OkHi Privacy Policy
- Our approach to privacy
- OkHi Limited. ("OkHi", "we", "our" or "us") is committed to protecting and respecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information").
- This Privacy Policy applies to your use of the OkHi application, which is our web-based application at okhi.com (the “App”) and also available for download on your mobile device; and (b) via OkHi partners that have integrated OkHi address collection and verification in their web or mobile apps (together, the "OkHi Platform"). The core functionality of the OkHi Platform is to allow users to create an accurate and verified address of their location.
- Please ensure that you have read this Privacy Policy and understood how we collect, store, use and disclose your personal information before accessing or using the OkHi Platform.
- By using the OkHi Platform, you agree to the collection and use of your personal information in accordance with this policy.
- PERSONAL information we collect FROM you when you use the OKHI PLATFORM, and how we use it
- We collect personal information that you voluntarily submit directly to us when you use the OkHi Platform. This can include information you provide to us when you set up an account, correspond with us by phone or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, when you report a problem with the OkHi Platform or use some other feature of the OkHi Platform.
- Location Data. We also use GPS technology to determine your current location. Some of our location-enabled services require your location data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by a) updating OkHi permissions and access to Location Data in browser or device settings, or (b) opting out from this feature on our website at www.okhi.com.
- We endeavour to limit the storage of location data to your current address and the immediate vicinity of your current address.
- If you choose not to provide such personal information, we may not be able to provide those parts of the OkHi Platform to you or respond to your other requests.
- The table at Annex 1 sets out in detail the categories of personal information we collect about you and how we use that information when you use the OkHi Platform, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.
- Information we collect about you automatically
- We also automatically collect personal information indirectly about how you access and use the OkHi Platform, and information about the device you use to access the OkHi Platform. For example, we may collect:
- information about the features you use and the pages you view on the OkHi Platform;
- information about your device (such as your IP address, device identifier, device type, model and manufacturer); and
- information about your usage patterns (such as how often you use the OkHi Platform and your language settings).
- We use this information to provide you the features and functionality of the OkHi Platform, to monitor and improve the OkHi Platform and to develop new products and services.
- The table at Annex 2 sets out in detail the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and recipients of that personal information.
- We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
- We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the OkHi Platform and developing new products and features. We may also share such anonymised and aggregated information with others.
- Principles of Processing
- Our collection and processing of your personal information is guided by the following principles:
- Personal information shall be processed fairly lawfully and in a transparent manner;
- Personal information shall be obtained for a specified, legitimate and lawful purpose and shall not be processed in any manner incompatible with such purposes;
- Personal information shall be accurate, adequate and without prejudice to the dignity of human person;
- Personal information shall be stored only for the period within which it is reasonably needed; and
- Personal information shall be secured against all foreseeable hazards and breaches such as theft, cyberattacks, viral attack, dissemination, manipulations of any kind, damage, rain, fire or exposure to other natural elements.
- How long will we store your personal information?
- We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in Annexes 1 and 2, and in accordance with our legal obligations.
- We may need to retain your personal information for longer if we are required to do so by law.
- Personal information which is not retained is safely archived or destroyed when it is identified that it is no longer needed for the purposes for which it was collected.
- Recipients of personal information
- In addition to the recipients listed in Annexes 1 and 2, we may also share your personal information with the following (as required in accordance with the uses set out in Annexes 1 and 2):
- Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services
- We have listed examples of specific service providers that we use in Annexes 1 and 2.
- Affiliates. Other companies owned by or under common ownership as OkHi, including our subsidiaries (i.e., any organisation we own or control) and our ultimate holding company (i.e., any organisation that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy.
- Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
- Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of OkHi, its users or others.
- Marketing and advertising
- From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.
- For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
- We send marketing messages to users of the OkHi Platform . You have the right to object to the processing of your personal information for direct marketing purposes at any time and we will cease sending marketing messages to you unless we have compelling legitimate grounds to process your personal information which override your right to object.
- Storing and transferring your personal information
- Security. We implement on the OkHi Platform appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting providers on secure servers.
- Whenever your personal information is transferred to a location outside your country, we will take all necessary steps to ensure that your data is handled securely and a similar level of protection in accordance with this Privacy Policy is afforded to you.
- Rights for users
- In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
- Right of access. The right to obtain:
- confirmation of whether, and where, we are processing your personal information;
- information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine OkHi Platform applicable retention periods;
- information about the categories of recipients with whom we may share your personal information; and
- a copy of the personal information we hold about you.
- Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
- Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
- Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
- Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
- Right to withdraw consent. If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
- You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
- If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.
- You may also review and edit some of the personal information you have submitted to us through the appropriate functionality on the OkHi Platform.
- Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.
- Links to third party sites
- The OkHi Platform may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates.
- If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
- Our policy towards children
The OkHi Platform is not directed at persons under 18 and we do not knowingly collect personal information from any persons under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
- Changes to this policy
We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the "last modified" date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.
- Notice to you
If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this by placing a notice on the OkHi Platform. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.
- Contacting us
Please contact our data protection officer, Navraj Ghataura (dpo@okhi.co) if you have any questions, comments and requests regarding this Privacy Policy. We will endeavour to respond to all legitimate requests, questions or comments within one month of receipt of such request. In the event your request, questions or comments are complex or you have raised multiple requests, comments or questions, we will provide you with an estimated time of resolution or response and keep you updated.
- This Privacy Policy was last modified on 27 July 2023.
ANNEX 1 – PERSONAL INFORMATION YOU PROVIDE TO US
Category of personal information - Profile information such as your name, phone number and physical address.
We may use this information to set up and authenticate your account on the OkHi Platform.
How we may use it & Legal basis for the processing
We shall only process your personal information in accordance with the following lawful purposes:
- You have given your consent to the processing of your personal information;
- Where the processing is necessary for the purposes of the legitimate interests pursued by OkHi, to which you are a party;
- Where the processing is necessary for the performance of a contract to which you are a party;
- Where processing is necessary to take steps at your request prior to entering into a contract;
- Processing is necessary to protect your vital interest of that of another person; or
- Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in OkHi.
We may use this information to communicate with you, including sending service-related communications.
We may use this information to send you marketing communications in accordance with your preferences.
We may use this information to deal with enquiries and complaints made by or about you relating to the OkHi Platform.
We may use this information for user verification purposes.
Recipients of personal information
We may share this information with cloud service providers including Amazon Web Services, Inc. and Google LLC.
We may share this information with payment businesses for them to use as a variable in authorising payment
Category of personal information - Location Data
We use GPS technology, building imagery, textual information (for example, building name and street and apartment name and number) to verify your address.
How we may use it & Legal basis for the processing
We shall only process your personal information in accordance with the following lawful purposes:
- You have given your consent to the processing of your personal information;
- Where the processing is necessary for the purposes of the legitimate interests pursued by OkHi, to which you are a party;
- Where the processing is necessary for the performance of a contract to which you are a party;
- Where processing is necessary to take steps at your request prior to entering into a contract;
- Processing is necessary to protect your vital interest of that of another person; or
- Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in OkHi.
We use GPS technology, gate imagery, text information (e.g., building name and street and apartment name and number) to allow businesses to deliver various services to you.
We may use this information to verify that you reside at the location that you say you do.
The processing is necessary for the provision of various business services to you.
We will only use your personal information in this way to the extent you have given us consent to do so.
Recipients of personal information
With your permission, Location Data and data generated about you may be shared with businesses that you have transacted with.
Category of personal information - Usage information
For example, the time and activities for while you use the OkHi Platform, your results when you use the OkHi Platform, any issues experienced when you use our products and any other information generated about how you use the OkHi Platform.
How we may use it & Legal basis for the processing
We shall only process your personal information in accordance with the following lawful purposes:
- You have given your consent to the processing of your personal information;
- Where the processing is necessary for the purposes of the legitimate interests pursued by OkHi, to which you are a party;
- Where the processing is necessary for the performance of a contract to which you are a party;
- Where processing is necessary to take steps at your request prior to entering into a contract;
- Processing is necessary to protect your vital interest of that of another person; or
- Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in OkHi.
We may use this information to analyse how the OkHi Platform performs, to fix issues and deal with any errors with the OkHi Platform, to improve the OkHi Platform and develop new products and services.
All personal information set out above.
We may use all the personal information we collect to operate, maintain and provide to you the features and functionality of the OkHi Platform, to communicate with you for marketing purposes, to authenticate you to your data, to monitor and improve the OkHi Platform and business, and to help us develop new products and services.
ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY
Category of personal information - Information about how you access and use the OkHi Platform.
For example, how frequently you access the OkHi Platform, the time you access the OkHi Platform and how long you use it for, the approximate location that you access the OkHi Platform from, whether you access the OkHi Platform from multiple devices, and other actions you take on the OkHi Platform.
How we may use it & Legal basis for the processing
We shall only process your personal information in accordance with the following lawful purposes:
- You have given your consent to the processing of your personal information;
- Where the processing is necessary for the purposes of the legitimate interests pursued by OkHi, to which you are a party;
- Where the processing is necessary for the performance of a contract to which you are a party;
- Where processing is necessary to take steps at your request prior to entering into a contract;
- Processing is necessary to protect your vital interest of that of another person; or
- Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in OkHi.
We may use information about how you use and connect to the OkHi Platform to present the OkHi Platform to you on your device and improve your experience on the OkHi Platform.
The processing is necessary to tailor the OkHi Platform to the user.
We may use this information to determine products and OkHi Platform that may be of interest to you for marketing purposes.
The processing is necessary to inform our direct marketing and generally improve your experience on the OkHi Platform.
We may use this information to monitor and improve the OkHi Platform and business, resolve issues and to inform the development of new products and services.
Recipients of Personal Data
We may share this information with cloud service providers including Amazon Web Services, Inc. and Google LLC (in respect of the Firebase cloud) as well as analytics tracking platforms such as Microsoft Clarity, Google Analytics, Mixpanel, Amplitude, or the or similar analytics tools that we may use from time to time.
Category of personal information - Location Data
Once you indicate in your device settings that the OkHi Platform should always have your access to your location, we shall collect your location data automatically in the background. We use GPS technology to determine your specific or approximate location depending on your device settings.
How we may use it & Legal basis for the processing
We shall only process your personal information in accordance with the following lawful purposes:
- You have given your consent to the processing of your personal information;
- Where the processing is necessary for the purposes of the legitimate interests pursued by OkHi, to which you are a party;
- Where the processing is necessary for the performance of a contract to which you are a party;
- Where processing is necessary to take steps at your request prior to entering into a contract;
- Processing is necessary to protect your vital interest of that of another person; or
- Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in OkHi.
We use your location data to verify that you reside at your stated location.
You can always change the automatic background collection of location data by opting out from the feature at www.okhi.me or opt out of notifications and marketing messages.
Category of personal information - Log files and information about your device.
We collect information about the tablet, smartphone or other electronic device you use to connect to the OkHi Platform. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and OkHi Platform applications connected to the OkHi Platform through the device, your mobile network, your IP address and your device’s telephone number (if it has one).
How we may use it & Legal basis for the processing
We shall only process your personal information in accordance with the following lawful purposes:
- You have given your consent to the processing of your personal information;
- Where the processing is necessary for the purposes of the legitimate interests pursued by OkHi, to which you are a party;
- Where the processing is necessary for the performance of a contract to which you are a party;
- Where processing is necessary to take steps at your request prior to entering into a contract;
- Processing is necessary to protect your vital interest of that of another person; or
- Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in OkHi.
We may use information about how you use and connect to the OkHi Platform to present the OkHi Platform to you on your device.
The processing is necessary to tailor the OkHi Platform to the user.
We may use this information to determine products and OkHi Platforms that may be of interest to you for marketing purposes.
We may use this information to monitor and improve the OkHi Platform and business, resolve issues and to inform the development of new products and services.