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Privacy Policy

Octus Privacy Notice

Effective Date: October 29, 2024

Octus Intelligence, Inc. and its subsidiaries (collectively, “Octus, “we,” “our” or “us”) are committed to protecting your privacy and complying with applicable data protection and privacy laws. This privacy notice applies to https://octus.com, https://aggredium.com and https://www.findox.com, and any Octus applications available through mobile and other online channels (the “Platform”), your interactions with the services available through the Platform (the “Services”), emails you receive in connection with the Services, and any information collected from you by us on the Platform or via the Services.

Contact information

Please contact us with any questions, comments or requests regarding this Privacy Notice using the following details:

Contact: Legal and Compliance Department

Address: Octus Intelligence, Inc.
11 E 26th St, 12th Floor
New York, NY 10010

Email: [email protected]

Changes to this privacy notice

We may amend this Privacy Notice from time to time. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Platform and/or Services or by sending you an email.

What personally identifiable information (“PII”) does Octus collect about you?

We may collect and process the following information about you:

  • Identifiers, such as name, email address, telephone number, and IP address;
  • Professional information, such as employer and job title; and
  • Internet or other electronic network activity information, such as details of your visits to, and actions you may take, on the Platform or via the Services, including but not limited to traffic data, location data, logs of web usage and the resources that you access. We may also collect the IP address of any person to whom you forward an electronic communication from Octus that such person opens.

Why does Octus collect your PII?

We collect your PII to:

  • Allow you to access the Platform and use the Services;
  • Manage our relationship with you, including contacting you regarding the Platform, the Services, events, and other issues that may be of interest to you;
  • Operate, administer, maintain and manage access to the Platform and the Services;
  • Carry out our obligations arising from any contracts between your employer (or the entity that subscribes to the Services you have access to if different than your employer) and us;
  • Carry out our business operations, such as accounting, audit, tax and compliance purposes;
  • Analyze use of, and to improve, the Platform and the Services, including using automated evaluation tools that analyze the nature and frequencies of usage and interaction with the Platform and the Services by visitors;
  • Monitor, investigate, prevent and detect fraud, security incidents and other misuse of the Platform and the Services, protecting you from harm and protecting the security and integrity of our systems and information; and
  • Comply with legal requirements, handle any complaints, and exercise or defend our legal rights.

Where permitted by law, we may combine PII collected through the Platform and the Services with Octus’ offline records and information provided to us by third parties. We use this consolidated information for the purposes described above.

How do we share PII that is collected through the Platform and the Services?

We may share your PII with vendors who help us provide the Platform and the Services, including those that help us communicate with our subscribers and website visitors and those that provide us with technical and administrative services. We may also share your PII with other entities in our corporate group in connection with the above purposes, with your employer, in connection with sale or similar transfer of our business, if we are legally compelled to do so, or for other legal purposes.

Security of PII

We implement appropriate technical and organizational measures to protect your PII against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access and any other unlawful forms of processing. We employ measures so that the level of security adopted to protect your PII is appropriate for the risks presented by the nature and use of your PII. We follow recognized industry practices for protecting our IT environment and physical facilities.

To help us protect your privacy, you should maintain the secrecy of the password that you set up in connection with your usage of the Platform and the Services.

Transfers of PII

Your PII may be transferred to, and processed in, countries around the world that may have different levels of privacy protection than your country. By using the Platform and the Services, you consent to such transfers and processing, including to and in the United States.

Retention periods

We retain your PII for as long as reasonably necessary for the purposes described above, including without limitation to provide the Services, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

Cookies

We use cookies on our Platform. Cookies are small data files which we download onto your device. Cookies enable us to deliver you a better and more tailored user experience. The types of cookies that we use are as follows:

  • Strictly Necessary Cookies: These cookies are necessary for site security, network management, and accessibility;
  • Performance cookies: These cookies allow us to measure the performance of our Platform, for example by understanding which pages you visit and how you interact with our Platform and Services. We use this information to improve our Platform and Services;
  • Functional cookies: These cookies enable our Platform to provide enhanced functionality and personalisation; and
  • Advertising cookies: These cookies may be set through our Platform or by our advertising partners. They may be used to build a profile of your interests and show you relevant adverts or other materials.

You can withdraw your consent using our cookie manager tool, which can be accessed directly on the Platform using the Manage Settings prompt.

We do not require your consent for strictly necessary cookies. It is possible for you to disable those by changing your browser settings, but this may affect how the Platform and Services function.

Sharing of data and communications

We may use your email address to contact you. We may use your registered name and email address to provide the Services to you and to provide you with announcements about Platform functions or Services that you are registered to use, about Octus events or about other significant developments that may concern your use of the Platform or the Services. You can choose not to receive these emails by using the ‘unsubscribe’ mechanism provided at the bottom of these emails.

Information regarding your usage of the Services may also be provided to your employer (or the entity that subscribes to the Services you have access to if different than your employer).

Complaints

If you do not think that we have processed your data in accordance with this notice, you should let us know as soon as possible by emailing us at [email protected]. You may also complain to the applicable data protection authority.

GDPR and UK GDPR

The additional information in this section applies to processing of PII that falls within the scope of the EU General Data Protection Regulation (GDPR) or GDPR as implemented into UK law (UK GDPR). References to PII in this section are to “personal data” as defined in the GDPR and UK GDPR.

Lawful bases for processing

The following are the main lawful bases under GDPR and UK GDPR on which we process your PII for the purposes described in the section “Why does Octus collect your PII?” above:

  • Legitimate interests: We may process your PII the purposes of Octus’ or a third party’s legitimate interests while applying appropriate safeguards to protect your privacy;
  • Compliance with laws: We are subject to certain legal requirements which may require us to process your PII; and
  • Consent: We may process your PII based on your consent. If we do so, you may revoke your consent at any time by emailing us at [email protected].

Your rights

You have the following rights in relation to your PII in the circumstances and subject to the limitations and exemptions set out in GDPR and UK GDPR:

  • Right of access: You can ask us for confirmation of whether we process your PII and, if so, to request a copy of that information;
  • Right to rectification: You can ask us to correct any inaccurate PII about you;
  • Right to erasure: You can ask us to delete your PII in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected;
  • Right to restrict processing: You can ask us to restrict the processing of your PII in certain situations, such as when you contest the accuracy of the data;
  • Right to data portability: You can ask us to receive certain PII in a structured, commonly used and machine-readable format, and to transmit that PII to a third party;
  • Right to object: You can object to our processing of your PII on grounds relating to your particular situation. You can also object where we are processing your PII for direct marketing purposes; and
  • Right related to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Please email us at [email protected] if you wish to exercise any of these rights. You should provide sufficient information that allows us to reasonably verify you are the person about whom we collected the PII or an authorized representative of that person, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Data transfers

We put in place appropriate safeguards based on standard contractual clauses when transferring PII outside the European Economic Area and UK. Please email us at [email protected] for more information.

CCPA/CPRA

The additional information in this section is applicable to you if you are a consumer resident in California, in accordance with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (jointly referred to as “CCPA/CPRA”). References to PII in this section are to “personal information” as defined in the CCPA/CPRA.

Sale and sharing of PII

We do not sell your PII. However, under the CCPA/CPRA, “sharing” includes disclosing it to third parties for cross-context behavioral advertising purposes. We may allow certain third parties to collect data through cookies and similar technologies on our Platform to serve ads that are more relevant to you. To opt-out of this “sharing” of your information for cross-context behavioral advertising, you can use our Cookie Setting tool available on the Platform to disable Advertising cookies.

Your rights

Consumers resident in California have the following rights in the circumstances and subject to the limitations and exemptions set out in the CCPA/CPRA:

  • Right of access: You can ask us, twice in a 12-month period, to disclose certain information about our collection and use of your PII over the past 12 months, including the categories of PII collected, the sources of collection, the business or commercial purpose for collecting or selling the information, the categories of third parties with whom we share the information, and the specific pieces of PII collected about you; 
  • Right to deletion: You can ask us to delete any of your PII that we collected from you and retained, subject to certain exceptions;
  • Right to correct inaccurate information: You can ask us to correct any inaccurate PII that we maintain about you, taking into account the nature of the information and the purposes of the processing; and
  • Right to opt-out of sharing: You can opt-out if we share your PII for cross-context behavioral advertising.

We do not discriminate against you because you exercised your rights under the CCPA/CPRA.

To exercise your rights under CCPA/CPRA, you may submit a verifiable consumer request to us by emailing us at [email protected]. The request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected PII or an authorized representative of that person, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.