Privacy policy
1 September, 2024
Octiga values your privacy and is fully compliant with GDPR and similar regulations. All data shared with and collected by Octiga is confidential and securely processed. Please also review our Data Processing Agreement for more details.
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 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
Octigas primary service is related to the management and security of Microsoft 365 (M365) environments (Tenants). Specifically this is done via a web interface and associated back end infrastructure which allows IT Service Providers to manage their clients M365 tenants. In so doing Octiga collects and processes certain data including some personal data where required.
Types of Personal Data Collected
The following sections outline this processing and storage with respect to the various parties and data classifications involved
Personal Data of your Tenants (Clients) 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.
What we Do NOT collect, process or store
For the elimination of doubt this section describes the data which we do not 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 categorizations.
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 Site Visitors
Visitors to the Octiga website are subject to site monitoring which may include analytics and remarketing
Analytics
We may use third-party Service providers to monitor and analyse the use of our Service.
- Google Analytics: Google Analytics is a web analytics service. Read the Privacy Policy for Google Analytics here: https://Google Analytics.com/terms
- Hotjar: This is a web analytics service. Read the Privacy Policy for Hotjar here: https://www.hotjar.com/legal/policies/privacy/
Behavioral 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.
- Remarketing Ads: LinkedIn, Facebook, Google Ads. You can opt-out of remarketing by visiting the respective remarketers preference page. For more information on the privacy practices of these services, please visit the respective policy web pages: http://www.Google Ads.com/about/privacy, https://www.facebook.com/policies/ads/, https://www.linkedin.com/legal/sas-terms
Storage and Processing Locations
Octiga's services, data processing and data storage reside within Octiga's data centers. These are in Amazon Web Services in Dublin Ireland. Octiga are registered within the The Republic of Ireland. Octiga are compliant and abide by GDPR under the European Union.
Octiga use 3rd party processors in the provision of its services. These amount to:
- The transfer and processing of IP addresses (ONLY) of Tenant Users for the purpose of geolocation and IP risk analysis. This processing is done in the jurisdiction of France and the United States. Octiga collect GDPR compliant Data Processing Agreements from these parties for this purpose
- The transfer and processing of email addresses of Tenant Users (ONLY) for the purpose of investigating if the email address has ever appeared on the dark web. This data is transferred to and processed in the United States
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 for reasonable business use in the provision of our services and 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