Privacy Notice, OTR Coaching, Backstage and OTR Protect
Effective: 28 October 2026. Version 3.1 (supersedes v3.0, effective 8 October 2026).
This notice supplements OTR Models’ main privacy policy at otrmodels.co.uk/privacy-policy/, which covers OTR’s general processing of your data (application, age verification, identification, financial information). This notice covers the specific processing carried out via the Telegram coaching platform and Backstage, OTR’s performer platform.
Who’s involved
| Role | Details |
|---|---|
| Data controller | NRM Enterprise Ltd t/a OTR Models (England & Wales, company number 11355190), registered office: C/O Layers Accountancy, Parker Court, Knapp Lane, Cheltenham, GL50 3QJ |
| Contact for any privacy questions | info@otrmodels.co.uk |
OTR Models decides what data is collected and why. Our UK technology partner builds and maintains the coaching platform and Backstage, and runs analytics for us, under contract and only on our instructions.
Data collected
- Messages: text, transcribed voice notes, images, files, reactions
- Telegram identifiers: phone number, username, user ID, display name
- Group membership records
- Derived data: coaching cues, response status, AI summaries, AI-assisted coaching profiles, cohort-level analytics
- Room-check videos: short recordings of your public free chat, only where you have given your recording consent
- OTR Protect, only if you opt in: your cam name; two reference photos (face and full body) and the facial template made from them; details of your content found online (the link, plus a screenshot as proof when content is removed from a site)
- Backstage account: your email address, your password (stored scrambled), sign-in security records, which can include your IP address, and a record of which Backstage summary you have seen and when; and a record of how you use Backstage: when you sign in, which pages you open and the minutes you are active in the app
- Your performer record (CRM): legal name, working name, contact email and phone, postal address, date of birth, bank details, your status with OTR, and the link to your Telegram coaching chat
- Streaming, pay and audience data from Streamate (SM): your streams, hours, minute-by-minute stream detail, take-home pay, tips, favourites and audience counts
- Your Backstage stream notes
You need to give us your contact, identity and bank details so you can work with OTR and be paid. Everything this notice describes as optional (OTR Protect, room-check recordings, the wellness consent and stream notes) is up to you.
Purposes and lawful basis
| Purpose | UK GDPR basis |
|---|---|
| Coaching delivery, tracking, and multi-coach operational visibility | Art. 6(1)(b), performance of contract |
| Aggregated coaching analytics (cohort-level performance trends, service-improvement work) | Art. 6(1)(f), legitimate interest |
| Wellness and availability information you choose to share in the channel (e.g. “feeling unwell, can’t stream today”) | Art. 9(2)(a), explicit consent (see below) |
| Operating Backstage: your performer record (CRM), performance pages, reports, stream notes, and sign-in security | Art. 6(1)(b), performance of contract |
| Backstage app usage: seeing how you use Backstage so your coaching team can support you and keep you on track, and improving Backstage | Art. 6(1)(f), legitimate interest (you can object, see “How you use Backstage”) |
| Room checks: viewing your public free chat to give coaching feedback | Art. 6(1)(b), performance of contract |
| Room-check recording (a short video of your public free chat, reviewed with you) | Art. 6(1)(a) consent and Art. 9(2)(a), explicit consent, given through the separate room-check consent message |
| OTR Protect: finding and removing leaked or stolen content of you, by scanning for your performer name and face matching from two reference photos | Art. 6(1)(a) consent and Art. 9(2)(a) explicit consent (your photos and facial template are biometric data), given by tapping “I’m in, cover me” in your OTR Telegram chat |
| AI-assisted coaching profiles to help your coaching team support you | Art. 6(1)(b), performance of contract (derived from your consented coaching chats) |
| Internal audit and record-keeping | Art. 6(1)(c), legal obligation; Art. 6(1)(f), legitimate interest |
The coaching channels are for work-related communication. Other special-category data (detailed medical conditions, religion, politics, immigration status, sex life, racial or ethnic background) should not be shared in the channel or in your Backstage stream notes. The one exception is OTR Protect: if you opt in, you send your two reference photos in your 1:1 OTR Telegram chat (see the OTR Protect section).
Wellness and availability information
Coaching naturally involves a bit of context: “I’m feeling under the weather”, “back from holiday Monday”, “I’m not streaming today”. That kind of message is treated as special-category data under UK GDPR because health information is involved.
We process that information on the basis of your explicit consent, given by ticking the wellness and availability consent box when you accept the Agency Agreement (Clause 5A.2).
You can withdraw this consent at any time by emailing info@otrmodels.co.uk. Withdrawal takes effect within 7 days and does not affect the lawfulness of any processing carried out before withdrawal.
Saying no, or withdrawing later, doesn’t affect your coaching.
Room checks and recordings
As part of coaching, a member of the OTR coaching team may join your public free-chat stream without telling you in advance, the way a customer would, watch for a few minutes, and give you feedback afterwards. This covers your public free chat only, never paid or private rooms, and is part of the coaching service under your Agency Agreement.
Separately, and only if you have given your explicit opt-in consent through the room-check consent message in your Telegram coaching chat, a room check may be recorded as a short screen video so your coach can go through it with you. If you have not consented, checks still happen but nothing is recorded.
Where a video is made: it never includes nudity (the checker leaves immediately and records none of it); it is seen only by you and the OTR coaching team and stored in a single access-restricted location; we aim to review it with you within 5 days; and it is permanently deleted no later than 7 days after recording, reviewed or not. You can withdraw your recording consent at any time through your coaching chat or by emailing info@otrmodels.co.uk; withdrawing changes nothing about your coaching.
OTR Protect, leak protection
What it is. OTR Protect is our optional leak-protection service. Its only purpose is to find leaked or stolen content of you online and get it removed. If you opt in, your performer name is searched for every day, and face matching, using two photos you give us, helps recognise you in content that has been cropped, renamed or re-uploaded. Takedown requests are sent to the sites where your content is posted, and where a site will not take it down, it is cleared from search engine results instead.
What we collect. If you opt in: your performer name (your cam name); two reference photos you send us, one of your face and one full body; a facial template (a digital fingerprint of your face) that the provider’s system makes from your photos and uses for the matching; and details of your content found online, meaning the link, plus a screenshot as proof when content is removed from a site. The details of found content come from publicly available websites. Your photos are only ever linked to your cam name. We never share your real name, contact details or documents.
Your photos are biometric data. Because your photos and facial template are used for facial recognition, they are biometric data, a special category of personal data under UK GDPR. They are used for one purpose only, finding your leaked or stolen content, and for nothing else. They are never posted or made public, never shared beyond the provider and the hosting and infrastructure providers that run its systems, and never included in any takedown notice or public record. They are stored encrypted, with access limited to the staff who need it to run the service.
Legal basis. Your explicit consent, given when you tap “I’m in, cover me” in your 1:1 OTR Telegram chat. This one consent covers both the name scanning and the face matching. OTR Protect is optional: choosing not to join changes nothing about your coaching or your standing with OTR.
Who receives it. A specialist content-protection provider based in Barbados, which runs the scanning, face matching and takedowns for us; the provider’s hosting and infrastructure providers, including in the United States, where your photos and facial template are stored; websites and search engines that receive takedown and delisting notices, which name your cam name and the content concerned but never include your photos or your real name; and the Lumen public archive (see below).
On our side. Your photos pass through your 1:1 OTR Telegram chat and a secure, access-restricted OTR storage area only so we can hand them to the provider. We delete our copies once the provider confirms it has received them.
Public takedown records. Takedown and delisting requests are formal legal notices. When one is sent to certain recipients, including Google, the recipient publishes it in the Lumen database, a public archive of legal notices. The published record shows the cam name the request was filed for, your official profile, and details of the content being taken down. It never shows your real name or your photos, and the request is made in the provider’s name, not yours. This publication is done by the recipient, is permanent, and is outside our control and the provider’s. These records remain public even if you later opt out.
Opting out. You can opt out at any time by messaging your coach or emailing info@otrmodels.co.uk, and nothing changes for you. Your photos and facial template are then deleted within 7 days. How long everything else is kept is in the Retention table below.
AI-assisted coaching profiles
To help your coaching team know you better, an AI tool builds a short internal profile from your consented coaching chats (things like how you prefer to communicate and what kind of support works best for you). It is visible only to the OTR coaching team, uses your performer name only, is always marked as an AI draft until your coach confirms it, and is deleted when you leave OTR. This runs on the same basis as your coaching chats; withdrawing from the coaching platform removes the profile too.
Coaching and mentoring calls
Some 1:1 coaching or mentoring sessions run on Zoom with AI-generated notes switched on, so you get a summary of your call sent to you afterwards. We tell you in the meeting details when your call is booked, and Zoom shows its recording notice when you join. If you would rather your calls were not recorded or summarised, just tell your coach or email info@otrmodels.co.uk and it is switched off for your calls, with no change to your coaching. We do this because it’s in our legitimate interests to give you an accurate record of your call. Recordings and summaries are seen only by you and your coaching team, and are not kept longer than needed to produce and share your notes.
Backstage, your performer platform
What it is. Backstage is OTR’s website for performers, at backstage.otrmodels.co.uk. You sign in to see your hours, streams, take-home pay, audience numbers, milestones and weekly report. The OTR team uses the same system to run your performer record (the CRM).
Where the information comes from. Your streaming, pay and audience figures come from Streamate (SM) through OTR’s data warehouse. Your name, contact details, address, date of birth and bank details come from you when you join and are entered by the OTR team. The link to your Telegram coaching chat comes from our Telegram coaching platform. Your stream notes come from you.
Customers and viewers. Your audience is shown as counts and percentages, and your top supporters by rank only. Customers’ names, usernames and account details are never shown in Backstage.
Your stream notes. Adding notes about your streams is optional, and you can change them at any time. The OTR coaching team reads them to coach you. Please keep them to what you tried in that stream, like an outfit or a type of show, and leave out what happened in private shows, explicit content and health details. If something like that ends up in a note, tell us and we will remove it.
How you use Backstage. We record when you sign in, which pages you open and how many minutes you are active in the app. A minute only counts while Backstage is on your screen and you have used it in the last two minutes, so leaving it open doesn’t count. We don’t record what you type or anything you do outside Backstage. Your coaching team uses this to see what helps you, to check in when you haven’t been on for a while, and to see where they can support you. OTR management uses the overall picture to see how Backstage is being used and to improve it. We do this because it is in our legitimate interests to coach and support you, which is what you join OTR for. You can object at any time by emailing info@otrmodels.co.uk, and we will stop recording your usage unless we have a strong reason to continue, which we would explain to you.
Who can see it. You see only your own information. The OTR coaching team can see your Backstage pages, including your stream notes. Only OTR management can see your bank details, which are stored encrypted, and every view of them is logged. Our technology partner can access Backstage to maintain it, on our instructions.
The Backstage summary. The first time you sign in, and after any important change, Backstage shows you a short summary of this notice. Tapping “Got it, take me in” records which version you saw and when. This is not consent: we use your information to run Backstage because it is part of the service in your Agency Agreement. If you sign out instead, nothing else changes: your record, your payments and your Telegram coaching carry on as normal.
Service providers
We use the following service providers for the coaching platform, Backstage and OTR Protect. You can ask us for more information about any provider at info@otrmodels.co.uk.
| Provider | Purpose | Country | Data-protection arrangement |
|---|---|---|---|
| Telegram FZ-LLC | Messaging infrastructure | UAE / global | No customer DPA available from provider; risk accepted by OTR Models |
| AI provider | AI summaries, coaching cues and draft coaching profiles | United States | DPA in place, SCCs plus UK Addendum |
| Voice transcription provider | Turning voice notes into text | United States | DPA in place, SCCs plus UK Addendum |
| Hosting provider | Hosting the coaching platform and Backstage | United Kingdom and European Union | DPA in place |
| Security provider | Storing the passwords and keys our systems use | United States | DPA in place, SCCs plus UK Addendum |
| Cloud data warehouse provider | Our data warehouse (coaching messages, analytics and the data shown in Backstage) and encryption keys | European Union; one scheduled-processing server temporarily in the United States | DPA in place, SCCs plus UK Addendum |
| Office software provider | Documents, spreadsheets, email and file storage, including the OTR Protect photo handover | Global, including the United States | DPA in place, SCCs plus UK Addendum |
| Database and sign-in provider | Backstage, and our internal coaching tools | United Kingdom (London); Backstage test copy in France | DPA in place, SCCs plus UK Addendum |
| Email delivery provider | Backstage sign-in emails | European Union (Ireland) | DPA in place, SCCs plus UK Addendum |
| Error monitoring provider | Spotting technical errors in Backstage | European Union (Germany) | DPA in place, SCCs plus UK Addendum |
| Server management provider | Managing the Backstage server | United States | DPA in place, SCCs plus UK Addendum |
| Zoom Communications, Inc. | Coaching and mentoring calls, recordings and AI-generated call notes | United States | DPA in place, SCCs plus UK Addendum |
| Website security and hosting provider | Secure sign-in to, and hosting of, our internal coaching tools | Global network, including the United States | DPA in place, SCCs plus UK Addendum |
| Content-protection provider | Leak scanning, face matching, takedown and search-engine delisting for OTR Protect, engaged only for performers who opt in | Barbados (data stored with its hosting and infrastructure providers, including in the United States) | DPA in place, SCCs plus UK Addendum |
International transfers
Transfers to the United States rely on the EU Standard Contractual Clauses (Module 2: Controller-to-Processor) as supplemented by the UK International Data Transfer Addendum issued by the Information Commissioner. Providers that store your data in the UK or EU do not need extra safeguards.
If you join OTR Protect, your cam name, photos and facial template go to the content-protection provider in Barbados and are stored by its hosting providers, including in the United States. This is protected by the EU Standard Contractual Clauses with the UK International Data Transfer Addendum, and you can ask us for a copy.
Retention
| Data | Period |
|---|---|
| Raw messages | 12 months |
| Voice files | Deleted after successful transcription |
| Derived coaching data (cues, summaries, response status) | Engagement duration plus 6 months |
| Telegram identifiers | Engagement duration plus 6 months |
| Cohort-level analytics (aggregated, pseudonymised) | Engagement duration plus 6 months |
| Room-check videos | Deleted within 7 days of recording, maximum, reviewed or not |
| AI-assisted coaching profiles | Deleted when you leave OTR |
| OTR Protect: your performer name at the content-protection provider | Duration of your enrolment; on opt-out the name is removed from the service, except legal-notice records already sent (see the OTR Protect section) |
| OTR Protect: your photos and facial template at the provider | While you are enrolled. Permanently deleted within 7 days of you opting out, withdrawing consent or leaving OTR, confirmed to us in writing; any backup copies cleared within 30 days |
| OTR Protect: our copies of your photos (your Telegram chat and our handover storage) | Deleted once the provider confirms it has received them |
| OTR Protect: links and screenshots of content found for you | Deleted when you opt out |
| OTR Protect: takedown notice records at the provider | Kept permanently by the provider as a record of the legal notices it has sent (cam name and content details, never photos). Copies published in the Lumen archive are permanent and outside our and the provider’s control |
| OTR Protect: record of your choice (your tap in Telegram) | While you are enrolled plus 6 years |
| Backstage: stream figures and minute-by-minute stream detail | Rolling 90 days, copied from our data warehouse |
| Backstage: your account and stream notes | While you are with OTR plus 6 months |
| Backstage: sign-in security records | 12 months |
| Backstage: app usage (sign-ins, pages opened, minutes active) | 12 months, then deleted |
| Backstage: record of which summary you have seen | While you are with OTR plus 6 years |
| Performer record (CRM) | While you are with OTR plus 6 years |
| Streaming, pay and audience data from Streamate (our data warehouse) | While you are with OTR plus 6 years, then deleted or anonymised |
| Bank details | 3 months after your final payment |
| Audit logs (who accessed or changed data) | Kept indefinitely as a security and accountability record |
Automated decision-making
Nothing in our coaching, Backstage or OTR Protect makes decisions about you automatically. AI tools only help your coaches; people make the decisions.
Your rights
You have the following rights under UK GDPR:
- Access, request a copy of the personal data we hold about you (Art. 15)
- Rectification, correct inaccurate data (Art. 16)
- Erasure, request deletion (Art. 17)
- Restriction, limit how we process your data (Art. 18)
- Portability, receive your data in a machine-readable format (Art. 20)
- Object, object to processing based on legitimate interest (Art. 21)
- Withdraw consent, withdraw any consent you have given (Art. 7(3))
To exercise these rights, email info@otrmodels.co.uk. OTR Models will respond within 30 days of receiving your request (or up to two months longer for complex requests; we’ll tell you if so).
Withdrawing consent
If you have given consent under this notice or the Agency Agreement, you can withdraw it at any time:
- How: message your coaching chat, or email info@otrmodels.co.uk, saying which consent you’re withdrawing.
- When it takes effect: within 7 days for the wellness and room-check recording consents (no new recordings from the moment we see it); within 14 days for the international-transfer consent; for OTR Protect, your photos and facial template are deleted within 7 days.
- Effect on you: withdrawing doesn’t affect anything we did before, and doesn’t affect your coaching. Without the international-transfer consent, AI cue extraction and voice transcription stop for your data. OTR Protect records already published in the Lumen archive stay public.
Changes
Material changes to service providers, retention, purposes, or lawful basis will be:
- Published as a revised version of this notice at policies.otrmodels.co.uk/privacy/, and
- Re-pinned in your Telegram coaching supergroup, and
- For changes that affect Backstage, shown to you the next time you sign in to Backstage, and
- For changes that require fresh consent or fresh acceptance, notified to you by email under the Agency Agreement variation process (Clause 18.1).
Complaints
If you are not happy with how OTR Models has handled your personal data, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk. If you can, contact us at info@otrmodels.co.uk first so we can try to put it right.
Issued by NRM Enterprise Ltd t/a OTR Models.
Last updated: 28 October 2026