Privacy - Octado

Last Updated: December 26, 2023

This document describes how Octado deal with personal information information that we collect from users of our website at www.octado.app and our mobile app (collectively, the “Service”).

Personal Information We Collect

We collect personal data from you to be able to use some of the premium services:

Information: We collect info such as your email, password, and telephone number. When you decide to activate the paid features, we collect the transaction ID to link it to your account.

We also collect device information automatically such as device make and model, app version installed, IP address. We also collect info about the usage behavior, such as, but not limited to, clicks heat maps, used features, and session durations.

Content: We collect media such as photos, live photos, videos, files, their analytics and other content.

The collected information is used in efforts to provide you with a better service.

We only use the collected information for the stated purposes. The information we collect is not shared with 3rd party entities unless authorized by you. This is with regard to “Compliance & Safety” section.

Affiliates & Services Providers

We reserve the right to share the information you collected with our subsidiaries, joint ventures, or sister companies and they will comply with our privacy policy.

We authorize service providers such as email delivery, hosting, mobile app analytics, payment aggregating to provide you with a comprehensive service. We will take the appropriate action, if we know that they use the information in a manner that violates this Privacy Policy.

Target Audience

The app is intended for audience over the age of 16.

Compliance & Safety

We reserve the right to use and/or disclose the information you provided as we see fit to investigate to make sure you do not violate our policies or the law. It can be used to comply with laws & legal processes.

Account Deletion

At any time, you can contact us to permanently delete your account. This is with accordance to “Compliance & Safety” section.

Data Security

The app architecture is designed in a way to protect your privacy and prevent unauthorized access. However, security risk is always a factor when it comes to digital infrastructure. Contact us immediately, if you believe our security measures are compromised.

We reserve the right to update this Privacy Policy at any time. You will be notified when the Privacy Policy is updated. Continuing to use the Service implies that you agree to the new Privacy Policy. If you do not, you may contact us to deactivate your account.

EU Users

Personal information

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller

Octado is the controller of your personal information and can be reached using the contact details in the Contact Us section above.

Legal bases for processing

Your country only allows us to use your personal information on certain “legal bases”. We generally rely on the following legal bases:

*Processing purpose*	*Legal basis*
To provide the Service	You have entered a contract with us and we need to use your personal information to provide services you have requested or take steps that you request prior to providing services. If you do not provide information indicated as required or mandatory within the Service, or that is otherwise necessary to provide a requested service or feature within the Service, it will not be available to you.
For research and development To send you marketing communications To create anonymous data For security, compliance, fraud prevention and safety	These processing activities constitute our legitimate interests. When we rely on our legitimate interests to process your personal data, we consider and balance potential impact on you and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where the impact on you overrides our interests (unless we have your consent or are otherwise required or permitted to by law).
For compliance with law; legal claims Sharing your personal information as described in this Privacy Policy	Processing is necessary to comply with our legal obligations or the activities constitute our legitimate interests.
With your consent	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated at the time consent is requested.

Note that different legal bases may apply to the same personal information when processed for different purposes. For example, we may rely on consent where required by law or your mobile operating system to access photos on user’s device, but we may rely on performance of a contract when we store or use the photos to provide the Service, or on legitimate interests if we had to review it to investigate a complaint that the photo contained content that violated our Terms of Service.

Data export

If we transfer your personal information out of the European Economic Area in a manner that requires us to apply additional safeguards to your personal information under European data protection legislation, we will do so. Please contact us for information on any such transfers or the safeguards applied.

Retention

We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including to satisfy legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights

You may ask us to take the following actions:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.

Correct. Update or correct inaccuracies in your personal information.

Delete. Delete your personal information.

Export. Export a machine-readable copy of your personal information that you can use with a different service.

Restrict. Restrict the processing of your personal information.

Object. Object to our reliance on our legitimate interests as the legal basis of processing your personal information if that processing adversely impacts your legal rights.

To request one of these actions, contact us using the details in the Contact Us section below. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, please contact us. In addition, you may submit a complaint to the data protection regulator in your jurisdiction.

You can contact us at: [email protected]