Privacy Policy

Last updated: Oct 09, 2020

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. Octiga in our respective roles as data controller and data processor; use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Website refers to Octiga, accessible from https://octiga.io
  • Service refers to Octiga's cyber security service application (the product) for which users can register an Account. This is accessible through app.octiga.io
  • Visitor means the individual who visits the main Octiga Website, or the Service website. This may include the Registered Account Holder but does not include the Tenant Users (unless they themselves act separately, as visitors, not in association with the Client or Tenant)
  • Client means the individual, company, organisation, or other legal entity, who use the Service and who connect their Tenant
  • Registered Account Owner means the entity, who may be an individual, who first registers account with the Service, who is the main point of contact for the Client and who we consider responsible to manage the Client in its interactions with the Service. Such interactions include, but are not limited to, billing.
  • You means the individual accessing or using the Website or the Service. You may refer to an  on behalf of which such individual is accessing or using the Service or Website, as applicable.
  • Tenant means the cloud service account, owned and managed by your company or organisation, which may hold data relating to your company or organisation. The tenant is generally the entity to which security service is applied
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Octiga, PorterShed, Galway.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Account means a unique account created for You (the registered account holder) to access our Service or parts of our Service.
  • Tenant User(s) means personal accounts, mailboxes and guests registered within the clients Office 365 Tenant. It may also include 3rd party guest individuals who are not directly controlled by the Client but who appear on the Tenant as guest users
  • Country refers to: Ireland
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Collecting and Using Personal Data

Types of Personal Data Collected

PERSONAL DATA

While using Our Service, We may ask You, the registered user, to provide Us with certain personally identifiable information that can be used to contact or identify You. In using the broad range or security services provided by use, our service also collects and stores data relating to users within within your organisation.

Personally identifiable information may include, but is not limited to:

  • Email address of users
  • First name and last name of users
  • Usage Data such as IP addresses
What we Do NOT collect, process or store

No information is collected stored or processed that does not relate to the continued provision of the service

We do NOT collect process or store emails, documents, or other business communications

We do NOT collect, process or store any other types of business information outside of the above categorisations

USAGE DATA

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

TRACKING TECHNOLOGIES AND COOKIES

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

We use both session and persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

  • Type: Session Cookies
  • Administered by: Us
  • Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies

  • Type: Persistent Cookies
  • Administered by: Third-Parties
  • Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.

Use of Personal Data

Personal Data of your Tenants Users

Tenant Users and third parties stored within your Tenant users may include its employees, and in some cases, other persons with whom your Office 365 tenant has connected with and hence collected personal information on. In the case of the "other persons" these may include persons such as your clients or vendors for whom you have allocated guest user roles. An example of guest user might be a person with whom you are sharing an internal document via SharePoint.

The Company may use Personal Data of users within your tenant for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service. When using our security services; all data is collected, stored and processed in accordance with the provision of the security service. More specifically the data is used to infer security risks, security incidents, and security related configurations about your tenant. Some personal information is required within this context so as to infer the persons for whom these, risks and incidents apply to. Users and third parties stored within your Tenant Users may include its employees, and in some cases, other persons with whom your Office 365 tenant has connected with and hence collected personal information on. In the case of the "other persons" these may include persons such as your clients or vendors for whom you have allocated guest user roles. An example of guest user might be a person with whom you are sharing an internal document via SharePoint. The data that we collect, which may contain personal data, is metadata about the use of your tenant and NOT business data. It can be categorised as follows

  • Event data - relating to events on your Office 365 tenant.
  • User and Mailbox Data - metadata relating to the users and mailboxes
  • Configuration Data - relating to the configuration of your tenant

The Company may share Personal Data of Tenant Users within your tenant for the following purposes:

  • For the processing and inference of risks and security incidents. In this case the data shared with the 3rd party "data processor" with the agreed sole purpose of providing us with additional security information relating to the personal information.
Personal Data of the Registered Account Owner

The company may use Personal Data of the registered account owner for the following purposes. NB We will NOT use the personal data of other Tenant Users for the following purposes

  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user. In this case the personal data used will be that of the account owner (registered owner).  We will not use the personal data of other users within your organisation for this purpose
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. In this case the personal data used will be that of the account owner (registered owner).  We will not use the personal data of other users within your organisation for this purpose
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.

We may share personal information of the registered account holder in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to help support and maintain Our Service, to contact You, to advertise on third party websites to You after You visited our Service or for payment processing.
  • For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
Personal Data of Visitors

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service providers to monitor and analyse the use of our Service.

Behavioural Remarketing

The Company uses remarketing services to advertise on third party websites to You after You visited our Service. We and Our third-party vendors use cookies to inform, optimize and serve ads based on Your past visits to our Service.

Retention of Personal Data

The Company will retain Personal Data only for as long as is necessary for the respective purposes set out in this Privacy Policy. We will retain and use the Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Personal Data

BUSINESS TRANSACTIONS

If the Company is involved in a merger, acquisition or asset sale, Personal Data may be transferred. We will provide notice before Personal Data is transferred and becomes subject to a different Privacy Policy.

LAW ENFORCEMENT

Under certain circumstances, the Company may be required to disclose Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

OTHER LEGAL REQUIREMENTS

The Company may disclose Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Personal Data

The security of Your Personal Data is important to Us in the extreme, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use the most secure commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these users.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

  • By email: info@octiga.com

If you need to contact the Data Protection Officer of Octiga you can contact them here:

  • By email: dpo@octiga.com