Privacy Notice

Last updated: Dec 5, 2023

Sections Covered

• Your Privacy Rights
• Scope and Updates
• What Data We Collect and How We Collect It
• Cross-Border Information Transfers
• How We Protect and Store Personal Information
• How We Use the Personal Information We Collect; Purposes and Legal Basis for Processing
• How We Share Personal Information with Third Parties
• Data Retention
• How You Can Access or Change Your Personal Information, etc.
• How We Use Tracking Technologies
• How You Can Opt Out of Marketing Communications
• Collection of Information from Children
• How You Can Contact Us about Privacy
• Other Regions’ Privacy Notice

Your Privacy Rights

The Ollion group of companies, successors, divisions and group entities consist of Ollion, Inc., a company incorporated under the laws of Delaware, formerly known as 2nd Watch, Inc.; Ollion Pte Ltd (UEN: 201727153K), a company incorporated under the laws of Singapore, formerly known as ST Telemedia Cloud Pte Ltd; PT Ollion International Indonesia (Principal Business No. 9120401581563), a company incorporated under the laws of the Republic Indonesia, formerly known as PT Cloud Comrade Indonesia; Ollion Sdn Bhd (201801006447 (1268461)), formerly known as Cloud Comrade Sdn Bhd; CloudCover Consultancy Pvt Ltd (CIN: U74900PN2015PTC153774), a company incorporated under the laws of the Republic of India; CloudCover Pte Ltd (UEN 20172789G), a company incorporated under the laws of Singapore; and Cloud Comrade Pte Ltd (UEN: 201414379M), a company incorporated under the laws of Singapore (collectively, “Ollion”, “we”, “us” or “our”).

This privacy notice (“Privacy Notice”) describes how we handle Personal Information (defined below) relating to you and your privacy rights regarding our collection, use, processing, disclosure, storage, sharing, and protection of such Personal Information in our possession or under our control.

“Personal Information” shall have the meaning prescribed by applicable privacy and data protection laws, but generally includes any information that can be used to distinguish or trace an individual’s identity, such as name, social security number, date and place of birth, medical, educational, financial and employment information.

This Privacy Notice applies to Ollion website and all related pages, regardless of how you access or use them (collectively, the “Site”).

This Privacy Notice does not apply to Personal Information you provide to or that is collected by the relevant service providers you do business with or you are a customer of, even if we have a business relationship with that service provider (e.g. where we provide them with services such as support and/or engineering services) and/or process Personal Information on their behalf and for their purposes. Please see your service provider’s privacy notice for information about how your service provider handles your Personal Information and how you can control your Personal Information under their possession or control. Please refer to the sub-section below titled “Service Provider Information Collection and Processing” for more information.

Notice at Collection: At or before the time of collection, California residents may have a right to receive notice of our practices, including the categories of personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. California residents can find those details by clicking on the above links.

Scope and Updates

This Privacy Notice informs you of our policies regarding the collection, use and disclosure of Personal Information when you:

• visit or use the Site;
• subscribe to our newsletters, or promotional campaigns;
• request information about our provision of services such as support and/or engineering services; or
• inquire about a job opportunity.

Please refer to “Other Regions’ Privacy Notice” for additional rights specific to different jurisdictions.

We may amend this Privacy Notice at any time by posting a revised version on the Site. We may also send other communications to you about updates made to this Privacy Notice. The revised version will be effective at the time we post it on the Site. Therefore, we encourage you to periodically review this Privacy Notice to remain informed about any changes or updates.

What Data We Collect and How We Collect It

Information You Provide to Us Through the Site and/or Interactions with Us: We collect certain information that you provide to us through the Site, and/or through interactions that we may have with you, such as during events and conferences and through our promotional efforts which may include your responses to our emails, phone calls, flyers or surveys.

Such information includes:

• Your company name
• Company location (State/Region)
• Location address
• First and last name
• Your title
• Email Address
• Telephone number
• Fax number
• IP address/geolocation (tracked through cookies, based on user browser settings & preferences)

Where you disclose Personal Information of other individuals to us, you warrant that you have the necessary authority to share such Personal Information with us, and such individuals have consented to us collecting, using and/or such Personal Information for the relevant purpose for which you made the disclosure or as was notified to you at the relevant time and such other purposes as described in this Privacy Notice. You understand and acknowledge that such Personal Information shall be subject to the terms and conditions of this Privacy Notice.

Information You Provide for Potential Employment: When individuals apply for employment with us, we collect additional information (such as resume, cover letter, and desired salary) to start the application process through the Site, or through our third party service providers. During the hiring process, we may collect sensitive personal data (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, ideological activities or views, trade union membership or information specifying the sex life of the individual) as required by U.S. EEO, state requirements and other applicable laws. Furthermore, we may send Personal Information relating to you to certain third parties to carry out verification and security checks. Personal Information relating to you may be transferred to our affiliates and service providers who are located in different jurisdictions.

Information Automatically Collected About Your Use of the Site and/or Interactions with Us: As is true of most websites, we automatically gather technical information about your computer when you visit the Site. This information includes your IP address, browser type, internet service provider, referring/exit pages, operating system and geolocation. We collect device identifiers such as system and performance information in order to assess the operating performance and security of the systems that we maintain. We may also collect information through our use of cookies. We do this to improve marketing and analytics. For more information, please see our Cookie Notice available at https://ollion.com/cookie-notice.

We collect information automatically when you:

• visit, interact with, or use the Site (including when you use your computer or other device to interact with us);
• download content from us;
• open emails or click on links in emails from us;
• interact or communicate with us (such as when you attend our events or when you request customer support); and
• complete an online inquiry form.

Examples of the information we automatically collect include:

• network and connection information, such as the Internet protocol (IP) address used to connect your computer or other device to the Internet and information about your Internet service provider;
• computer and device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting;
• the location of your device or computer;
• authentication and security credential information;
• content interaction information, such as content downloads, streams, and playback details;
• metrics relating to the Site, such as usage, occurrences of technical errors, diagnostic reports, your settings preferences, and other logs;
• the full Uniform Resource Locators (URL) clickstream to, through, and from our website (including date and time) and the content you viewed or searched for, page response times, download errors, and page interaction information (such as scrolling, clicks, and mouse-overs);
• email addresses and phone numbers used to contact us; and
• identifiers and information contained in cookies (see our Cookie Notice).

Service Provider Information Collection and Processing: In some cases, we act as a service provider and perform services such as support and/or engineering services on behalf and under the contractual obligations with our business customers (“Clients”). In our role as a service provider to our Clients, we may handle their data as a data processor or sub-processor on behalf of and for the purposes of our Clients. We have no direct relationship with our Client’s individual customers and end-users (who may include you) whose Personal Information our Client may collect and process or that we may process on behalf of and for the purposes of our Clients.

You should contact your service provider directly (even if they are our Client) to inquire about the Personal Information that they may have about you, or to exercise any other data subject rights that you may have. You understand that your use of their websites and/or services may be subject to terms and policies provided by such service providers (even if they are our Client) and we are not a party to such agreements.

Social Media Platforms or Other Forums, etc.: We may receive certain information that is stored or processed by third parties, such as the social media sites including, but not limited to, Facebook®, X / Twitter® and LinkedIn® when you interact with us through these social media platforms.

The Site may include social media features – such as the Facebook “Like” button – and widgets – such as the “share this” button. These features may collect your IP address as well as details of the pages you are visiting on the Site. Social media features, widgets, and chatbots are either hosted by a third party or hosted by the Site. Each social media platform may have its own privacy policies that specifically govern your use of social media platforms and features.

The Site may also feature bulletin boards, blogs, or forums. While you may comment on these channels, we do not require your personal information to do so. Any Personal Information that you choose to enter via such forums may be read, collected, or used by other visitors to send you unsolicited messages.

The appearance of hyperlinks or the information, products or services contained in a hyperlink on a social media site does not constitute our endorsement of that site and we do not exercise any editorial control over the information found at these sites. In addition, any opinions expressed in posts by users on a social media site do not necessarily represent the positions, strategies or opinions of us or any of our affiliates. Upon using those sites, please note that other privacy notices or policies may apply.

The Site may contain links to other third party websites/platforms/applications. Please note that we do not have any control over such other websites/platforms/applications, and you will be accessing these websites/platforms/applications at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/platforms/applications and those are not governed by this Privacy Notice. You should exercise caution and look at the privacy notice applicable to such websites/platforms/applications.

Accuracy of Information: You undertake that you shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Information you have shared with us, including those of any third party.

Cross-Border Information Transfers

You acknowledge (a) that you are accessing the Site that is based in the United States, (b) that you are providing Personal Information to us in the United States, and (c) that we must adhere to laws of the United States. You agree that Personal Information collected on the Site may be stored and processed in the United States or any other country where our affiliates and service providers maintain facilities, and while in such jurisdictions may be subject to access pursuant to the laws of those jurisdictions.

As a global company, we may transfer Personal Information relating to you to locations outside of your country for processing and storage. We will take appropriate measures to protect such Personal Information during such transfers, in accordance with applicable laws.

How We Protect and Store Personal Information

While we take reasonable steps to help protect the security of your Personal Information, you should be aware that despite our efforts, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee that Personal Information will be protected from interception, misappropriation, misuses or alteration, viruses, worms, Trojan horses, any other vulnerabilities or that it will not be disclosed or accessed by accidental circumstances or by unauthorized actions.

How We Use the Personal Information We Collect; Purposes and Legal Basis for Processing

We value your privacy and are committed to using your Personal Information responsibly and lawfully. Our primary purpose for collecting, using, processing and/or disclosing Personal Information relating to you is to provide you with a secure, smooth, and efficient visitor and client experience.

In addition, we may collect, use process and/or disclose Personal Information relating to you for the following purposes and such other purposes set out in this Privacy Notice:

• Operating the Site: based on our legitimate interest in offering you products and services, ensuring the smooth functioning of our website, and enhancing your overall experience;
• Providing Support and Products and/or Services: to provide support you requested, and to fulfill the products and/or services you requested and our contractual obligations with you;
• Identity Verification: to confirm your identity, verify accounts, and in an effort to ensure the secure operation of the Site;
• Communications and Marketing: to send you alerts concerning product upgrades, special offers, white papers, upcoming events and webinars, surveys, marketing campaigns, newsletter subscriptions, blog update notifications, and other communications about existing and new products and services from us or our partners;
• Security Purposes: for security purposes in an effort to safeguard both your data and our platform;
• Legal Compliance: to respond to legal processes, comply with applicable laws, governmental or regulatory requirements of relevant jurisdictions (and any applicable rules, codes of practice or guidelines), and cooperate with law enforcement and relevant authorities. This processing is necessary for our compliance with applicable legal obligations; and/or
• Recruitment Purposes: (where you apply for a position with us) for recruitment and hiring purposes.

How We Share Personal Information with Third Parties

We partner with and occasionally hire other companies to provide services on our behalf. Personal Information may be shared with these companies, vendors, consultants and other service providers who work for us and need access to your Personal Information to do that work.

We may also share Personal Information relating to you in the following situations:

• with your consent;
• when we believe in good faith that disclosure is necessary to protect our rights or property;
• to protect your safety or the safety of others;
• to investigate fraud or respond to a government, judicial or other legal request;
• to comply with the law;
• in connection with a corporate change, such as an acquisition or merger (and any such third party or resultant entity that receives such Personal Information shall have the right to continue to use such Personal Information in line with the purposes set out in this Privacy Notice); and
• we are a global organization. While we have distinct legal entities (e.g., country subsidiaries) in many parts of the world, our internal processes and infrastructure are international in scope and nature and generally cross-country borders. Accordingly, you should be aware that we may share your personal information with other entities of Ollion and transfer it to countries in the world where we do business. Such data transfers will be in accordance with, and will be as permitted by, applicable data protection law.

Data Retention

We will only retain Personal Information relating to you for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying our processing obligations to you and to satisfy our business and/or legal purposes, including any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider various factors which may include the amount, nature and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process such data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your Personal Information – please refer to “Other Regions’ Privacy Notice” below for further information.

In some circumstances we may de-identify, aggregate and/or anonymize your Personal Information (so that it can no longer be associated with you), in which case we may retain and use this information indefinitely without further notice.

How You Can Access or Change Your Personal Information, etc.

You may contact us at any time to inquire about the Personal Information we collect about you. You may withdraw your consent, request access, correct, or (in some circumstances as set out in “Other Regions’ Privacy Notice”) request deletion of your Personal Information through the following methods (as appropriate):

• by using the options on the Site forms
• General Inquiry Form – here
• California Specific Inquiry Form – here

• by unsubscribing from emails
• Marketing Request Form – here; or

• by contacting us at privacy@ollion.com.

We will respond to your request within a reasonable timeframe. We will process such requests in accordance with applicable laws.

How We Use Tracking Technologies

When you visit the Site, please note that we and our service providers use cookies or similar technologies to expedite the user login process, remember user experience settings, analyze trends, administer the Site, track users’ movements around the Site, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the Site or service. For more information, please see our Cookie Notice available at https://ollion.com/cookie-notice.

We may partner with third party providers to display advertising on the Site or to manage our advertising on other websites. Our third party provider may use cookies or similar technologies in order to provide you with advertising based upon your browsing activities and interests.

If you wish to learn more about opting out of interest-based advertising, please visit external sites: https://www.aboutads.info/choices/, or if located in the European Union, please visit: https://www.youronlinechoices.eu/. However, please note you may still continue to receive generic ads.

How You Can Opt Out of Marketing Communications

We may contact you to alert you of upcoming events, webinars, white papers and promotional campaigns relating to our products and services. If we determine that your explicit consent is needed to send marketing communications, we will obtain that consent before or at the time of Personal Information collection.

We honor your choices with respect to your Personal Information as required by applicable privacy and data protection laws. You can choose whether you wish to receive promotional emails, SMS messages, telephone calls, and postal mail from us by using the opt-out methods (where permitted under applicable laws) described in that communication. For example, if you wish to stop receiving email marketing communications from us, you may click the “unsubscribe” link at the bottom of the relevant email marketing communication or by following the instructions detailed in the communication. Please note that this may not unsubscribe you from all other communications.

If you wish to opt-out of all marketing communications, please contact us using the details provided below.

Marketing Opt-Out Request - here

Collection of Information from Children

We do not knowingly collect Personal Information relating to children. In the event we learn that we have collected Personal Information from anyone under 13 years of age or any other minimum age as stipulated in the relevant sub-section of “Other Regions’ Privacy Notice” (the higher of which, “minimum age”) without prior parental consent, we will take steps to promptly delete such information. By providing your Personal Information to us, through the Site or otherwise, you represent that you are of minimum age or older.

How You Can Contact Us about Privacy

If you have any questions, comments, or concerns about your privacy or this Privacy Notice, or to exercise your rights under applicable privacy and data protection laws, please contact us via email at Privacy@ollion.com or via phone at 1 (888) 317-7920.

Where appropriate, we will verify your request using the information associated with your name and email address.

OTHER REGIONS’ PRIVACY NOTICE

We provide additional information below about the collection, use, processing, disclosure, storage, sharing and/or protection of Personal Information for certain jurisdictions as set forth below.

Data Subject Rights – European Economic Area (EEA) and United Kingdom (UK)

If you are a resident of the EEA, you may have additional rights under the European Union General Data Protection Regulations and UK Data Protection Act 2018 with respect to your personal data (as defined in the relevant legislations), including those as outlined below. For the purposes of this section of the Privacy Notice, the following countries are included: the United Kingdom, Switzerland, and the European Economic Area countries Iceland, Liechtenstein, and Norway.

If you are an EEA individual submitting your personal data to us, you have data subject rights that you should be aware of. As your data controller, you can reach out to us regarding exercising any of your data subject rights.

• Right to access – You have the right to request from us copies of your personal data.
• Right to correction – You have the right to request that we correct any personal data you believe is inaccurate. You also have the right to request us to complete the personal data you believe is incomplete.
• Right to erasure – You have the right to request that we erase your personal data, under certain conditions.
• Right to data portability – You have the right to request that we transfer the personal data that we have collected to another organization, or directly to you, under certain conditions.
• Right to object/restrict processing – You have the right to object to our processing of your personal data, under certain conditions. You also have the right to request that we restrict the processing of your personal data, under certain conditions.
• Right to object to automated individual decision-making, including profiling.
• You have the right to lodge a complaint with a data protection authority.
• UK residents have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. We may need to request specific information from you to help us confirm your identity or also contact you for further information in relation to your request.

Supplemental Notice – California Consumer Privacy Act (“CCPA”)

This Supplemental Notice only applies to our processing of Personal Information that is subject to the CCPA.

The CCPA provides California residents with the right to know what categories of personal information Ollion has collected about them, and whether Ollion disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

The categories of sources from which we collect Personal Information and our business and commercial purposes for using and disclosing Personal Information are set forth in “What Data We Collect and How We Collect It”, “How We Use the Personal Information We Collect; Purposes and Legal Basis for Processing” and “How We Share Personal Information with Third Parties” above, respectively. We will retain personal information in accordance with the time periods set forth in “Data Retention.”

Additional Disclosures for California Residents

Rights under the CCPA. Under the CCPA, you have the right to:

• Confirm Whether Ollion is Processing Your Personal Information (also known as the “right to know”);
• Request Access to or Portability of Your Personal Information, including: (i) obtaining access to or a copy of your Personal Information; and (ii) obtaining an electronic copy of Personal Information that you have provided to us, or asking us to send that Personal Information to another company in a structured, commonly used, and machine-readable format (also known as the “right of data portability”);
• Request Correction of your Personal Information; and
• Request Deletion of your Personal Information.

If you are a California resident and would like to exercise any of these rights, please contact us as set forth in “How You Can Contact Us about Privacy” above. We will process such requests in accordance with the CCPA.

Disclosure Regarding “Sales” of Personal Information under the CCPA. In the preceding twelve months, Ollion, Inc. has not “sold” (as defined in the CCPA) any Personal Information, nor does Ollion have actual knowledge of any “sale” (as defined in the CCPA) of Personal Information of minors under 16 years of age.

Disclosure Regarding Cross-Context Behavioral Advertising under the CCPA. In the preceding twelve months, Ollion has not “shared” (as defined in the CCPA) any Personal Information for “cross-context behavioral advertising” (as defined in the CCPA), nor does Ollion have actual knowledge of any “sharing” of Personal Information of minors under 16 years of age for “cross-context behavioral advertising”.

Disclosure Regarding Sensitive Personal Information. Ollion only uses and discloses sensitive Personal Information for the following purposes:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted Personal Information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at Ollion and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Ollion, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Ollion.
• For purposes that do not infer characteristics about individuals.

Disclosure Regarding De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, the CCPA.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “How You Can Contact Us about Privacy” above for additional instructions.

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request submitted under the CCPA. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. Examples of our verification process may include asking you to provide the email address we have associated with you and following the instructions we provide to you.

Disclosure Regarding Opt-Out Preference Signals. Ollion does not “sell” Personal Information or “share” Personal Information for “cross-context behavioral advertising” so it does not respond to opt-out preference signals.

Personal Data Protection Under The Personal Data Protection Act 2012 of Singapore (“Singapore PDPA”)

The Singapore PDPA applies to the collection, use and disclosure of Personal Data (where this defined term is used in this section, it shall have the meaning as defined under the Singapore PDPA) by organizations (as defined thereunder). The Privacy Notice as stated would apply to such Personal Data as well as the following specific provisions:

●WITHDRAWAL OF CONSENT

If you wish to withdraw your consent in respect of the collection, use or disclosure by us of any Personal Data about you for any purpose, you may contact us in the manner set out in the section titled “How You Can Contact Us about Privacy”.

Please allow a reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed, and for us to notify you of the likely consequences of such withdrawal. Do note that we will not be liable for the consequences arising from your request to withdraw your consent. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our solutions, products or services to you and we shall, in such circumstances, notify you before completing the processing of your request.

Upon withdrawal, we will cease (and require our data intermediaries and agents to cease) collecting, using or disclosing the Personal Data unless such collection, use or disclosure (as the case may be) without your consent is required or authorized under the Singapore PDPA or other written law.

●ACCESS & CORRECTION

Where you have submitted an access request to for the Personal Data about you that is in our possession or under our control, and information about the ways in which such Personal Data has been or may have been used or disclosed by us within a year before the date of the request, we may charge you a reasonable fee to process such access request and will provide you with a written estimate of such fee before processing your request.

Where you have submitted a request for us to correct an error or omission in your Personal Data that is in the possession or under our control and unless we are satisfied on reasonable grounds that a correction should not be able or exceptions apply, we will: (i) correct the Personal Data as soon as practicable; and (ii) send the corrected Personal Data to such other organizations to which the Personal Data was disclosed by us (or with your consent, to only specific organizations) within one year before the date the correction was made, unless those other organizations do not need the corrected Personal Data for any legal or business purpose.

●DATA PROTECTION OFFICER

If you have any questions or concerns or grievances regarding this Privacy Notice, you can reach out to our appointed Data Protection Officer at Privacy@ollion.com. We will respond to such requests in a timely manner.

Personal Data Protection under the Personal Data Protection Act 2010 of Malaysia (“Malaysia PDPA”)

The Malaysia PDPA applies to all Personal Data (where this defined term is used in this section, it shall have the meaning as defined under the Malaysia PDPA) that is collected, used or disclosed: (i) in Malaysia; or (ii) outside of Malaysia if there is intention for the Personal Data to be further processed in Malaysia.

The Privacy Notice as stated would apply to such Personal Data as well as the following specific provisions:

●DEFINITION OF CHILD

For the purpose of this Privacy Note, a child refers to anyone who is under the age of 18 years old.

●WITHDRAWAL OF CONSENT

It is obligatory for you to provide us with all Personal Data requested (unless stated otherwise) and we may not be able to provide you with your services if you fail to provide us with the Personal Data requested.

You have the right to withdraw your consent for us to continue processing your Personal Data and we will respond to your request within a reasonable period of time.

●ACCESS & CORRECTION

You have the right to access, correct and update your Personal Data and we will comply with such request within the time period stipulated under the Malaysia PDPA save in exceptional circumstances as prescribed under the Malaysia PDPA. We also reserve the right to charge you a fee to provide you with a copy of the Personal Data requested and will provide you with a written notice of such fee before processing your request.

●DATA PROTECTION OFFICER

If you have any questions or concerns or grievances regarding this Privacy Notice, you can reach out to our appointed Data Protection Officer at Privacy@ollion.com or via phone at 1 (888) 317-7920. We will respond to such requests in a timely manner.

Please click here for the Malay Language version of this Privacy Notice./ Sila klik di sini untuk versi Bahasa Melayu Notis Privasi ini.

Personal Data Protection under Law No.27 of 2022 on Personal Data Protection of Indonesia (“Indonesia PDP Law”)

The Indonesia PDP Law applies to all Personal Data (where this defined term is used in this section, it shall have the meaning as defined under the Indonesia PDP Law) that is collected, used or disclosed: (i) in Indonesia, and/or (ii) outside of Indonesia to the extent that the Personal Data is owned by the Indonesian citizen, or the collection of Personal Data has legal consequences within Indonesia.

The Privacy Notice as stated would apply to such Personal Data as well as the following specific provisions:

●DEFINITION OF CHILD

For the purpose of this Privacy Notice, a child shall be anyone who is under the age of 18 years old and has not married.

●DATA SUBJECT’S RIGHTS

As your data controller, you can reach out to us regarding exercising any of your data subject rights below in accordance with Articles 5 – 13 of Indonesian PDP Law:

a) Right to information;

b) Right to rectification;

c) Right to access;

d) Right to erasure;

e) Right to withdraw consent;

f) Right not to be subject to a decision based solely on automated processing;

g) Right to restrict processing;

h) Right to compensation; and

i) Right to data portability;

Please “click” here for the Bahasa Indonesia version of this Privacy Notice /

Mohon “klik” di sini untuk versi Bahasa Inggris dari Pemberitahuan Kebijakan

Perlindungan Data.

Privacy Laws of India

This Privacy Notice is aligned in accordance with requirements of the applicable laws in India such as the Information Technology Act 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.

●DEFINITION OF CHILD

For the purpose of this Privacy Notice, a child shall be anyone who is under the age of 18 years old.

●YOUR RIGHTS

a) You have the right to access and review the Personal Information in our possession.

b) If the Personal Information is found to be inaccurate or deficient, you have the right to have us correct or amend any such Personal Information.

c) You have an option to withdraw consent at any time where we are relying on consent to process Personal Information.

Depending on the nature of the request, we may ask you to complete a Personal Information request form or seek certain details to verify the request. All requests for Personal Information will be handled within a reasonable period of time. If you would like to exercise any of these rights, please contact us as per “How You Can Contact Us about Privacy” section.

●TRANSFER OF YOUR PERSONAL INFORMATION ACROSS BORDERS:

We have a worldwide presence in countries including but not limited to Singapore Malaysia, Indonesia and the United States. The Personal Information we collect might be processed outside India with adequate safeguards. You hereby acknowledge and consent to such data transfers.

●GRIEVANCE REDRESSAL OFFICER

If you have any questions or concerns or grievances regarding this Privacy Notice, you can reach out to our appointed Grievance Redressal Officer at privacy@ollion.com. We will respond to such requests in a timely manner.