on this Website, which stores your username, e-mail address and a session cookie.
• Licence check: when an Application starts, it contacts our server to confirm that it is running on otomcomposite.eu. Like any web request, this exposes your IP address and browser type, which appear in our server logs.
• Protection against unauthorised copies: your account identifier is embedded in the running page. If a copy of an Application is opened anywhere other than otomcomposite.eu (for example a saved copy of the page), it sends us a report containing that account identifier, the address the copy was opened from, the time, your IP address and your browser type. We use these reports only to detect and stop unauthorised copying of our software.
• Feedback form: if you send feedback from inside an Application, we receive your name, e-mail address, topic and message, and use them only to respond.
• Data kept on your device: the Applications save your settings, sessions, imported models and drawings in your browser’s local storage and IndexedDB so that your work can be restored. This data stays on your device and is never sent to us; you can remove it at any time by clearing your browser’s site data.
• Camera: some Applications can optionally use your camera to capture a photo as a surface texture. This happens only after you allow it in your browser. The photo is processed on your device, is never uploaded, and the camera is switched off immediately after capture.

AI ASSISTANTS

The Website and the Applications offer optional AI assistants. When you use one, the text you type and, in the Applications, a short technical description of your current simulation set-up are sent to an AI provider (Google Gemini, OpenAI or Anthropic) to generate an answer. Do not enter personal or confidential information into an AI assistant. If you enter your own API key for a provider, the key is stored only in your browser and your messages go directly from your browser to that provider under your own agreement with them. If you choose a local model (for example Ollama or an in-browser model), your messages do not leave your device. Our AI service blocks requests from certain countries; to do this, your IP address is checked against a country database on our own server and is not shared with anyone.

LEGAL BASES FOR PROCESSING

Where the EU General Data Protection Regulation (GDPR) applies, we process personal data on the following bases: performance of a contract (providing your account and access to the Applications); our legitimate interests (keeping the Website and the Applications secure and working, preventing unauthorised copying of our software, measuring use of the Website, and answering your enquiries); your consent (newsletters, optional and advertising cookies, use of your camera, and the AI assistants), which you may withdraw at any time; and legal obligations (for example, keeping financial records).

HOW LONG WE KEEP YOUR DATA

We keep your sign-in account for as long as you use the Applications, and delete it when you ask us to or after 24 months without any sign-in. We keep reports of unauthorised copies and server logs for no longer than 12 months, unless they are needed to establish or defend a legal claim. We keep feedback and contact messages for as long as needed to deal with them, and newsletter subscriptions until you unsubscribe.

INTERNATIONAL TRANSFERS

Some of the providers named in this Privacy Policy (including Google, Meta, OpenAI and Anthropic) process data in the United States or other countries outside the European Economic Area. Where this happens, the transfer relies on the EU–U.S. Data Privacy Framework or on the European Commission’s Standard Contractual Clauses.

ANONYMOUS DATA

From time to time, we may use anonymous data, which does not identify you alone, or when combined with data from other parties. This type of anonymous data may be provided to other parties for marketing, advertising, or other uses. Examples of this anonymous data may include analytics or information collected from cookies.

PUBLICLY VISIBLE INFORMATION

If you create a user profile on the Website, post in our forum or leave a comment, certain information (such as your display name and what you post) may be publicly visible.

COOKIES

The Website uses cookies to store visitors’ preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, and customize Website content based on visitors’ browser type or other information that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics and Google AdSense, as described herein. Sign-in to the Applications uses browser storage that is strictly necessary for you to stay signed in.

Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of their internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if users deactivate the setting of cookies in their Internet browser, not all functions of our Website may be entirely usable.

ADVERTISING

Display Ads
The SPH tool page shows advertisements served by Google AdSense. Google and its partners may use cookies and similar technologies to show ads and to measure their performance, which can include ads based on your interests. You can turn off personalised ads at adssettings.google.com, and you can read how Google uses this data at policies.google.com/technologies/partner-sites. We do not share your name, e-mail address or account details with ad providers.

Retargeting Ads
From time to time, the Website may engage in remarketing efforts with third-party companies, such as Google, Meta, or Twitter, in order to market the Website. These companies use cookies to serve ads based on someone’s past visits to the Website.

Sponsored Content Tracking Pixels
This Website may engage in sponsored campaigns with various influencer networks, brands, and agencies. All sponsored content is duly disclosed in accordance with the FTC’s requirements. From time to time, these sponsored campaigns utilize tracking pixels (aka web beacons), which may contain cookies to collect data regarding usage and audience. This information is collected by the sponsoring company to track the results of the campaign. No personally identifiable information collected by the Website is used in conjunction with these tracking pixels.

Affiliate Program Participation
The Website may engage in affiliate marketing, which is done by embedding tracking links into the Website. If you click on a link for an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commissions.

Newsletters
On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows the Website to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.

RIGHTS RELATED TO YOUR PERSONAL INFORMATION

Opt-out – You may opt out of future email communications by following the unsubscribe links in our emails. You may also notify us at info@otomcomposite.eu to be removed from our mailing list.

Amend – You may contact us at info@otomcomposite.eu to amend or update your personal information.

Forget – In certain situations, you may request that we erase or forget your personal data, including your account for the Applications. To do so, please submit a request to info@otomcomposite.eu

Access, portability, restriction and objection – Where the GDPR applies, you may also ask for a copy of your personal data, ask to receive it in a portable format, ask us to restrict its use, or object to processing that is based on our legitimate interests. Where we rely on your consent, you may withdraw it at any time; this does not affect processing that took place before you withdrew it. Send any such request to info@otomcomposite.eu.

Complaints – You have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU country where you live or work, or where you believe your data was misused.

Please note that we may need to retain certain information for recordkeeping purposes, to complete transactions, or when required by law.

CHILDREN

The Website and the Applications are intended for professional and educational use and are not directed at children under 16. We do not knowingly collect personal data from children under 16.

SENSITIVE PERSONAL INFORMATION

At no time should you submit sensitive personal information to the Website. This includes your social security number, information regarding race or ethnic origin, political opinions, religious beliefs, health information, criminal background, or trade union memberships. If you elect to submit such information to us, it will be subject to this Privacy Policy.

CONTACT INFORMATION

OTOMcomposite, Westerstraat, 7522 DJ Enschede, the Netherlands. At any time, please contact us at info@otomcomposite.eu for questions related to this Privacy Policy.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. The date below shows when it was last changed.

Last updated: 7 October 2026