Effective date: 14th June 2022
We, Octon Inc. (“Octon,” “we,” “us,” or “our”), will collect information related to individuals (“Personal Data”) in providing our Concio communication app (“Concio”App) and all products, apps, services platform (“Concio Platform”) and websites related to the Concio App (collectively, the “Services”) to individuals granted access to a Concio Platform (“Authorized Users”). We consider the protection of Personal Data to be one of the most important management issues as a responsibility of an communication service company. We will act in compliance with the laws and regulations applicable in countries and regions where we are conducting business (such laws and regulations are hereinafter collectively referred to as the “Applicable Laws”), and will make efforts to properly protect Personal Data based on this Privacy Policy (this “Policy”).
This Policy describes how Orion collects, uses and discloses information and what choices do you have with respect to the information.
Applicability of this Privacy Policy
This Policy does not apply to any third-party applications or software that integrates with the Services through the Concio Platform (“Third-Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The organization (e.g. your employer, or another entity or person) that enters into the Customer Agreement (the “Customer”) controls its instance of the Concio Platform and any associated Customer Data.
Applicable scope of this Policy
This Policy applies to all Personal Data that is collected in relation to our Services regardless of the country or region where our Services are being used.
Target services and service provider
This Policy applies to all Personal Data that is collected in relation to our Services.
We may apply individual privacy policies or additional provisions to terms of use or this Policy (collectively, “Individual Policies”) to specific services. The Individual Policies explain what kind of Personal Data we will collect, and how we will use and share such Personal Data, for such specific services, and the other policies that are applicable to such specific services. If there is any inconsistency between the subject matter of the Individual Policies and this Policy, the Individual Policies shall prevail.
In connection with the application of this Policy, Customer is the controller of the processing of Personal Data.
Applicable countries and regions
We will process Personal Data only to the extent permitted under the Applicable Laws according to this Policy and only within the scope described in this Policy.
While we may provide various translations of this Policy as a reference, to the extent permitted under Applicable Laws, the Traditional Chinese version applies to users using our Services in Taiwan, the Simplify Chinese version applies to users using our Services in China, the Japanese version applies to users using our Services in Japan, and the English version applies to users using our Services in other countries or regions.
Personal and Customer Data to be collected
We will collect the following Personal Data:
Information that you provide to Concio Platform such as your phone number that you register at the time of creating an account, and profile information that you set at the time of using our Services.
Information related to your status of use of our Services such as the text, image, video and other contents that you post, and your access log.
Information related to you which is posted by other users such as an image of your face photo provided by your employer during or after creation of Concio account in Customer's Concio Platform.
Personal Data to be provided by you
Profile information
Profile information includes information such as the icon image, display name, status message, gender, department, address and personal photo that you set or disclose in order to connect to other users. Profile information will be disclosed and made available to other users and third parties such as companies operating an Concio Platform. A unique identification number (“Star Number”) is an identification number set in your Account to make it easier for your friends or other Concio users to find you in our Services, and your friends can find you through your Star Number.
Address book
We offer an “Auto Import” feature which automatically adds contacts of your contacts in your address book on your device. We will access only the phone numbers registered in your mobile device's address book only when you wish to establish audio communication through Concio Platform (if enabled).
Customer Data to be collected in connection with your use of our Services
Status of use of our Services
Concio Platform automatically collects information related to when and how you used our Services. The collected information includes the status of use of various features such as the date and time that you activated our individual apps, length of time that you used our individual services, results of searches conducted in the apps.
Account Information
To create or update a Concio account, we or our Customer (e.g. your employer) create and provide Concio Platform with display name, an email address, phone number, department, gender, password, domain and/or similar account details.
Posts and reactions to posts
In distributing your posts to other users, the contents that you posted are sent via our Concio Platform or Customer's Concio Platform.
For example, standard contents such as emoji, stickers and location information and non-standard contents such as text, image, video and audio that you post are all sent via Concio Platform. In addition, external information such as the recipient of the contents, data format, date and time of the posting, and other information on how you are interacting with your counterparty is also recorded in the Concio Platform.
Furthermore, in distributing reactions or replies to the posts of other users, we collect and use information related to how you reacted to the posts of other users. This information includes the action that you took against the distribution by other users, and the time and date of such action, such as whether you viewed the text, image or video of messages that you received, and whether you replied to the post. In principle, we will not use private posts, as such messages exchanged between users, for any purpose other than distributing such posts.
Log data
As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
Device information
Concio collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
Location information
We may collect the location information of your device when you share your location information with your friends, or in order for us to provide optimized search results to you. When you do not accept sending your location information by your mobile device settings, location information will not be sent to us.
Cookie information
Small amount of data generated by a website and saved by your web browser. It is used to identify your browser, provide analytics, remember information about you such as your language preference or login information.
Apps, browsers, devices and network information
We will collect information related to the device, browser and the app that you are using (identifier for identifying the device/browser, Cookie ID and device type, OS, language/time zone setting, browser type, app version, etc.), and network information (telecommunications carrier's name, IP address, etc.).
Services metadata
When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way that Authorized Users work. For example, Concio logs the Concio Platform, communication group, people, features, content and links that you view or interact with, the types of files shared and what Third-Party Services are used (if any).
Customer Data uploaded by other users
There may be cases where a certain user, in using our Services, uploads information containing Personal Data such as a photo that includes a third party other than that user, and we collect such information.
Customer Data that is collected from third-party services integration
When our Customer provides Concio Platform services operated by a third party such as when our Customer uses our Services to collect and analysis Personal Data through integration with third-party services with our Services, we request our Customer to take lawful and proper measures.
How we use information
Personal Data will be used by Concio in accordance with the Customer's instructions, including any applicable terms in the Customer Agreement and the Customer's use of Services functionality, and as required by applicable law. Concio Platform is a Processor of Customer Data and the Customer is the Controller. The Customer may, for example, use the Services to grant and remove access to a Concio Platform, assign roles and configure settings, access, modify, export, share and remove Personal Data and otherwise apply its policies to the Services.
To provide, update, maintain and protect our Services, Websites and business. This includes use of Concio Platform to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User's request.
As required by applicable law, legal process or regulation.
To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
To develop and provide search, learning and productivity tools and additional features. Concio tries to make the Services as useful as possible for specific Concio Platforms and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services or Third-Party Service suggestions based on historical use and predictive models, or identify organizational trends and insights to customize a Services experience or create new productivity features and products.
To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. If you have additional questions about a message that you have received from Concio, please get in touch through the contact mechanisms described below.
To investigate and help prevent security issues and abuse.
If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, Concio may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as Personal Data under applicable data protection law, it is referred to in this Policy.
Data retention
Concio will retain Customer Data in accordance with a Customer's instructions, including any applicable terms in the Customer Agreement and Customer's use of Services functionality, and as required by applicable law. Depending on the Services subscription, the Customer may be able to customize its retention settings and apply those customized settings at the Concio Platform. The Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or de-identification of certain associated Information. Concio may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Concio to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
How we share and disclose information
This section describes how Concio may share and disclose Information, as described in the section entitled “Information we collect and receive” above. Customers determine their own policies and practices for the sharing and disclosure of Information. Concio does not control how they or any other third parties choose to share or disclose Information.
The Customer's instructions. Concio may share and disclose Information in accordance with a Customer's instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer's use of Services functionality and in compliance with applicable law and legal process. Some sharing at a Customer's request may incur additional fees.
Displaying the Services. When an Authorized User submits Information, it may be displayed to other Authorized Users in the same or connected Concio Platform. For example, an Authorized User's email address may be displayed with their Concio Platform profile.
Collaborating with others. The Services provide different ways for Authorized Users working in independent Concio Platforms to collaborate, such as Concio Connect or email interoperability. Information, such as an Authorized User's profile Information, may be shared, subject to the policies and practices of the other Concio Platform(s).
Customer access. Owners, administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to Information. This may include, for example, your employer using Service features to export logs of Concio Platform activity, or accessing or modifying your profile details.
Third-Party Service Providers and Partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with Third-Party Service providers to support our common customers.
Third-Party Services. Customer may enable or permit Authorized Users to enable Third-Party Services. We require each Third-Party Service to disclose all permissions for information access in the Services, but we do not guarantee that they do so. When enabled, Concio may share Information with Third-Party Services. Third-Party Services that are not owned or controlled by Octon and third parties that have been granted access to Information may have their own policies and practices for its collection, use and sharing. Please check the permissions, privacy settings and notices for these Third-Party Services, or contact the provider if you have any questions.
Forums. The information that you choose to provide in a community forum, including personal data, will be publicly available.
Corporate affiliates. Concio may share Information with its corporate affiliates, parents and/or subsidiaries.
During a change to Concio's business. If Octon engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Octon's assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or deidentified Data. We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research
To comply with laws. If we receive a request for information, we may disclose Information if we reasonably believe that disclosure is in accordance with or required by any applicable law, regulation or legal process, If Concio responds to requests to disclose data from government agencies, law enforcement entities and other sources.
To enforce our rights, prevent fraud and for safety. To protect and defend the rights, property or safety of Octon, its users or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud or security issues, including to prevent death or imminent bodily harm.
With consent. Octon may share Information with third parties when we have consent to do so. For Concio Platforms registered and operated by corporate entities, Octon may share Information with consent of the Concio Platform owner or authorized corporate officer. For account created without a formal affiliation, Concio may require user consent.
Security
Octon takes security of data very seriously. Octon works hard to protect Information that you provide from loss, misuse and unauthorized access or disclosure. These steps take into account the sensitivity of the Information that we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Octon cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site, and we don’t control or endorse what is on third-party sites.
Changes to this Privacy Policy
Octon may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Octon will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.
International data transfers
Octon may transfer your Personal Data to countries other than the one in which you live. To the extent that Personal Data is transferred abroad, Octon will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with Octon's obligations.
Identifying the Data Controller and Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Customer is the controller of Customer Data. In general, Concio is the processor of Customer Data and the controller of Other Information. Different Concio Platform entities provide the Services in different parts of the world. Customer who purchase and provide services of Orion Platform is the controller of Personal Data and a processor of Customer Data relating to Authorized Users who use Concio Platforms established by Customers.
Your rights
Individuals across the globe, including the European Economic Area, the United Kingdom and Brazil, have certain statutory rights in relation to their Personal Data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Customer who controls your Concio Platform for additional access and assistance.
To the extent that Octon's processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws covering the processing of Personal Data such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), Concio relies on its legitimate interests, described above, to process your data. Octon may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Octon's use of your Personal Data for this purpose at any time.
Contact Us
Please also feel free to contact Octon if you have any questions about this Privacy Policy or Octon's practices or if you are seeking to exercise any of your statutory rights. Octon will respond within a reasonable timeframe. You can contact us at info@octon.net or at our postal address below:
114, Taipei City, Neihu District, Lane 146, Xinhuer Rd, No. 19, 4th Floor
