Latest Update: August 8, 2023.
At Okibro Inc., safeguarding your privacy is of utmost importance. We are committed to upholding your privacy rights and adhering to all applicable laws and regulations concerning the collection of any personal information. This pertains not only to our official website, https://app.okibro.com, but also to other websites under our ownership and operation.
Personal information encompasses any data that can be utilized to identify you. This includes details related to your identity, such as your name and date of birth, particulars about your devices, payment information, and even data about your interactions with websites and online services.
Should you have any further inquiries regarding our policy, please feel free to reach out to us.
This policy is relevant to your usage of our software and engagement in our online activities. It remains applicable to visitors accessing our website, pertaining to the information they choose to share with us.
Who we are
Okibro Inc is the data controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our”). Our full details are:
Email: [email protected]
Information We Collect
Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.
“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.
“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.
When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, geolocation, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.
Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
When you visit our website or interact with our services, we may automatically collect data about your device, such as:
Data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
We may ask for personal information — for example, when you register an account or when you contact us — which may include one or more of the following:
Social media profiles
Some speaking tasks involve you speaking on our website. To recognize speech your audio may be sent to a third party provider such as Google. Any audio you agree to send to us for our internal business purposes, including without limitation for purposes of language proficiency evaluation, dispute resolution, and improving our services. By accepting this policy you agree that we may transfer your audio for the purpose of language proficiency evaluation to our tutors and specialists or provide them with access to your audio files.
To have access to some of our services you will need to actively provide access to a microphone. We will then collect recordings of your voice speaking to improve our services, and do not derive a voice print or any other information that could be used to identify you from your vocal data.
We also collect, use and share aggregated data such as statistical, demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your personal data to provide statistics on language proficiency. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.
Legitimate Reasons for Processing Your Personal Information
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.
Collection and Use of Information
We may collect personal information from you when you do any of the following on our website:
Register for an account
Use a mobile device or web browser to access our content
Contact us via email, social media, or on any similar technologies
When you mention us on social media
We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
to provide you with our platform’s core features and services
to respond to your requests, for example to contact you about a question you submitted to us, or contact you regarding your use of the website
to inform you about changes in your services and software, our service offering and other important service-related notices
to protect our rights and interests as well as the rights and interests of our users and any other person
to enable you to customize or personalize your experience of our website
for analytics, market research, and business development, including to operate and improve our website, associated applications, and associated social media platforms
for technical assessment, including to operate and improve our website and other software, associated applications, and social media platforms
to perform research and analysis about your use of, or interest in, our software, products, services, content, or products, services or content offered by others
to comply with applicable legal or regulatory obligations, including complying with requests from law enforcement or other governmental authorities, or in legal proceedings involving our website
to fulfill our contractual obligations
to communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
initiate a payment, add value to an account, or pay a bill, if required
prevent and investigate fraudulent or other criminal activity
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, Our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our site to improve our site and your experience on it.
We do not collect the following special categories of personal data about you: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, data about your health data.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
How Long We Keep Your Personal Information
We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
Disclosure of Personal Information to Third Parties.
We may disclose personal information to:
a parent, subsidiary, or affiliate of our company
third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators
our employees, contractors, and/or related entities
our existing or potential agents or business partners
credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you
third parties to collect and process data
an entity that buys, or to which we transfer all or substantially all of our assets and business
Third parties we currently use include:
Your Rights and Controlling Your Personal Information
Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our website or the products and/or services offered on or through it. For example, if you do not provide your email, we will not be able to communicate with you, and (b) if you do not provide us with voice recordings, we will not be able to provide you feedback regarding your language proficiency skills.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s full consent to provide the personal information to us.
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Notification of data breaches: We comply with applicable laws in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Limits of Our Policy.
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Changes to This Policy.
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
So that you are aware changes have been made, we will adjust the “Last Revised” date or “Date of publication” at the beginning of this document.
Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)
The GDPR distinguishes between organisations that process personal information for their own purposes (“data controllers”) and organizations that process personal information on behalf of other organizations (“data processors”). We, Okibro Inc. are a Data Controller with respect to the personal information you provide to us.
Legal Bases for Processing Your Personal Information.
We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.
Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:
Consent From You.
Performance of a Contract or Transaction.
Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you contact us with an enquiry, we may require personal information such as your name and contact details in order to respond.
Our Legitimate Interests.
Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.
Compliance with Law.
To facilitate our global operations, the Company may transfer, store, and process your operations with our partners and service providers based outside of the country in which you are based. Laws in those countries may differ from the laws applicable to your country of residence. Where we transfer, store, and process your Personal Data outside of the country in which you are based we will ensure that the appropriate safeguards are in place to ensure an adequate level of protection. Further details regarding the relevant safeguards can be obtained from us on request.
International Transfers Outside of the European Economic Area (EEA).
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Your Rights and Controlling Your Personal Information.
Restrict processing: You have the right to request that we restrict the processing of your personal information.
Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
Consent withdrawal: You have the right to withdraw your consent to the processing and use of your data completely or partially at any time with future application.
Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in readable machine format. You may also have the right to request that we transfer this personal information to a third party.
Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. We will let you know how the deletion affects your use of our website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your personal information within 30 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.
Complaint: You have the right to complain to the responsible supervisory authority if you believe that the processing of your personal data is in violation of the legislation.
Additional Disclosures for California Compliance (US).
If you are a California resident, you may have certain additional privacy rights. Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organizations for their marketing purposes.
Do Not Track.
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals.
Cookies and Pixels.
CCPA-permitted financial incentives.
In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide.
Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information, and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
California Notice of Collection.
In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:
Audio or visual data, such as photos or videos you share with us or post on the service.
For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.
Right to Know and Delete.
If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
The categories of personal information we have collected about you;
The categories of sources from which the personal information was collected;
The categories of personal information about you we disclosed for a business purpose or sold;
The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
The business or commercial purpose for collecting or selling the personal information; and
The specific pieces of personal information we have collected about you.
Shine the Light.
If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes.