Privacy Notice, OTR Coaching on Telegram
Effective: 18 July 2026. Version 2.0 (supersedes v1, effective 7 May 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 the wider performer platform that supports it.
Who’s involved
| Role | Details |
|---|---|
| Data controller | NRM Enterprise Ltd t/a OTR Models (England & Wales, company number 11355190), registered office: 85 Great Portland Street, First Floor, London, W1W 7LT |
| Build, maintenance and analytics partner | N-Zyte Limited (England & Wales, company number 12128436), ICO registration ZA898463 |
| Contact for any privacy questions | info@otrmodels.co.uk |
OTR Models decides what data is collected and why. N-Zyte builds, runs and maintains the coaching platform on OTR’s behalf and performs operational analytics queries on OTR’s behalf. N-Zyte’s access is read-only and audit-trailed.
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, cohort-level analytics
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 the wider performer platform (CRM administration, performer-facing dashboard) | Art. 6(1)(b), performance of contract |
| 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.
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.
Refusing or withdrawing this consent will not affect your coaching. Your coaching relationship continues through alternative channels: WhatsApp groups, direct messages with your coach, or other channels OTR’s coaching team operates. There is no penalty for declining and no benefit withheld from those who decline.
The wider performer platform
Alongside the Telegram coaching layer, OTR Models operates a wider performer platform that includes:
- A performer-facing dashboard. A web surface where you log in to see visualisations of your stream performance, the coaching cues your assigned coaches have surfaced for you, your training-material progress, and other operational insights derived from the same data described elsewhere in this notice. The data shown is your own data; OTR processes it on the lawful bases set out in the table above.
- CRM systems operated by OTR Models to administer your profile, contact details, financial information (including payout details) and any other personal data captured under your Agency Agreement. Identity-verification documents (passport, driving licence, verification photo) are not held in OTR Models’ CRM; those are processed by the streaming platform during your age-verification step.
Specific feature releases and any new third-party tools used for the dashboard or CRM (for example, a specific CRM platform vendor, a dashboard hosting service, a payment processor integration) will be:
- Added to the Service providers table below as they go live, and
- Notified to you via your Telegram supergroup and via email under the change-notification mechanism in the Agency Agreement,
before any new tool starts processing your data.
Service providers
OTR Models contracts directly with the following service providers in connection with the coaching platform. N-Zyte does not engage any sub-processors of its own for this engagement. Additional service providers may be added for the wider performer platform; the table below will be updated as they go live.
| Provider | Purpose | Country | Data-protection arrangement |
|---|---|---|---|
| Telegram FZ-LLC | Messaging infrastructure | UAE / global | No customer DPA available from provider; risk accepted by OTR Models |
| Anthropic, PBC | AI cue extraction (Claude) | United States | DPA in place, SCCs Module 2 plus UK IDTA |
| Deepgram, Inc. | Voice transcription | United States | DPA in place, SCCs Module 2 plus UK IDTA |
| Hostinger International Ltd. | Platform hosting | European Union | DPA in place |
| Doppler, Inc. | Secrets management | United States | DPA in place, SCCs Module 2 plus UK IDTA |
| Google Cloud (BigQuery) | Data warehouse: operational analytics and the synced copy of coaching-channel messages used for AI cue extraction and analytics | European Union | GCP DPA in place |
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. EU-region providers (Hostinger, Google Cloud BigQuery) do not require additional transfer safeguards.
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 |
| Audit logs | 12 months |
Automated decision-making
OTR Models does not use automated decision-making that produces legal effects concerning you or that similarly significantly affects you. The AI processing described above surfaces coaching cues and summaries for your coaches; decisions about your coaching, profile, or registration are taken by OTR Models’ staff.
What N-Zyte does
N-Zyte performs operational analytics queries on OTR Models’ BigQuery data warehouse on OTR Models’ written instruction, for the purpose of improving the coaching service. Access is read-only and audit-trailed: every query is logged, and N-Zyte does not send messages, take actions, or make decisions about individual performers.
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 (extendable by a further two months in complex cases, in accordance with Article 12(3) UK GDPR; we will tell you if that applies).
Withdrawing consent
If you have given consent under this notice (for example, the wellness and availability consent described above, or the international-transfer consent in the Agency Agreement), you can withdraw it at any time:
- How: email info@otrmodels.co.uk saying which consent you’re withdrawing.
- When it takes effect: within 7 days for the wellness consent; within 14 days for the international-transfer consent.
- Effect on you: withdrawal does not affect the lawfulness of any processing carried out before withdrawal. Withdrawing the wellness consent means OTR will not process special-category information you share in the channel, but does not affect your coaching relationship, which continues through alternative channels (WhatsApp, DM). Withdrawing the international-transfer consent means certain features of the coaching platform (AI cue extraction, voice transcription) can no longer be applied to your data; OTR will continue to provide coaching through alternative channels.
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 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 or N-Zyte 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. We would appreciate the chance to put things right first if you contact info@otrmodels.co.uk.
Issued by N-Zyte Limited on behalf of NRM Enterprise Ltd t/a OTR Models.
Last updated: 18 July 2026