Privacy

Your Privacy Comes First

Global Privacy Policy

Effective date : December 1, 2024

Last modified : November 1, 2024

aOK (officially, OK.ME Inc.) is committed to protecting the privacy of all users of the applications and internet services distributed under the aOK brand via the major app stores, our websites, and/or via any affiliate websites (the "Software"), and all users and partners who use our personally controlled identity system, software products, web services, application programming interfaces (APIs), software development kits (SDKs), tools, and related services (together with the Software, the “Platform”). We ask that you read it carefully.

This Global Privacy Policy (“Policy”) explains how we collect, use, disclose, and protect users’ and visitors’ information as part of the Platform. Any discussion of your use of the Platform in this Policy is meant to include your visits to our websites whether or not you are a user of the Platform. If you are a resident of the European Union, European Economic Area, United Kingdom, or Switzerland, please read in addition to this Policy our EU & Swiss Privacy Policy for further information about our data collection practices and your rights.

In this Policy, "aOK" refers to aOK staff, officers, attorneys, and affiliates, all of whom are bound by law or contract to keep confidential information they receive as part of their assistance to aOK.

When we refer to “aOK,” “we,” “our,” or “us” in this Policy, we are referring to aOK, and its subsidiaries and affiliates, as the “controller” (and/or a “business” or “organization” under the CCPA) or the equivalent legal construct under applicable law of the information we process when you visit our websites, use the Platform, and/or we interact with you through our communication channels for business purposes. This Privacy Policy covers the digital properties listed herein.

Capitalized terms that are not defined in this Policy have the meaning given them in our Terms of Service including any relevant agreement, policy, or addendum incorporated therein and any amendments or modifications thereto.

It is important to note that where aOK handles Personal Information on behalf of or at the direction of its users through their use of our Platform, aOK is the “processor” (and/or “service provider” under the CCPA) or the equivalent legal construct under applicable law of that data and aOK’s use, processing, and handling of such data is done pursuant to the written instructions of its users in the form of the Terms of Service and/or any similar written agreement between the parties. In these cases, our use of information collected through our Platform shall be limited to the purpose of providing and operating the Platform for our users. aOK may, from time-to-time, introduce new products and services. To the extent that any new products and/or services affect this Privacy Policy, we will notify you as further described in Section 13 below.

If you have any questions about this privacy policy or our practices, please contact us. If you are in the European Union, you may contact our Data Protection Officer through this same email address.

Contents

What “Personal Information” means

In this Policy, “Personal Information” means any information relating to an identifiable natural person. aOK does not sell or rent user information under any circumstances, and we do not share user information without prior consent except as compelled by law.

Personal Information does not include data or information collected, derived, or otherwise generated from the use of the Platform, provided that such data has been anonymized, de-identified, and/or aggregated so as not to identify or permit the identification of any individual (“De-identified Data”), De-identified Data helps us understand trends in usage of the Platform so that we can better consider new features or otherwise tailor the Platform. In addition to collecting and using De-identified Data ourselves, we may share De-identified Data with third parties, including our users, partners and service providers, for various purposes, including to help us better understand our users’ needs and improve the Platform as well as for communications purposes.

How we collect, use, and share your Personal Information and other information

a. Information you provide to us

When you register to use the Platform, we may ask for Personal Information such as your name, email address, identity document(s), credit card or other billing information. You may also provide at your own discretion certain related information like your personal website name, social media websites, and other personal information which will be stored within your secure Personal Data Vault. Additionally, as you utilize the Platform, the software continuously saves changes made by you within your secure Personal Data Vault. All information within your secure Personal Data Vault is encrypted at rest and can only be accessed by you.

We may also retain the contents of any messages you send to us, and we may collect information you provide in Web Forms that you post or upload to us to the extent required or permitted under applicable law.

aOK may use Personal Information you provided to operate, improve upon, and personalize the Platform, for billing identification and authentication, to contact you about the Platform and your use of the Platform, to support your use of the Platform, and to send messages to which you have subscribed (for example, our newsletter).

Note that we will never email you to ask for your account information. If you ever receive such an email, please forward it to privacy@aokapp.com. For more information about our procedures in this regard, please review our Terms of Service.

We use financial information solely as authorized by you. While aOK does not store your credit card information and will use commercially reasonable efforts to ensure the security of all credit card and all other Personal Information, we expressly disclaim any liability for any unauthorized access to or use of our secure servers and/or any and all personal and/or financial information stored therein, and you agree to hold aOK harmless for any damages that may result therefrom.

b. Information we receive from and share with third parties

We receive Personal Information about you from third parties. For example, if you access the Platform through a third-party connection or connect an application to aOK, that third party you connected with may pass certain information about your use of its service to aOK. This information could include, but is not limited to, the user ID associated with your account, an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that third-party service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Platform.

Our identity verification is performed by IDVerse, which is a trading name of OCR Labs. If you are resident in the USA or Canada then it is performed by OCR Labs Global (USA) Inc (a Delaware corporation), if you are resident in Europe, the Middle East or Africa then it is performed by OCR Labs Global Limited (an English company) and if you are resident anywhere else then it is performed by OCR
Labs Pty Ltd (a New South Wales, Australia company).

If you are a US resident then please see IDVerse’s US biometric statement in its Privacy Policy.

IDVerse verifies your ID is genuine and then extracts all of the data on the identity document. Data extracted includes the data written on the ID doc and your picture, and also data in any barcode, machine readable zone or in the chip (if the chip is being read). IDVerse sends that data to us. In the user flow you can correct any data extracted incorrectly. If you do correct any incorrect data then IDVerse will take just the incorrect character (and no personal data) from the ID document to make sure it does not make that mistake again.

IDVerse uses your biometric data to check you are a real person, to extract your face from the ID document and to compare that against your selfie to ensure you are the right person, and for anti-fraud purposes. IDVerse deletes your biometric data within seven days of initial collection.

IDVerse also uses location information from your device for anti-fraud purposes.

aOK will only transfer your Personal Information at your request, and with your consent, for use by third parties to authenticate your identity or group eligibility, and as required for the provision of the Platform which aOK is designed to provide as defined in the Terms of Service and the prevention of fraud. We've built rigorous security and privacy requirements into our technology from its inception. We are an ethical steward of your Personal Information and are committed to supporting the following principles:

  • You are the sole controller of your own Personal Information.
  • You must provide consent before we will share any of your Personal Information.
  • You can see all authorized applications and parties with whom you interact, and which specific elements of your Personal Information are shared in your dashboard.
  • You can revoke access to your Personal Information for any authorized application and/or party at any time.
  • You can delete your Account credentials and associated Personal Information at any time.

It is important to note that where aOK handles Personal Information on behalf of or at the direction of its users through their use of the Platform, aOK is the “processor” (and/or “service provider” under the CCPA) or the equivalent legal construct under applicable law of that data and aOK’s use, processing, and handling of such data is done pursuant to the written instructions of its members in the form of the Terms of Service and/or any similar written agreement between the parties. In these cases, our use of information collected through the Platform shall be limited to the purpose of providing and operating the Infrastructure for our members.

aOK may also provide Personal Information to its third-party service providers (such as its credit card processors and hosting partners) as necessary to provide the necessary hardware, software, networking, storage, and other services we use to operate the Platform. We do not permit our service providers to use Personal Information we provide to them for any purpose other than providing their services to us. We execute the legally required data processing addenda with all of our service providers.

c. Application integration

To facilitate the exchange of data between third-party SaaS applications, we may need to store certain information (“App Credentials”) that helps us access these third-party SaaS application accounts on your behalf. We store your App Credentials in an encrypted form.

When we access these third-party applications on your behalf, the third-party application provides us with access to certain data. We will use, store, and disclose this data in accordance with this Policy.

You should note that aOK shall have no liability or responsibility for the privacy practices or other actions of any third-party applications for which you provide us with App Credentials.

d. Log file information

We collect certain technical information from our End Users. This information includes Internet Protocol (IP) addresses; the date/time a webpage or feature is accessed; the user agent string that identifies the browser or operating system to the server; installed fonts; mime-types; browser language and time zone; Silverlight data; installed plugins; HTTP headers; and screen resolution.

aOK uses this information to monitor the volume of our website traffic. We use this technical information for our own security and analytical purposes, such as to measure how many users are using the Platform. Lastly, we may use this information to create separate analytics products that we offer to users — provided that analytics products would only utilize De-Identified Data — to help users understand how the Platform is being used and to provide other measurement metrics.

e. Other information disclosure

We may be required to disclose Personal Information to respond to subpoenas, court orders, and law enforcement or governmental requests or investigations, or to establish or exercise our legal rights or defend against legal claims. We may also share Personal Information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations or our Terms of Service, or as otherwise required by law.

We use or may use information collected by cookies, log files, device identifiers, and clear GIFs information to:

  • remember information so that you will not have to re-enter it during your visit or the next time you use the Platform
  • provide custom, personalized content and information
  • to provide and monitor the effectiveness of the Platform
  • monitor aggregate metrics such as total number of users and traffic patterns
  • diagnose or fix technology problems
  • help you efficiently access your information after you sign in, and
  • automatically update the aOK applications on your devices.

We will only provide Personal Information to members of the aOK team, including our Affiliates, with your express permission as stated herein.

4

Public forums

The Platform offers publicly accessible community forums. If you elect to post something in a public area of the Platform, any Personal Information or content that you voluntarily disclose for posting to such area becomes available to the public, as controlled by any applicable privacy settings. If you remove information that you posted to the public areas of the Platform, copies may remain viewable in cached and archived pages of the Platform, or if other users have copied or saved that information.

To request removal of your Personal Information from our community forums, contact us at privacy@aokapp.com. In some cases, we may not be able to remove all of your Personal Information.

5

User testimonials / comments / reviews

From time to time, we may post user testimonials which may contain Personal Information. We will always obtain your consent prior to posting any Personal Information included in your testimonial(s).

6

Protection of information

aOK is committed to ensuring the security of your Personal Information. All information within your secure Personal Data Vault is encrypted at rest and can only be accessed by you. We use what we determine to be the best available technological, physical, and administrative security safeguards, such as public key encryption (PKE), firewalls, and carefully developed security features, to protect the confidentiality and security of your Personal Information on the Platform. When you enter confidential information (such as information submitted from within the Platform) we encrypt the transmission of that information using PKE and secure socket layer technology (SSL). HTTPS is enabled by default on all of our web services, and certificates are refreshed on a regular basis. These technologies, procedures, and other measures are used in an effort to ensure that your data is safe, secure, and only available to you and to those you authorized to access your data. However, no internet, email, or other electronic transmission is ever fully secure or error-free, so you should take care in deciding what information you send to us in this way. aOK is not responsible for the functionality or security measures of any third party.

7

Hosting and data transfer

As aOK is based in the United States, we may host, transfer, and process your Personal Information in the United States or countries other than the United States. aOK uses a variety of safeguards, including contractual and technical measures, to protect the Personal Information and data we transfer. aOK will ensure that any of our service providers, processors, or third parties will undergo a comprehensive privacy vetting process prior to providing them your Personal Information.

If you are located in the United Kingdom (“UK”), European Union (“EU”), European Economic Area (“EEA”) or Switzerland, please see our EU & Swiss Privacy Policy. aOK is seeking certification under the EU-US and Swiss-US Data Privacy Framework as well as the UK Extension to the EU-US Data Privacy Framework. aOK is committed to complying with the Data Privacy Framework’s Principles. If you would like to submit a dispute under the Data Privacy Framework you may do so by following the instructions found here.

8

Correcting and updating your information

You may update, delete, or change Personal Information you have provided to aOK by logging into your aOK app and providing such additional information or deleting such information where applicable. If you are not a User and would like to gain access to, or request deletion of, information we have collected, please contact us at privacy@aokapp.com. We will provide a response in accordance with applicable parameters in a commercially reasonable amount of time.

9

Data retention

aOK will retain Personal Information we process on your behalf for as long as necessary to provide the Platform to you, subject to our compliance with this Policy, or as required or permitted under applicable law. We may further retain and process Personal Information as necessary to comply with our legal obligations; maintain accurate accounting, financial, and other operational records; resolve disputes; and enforce our agreements. We have established internal policies for the deletion of Personal Information following the termination of your Account.

10

Children's Personal Information

aOK does not knowingly collect any Personal Information from children under the digital age of consent (13 in the United States, 16 in the EU). If you are under the age of 13 (or the applicable digital age of consent), please do not submit any Personal Information through the Platform. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Policy by instructing their children never to provide Personal Information on the Platform. If you have reason to believe that a child under the age of 13 (or the applicable digital age of consent) has provided Personal Information to aOK through the Platform, please contact us, and we will delete that Personal Information from our databases without delay.

11

Your California privacy rights

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the Personal Information categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect your Personal Information, where we obtain the Personal Information, and the third parties with whom we may share your Personal Information.

We generally collect the following categories of Personal Information about you when you use our sites or Platform:

  • identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;
  • protected classifications, such as gender;
  • commercial information such as records of products or services purchased, obtained, or considered by you;
  • Internet or other electronic information regarding your length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
  • audio recordings of your voice to the extent you call us and leave voicemail, as permitted under applicable law;
  • professional or employment-related information.

We do not collect education-related information, geolocation information, or inferences about your preferences, characteristics, behavior, and attitudes. For more information about the Personal Information we collect and how we collect it, please refer to Sections 1 and 2, above.

We collect your Personal Information for the business purposes described in Section 2, above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.

The categories of third parties with whom we may share your Personal Information are listed in Section 2, above.

12

US State Privacy Rights

Residents of certain US states, including but not limited to California, Colorado, Connecticut, Virginia, and Utah, may have additional rights in relation to their Personal Information. However, these rights may be subject to certain exceptions. For instance, we may be unable to disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of Personal Information, your Account with us, or the security of our network systems. Your rights may include:

  • Right Against Discrimination - You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
  • Right to Know - You have the right to request in writing: (i) a list of the categories of personal information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties' direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.
  • Right to Delete - You have the right to request us to delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.

To assert your right to know or your right to delete your Personal Information, please contact us according to the “Contact Us” section below. To verify your identity, we will rely upon the Platform as that is its purpose, and the sole method available to us for identity verification purposes.

California consumers may also use the Digital Advertising Alliance’s tool to send requests under the California Consumer Privacy Act (“CCPA”) for a web browser to opt out of the sale of personal information by some or all of that framework’s participating companies by accessing the DAA’s tool here: https://www.privacyrights.info/, or by downloading the DAA’s AppChoices mobile application opt-out here: https://www.privacyrights.info/appchoices.

The AppChoices app is not limited to opt-outs for CCPA purposes and may be used by anyone to limit the collection of cross-app data for interest-based advertising purposes by participating DAA member companies.

In addition, under California Civil Code Sections 1798.83–1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties, and providing contact information for such affiliates and/or third parties.

If you are a California resident and would like a copy of this notice, please submit a written request to privacy@aokapp.com or to:

aOK c/o OK.ME Inc.
8 The Green, Suite B
Dover, DE 19901

13

Changes to the Privacy Policy

We reserve the right to modify, update, or change this Policy from time to time in the usual course of operations, so we encourage you to review this page periodically. Notwithstanding, when we change this Policy in a material manner, we will update the effective date at the top of this page and provide you with reasonable advance notice before the updates to this Policy become effective. aOK may provide such notifications to you via email notice, written or hard copy notice, and/or through posting of such notice on the Platform. We reserve the right to determine the form and means of providing notifications to you. You may be required to click-to-accept or otherwise agree to the updated Policy, but in any event your continued use or access of the Platform after the effective date of the updated Policy shall constitute your agreement to the updated Policy. The Policy will be effective as of the date specified in the effective date at the top of this page, and will apply to your use of the Platform from that point forward. If we update this Policy in a non-material manner after the effective date, we will update the last modified date at the top of this page. If you choose not to agree to this Policy or any future updated Policy, you may not use or access (and must discontinue any use or access to) the Platform. aOK is not responsible for any automatic filtering you or your network provider may apply to email notifications we send to the email address you provide us.

14

Contact us

If you have questions regarding this Policy or about the privacy practices of aOK, please contact us by email at privacy@aokapp.com, or at:

aOK c/o OK.ME Inc.
8 The Green, Suite B
Dover, DE 19901

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