PRIVACY POLICY

PRIVACY POLICY FOR OKA BEHAVIOUR WEBSITES
AND DATA PLATFORMS
Please remember that your use of the Services is at all times subject
to the Terms of Use. Any terms we use in this Privacy Policy without
defining them have the definitions given to them in the Terms of Use.
Hello, and welcome to our Privacy Policy. This Privacy Policy helps
you to make informed decisions about your relationship with us, so
please read it carefully. We hope you’re sitting comfortably and getting
ready for some great assessments and recommendations. Here we
go…
SUMMARY
Thank you for working with Oka Behaviour, LTD (“Oka”). This is our
Privacy Policy. Before we dive into the more detailed explanations, we
would like to summarize a couple of key items because we know how
important they are and want to give you insights into your rights under
the GDPR regulations.
This Privacy Policy is here to do a couple of things:
1. Stipulate your rights and responsibilities forthcoming out of
working with Oka;

2. Explain exactly what we do with your data and how we use it to
help you with advice, recommendations, or suggestions that you
give permission to or request from us;
3. Make sure that you understand what data we collect with your
permission, and what we do – and not do – with it;
4. Determine accountability for protecting your rights and your
privacy under this policy;
All the information we collect is related to providing the Oka services
and its features. In these terms and conditions, any reference to Oka
shall mean any applicable company or site directly owned or co-
owned by Oka (https://app.oka.life).
We do not knowingly collect or solicit personal information from
anyone under the age of 16. If you are under 16, please do not
attempt to register for the Services or send any personal information
about yourself to us. If we learn that we have collected personal
information from a child under age 16, we will delete that information
as quickly as possible. If you believe that a child under 16 may have
provided us personal information, please contact us at info@oka.life.
Broadly speaking, there are three categories of information we collect:
1) information that we must have in order for you to use our platforms;
2) information that we can use to provide analytics, assessments,
additional features and improved experiences, if you choose to share

that information with us; and 3) publicly available information from
which we directly make inferences.
The first category includes:
• Registration Information, including name, birth date (age), email,
address, and other information that you provide when you sign
up for our services;
• Your location, so we can place you with geographically specific
happenings based on where you are or want to be.
• Technical and sensor information necessary to operate the OKA
platform. This includes the type of browser and device you use,
data from the touchscreen, and information from your device’s
gyroscope and accelerator sensors. This enables you to control
the Oka platform and allows us to do simple things like scale the
platform to your device, rotate videos, and recommend tasks
based on whether you’re sitting still or are on the road.
We will never gather or use your personal data without first getting
your explicit permission. The gathering of personal data enables us to
help you create a profile for you and you alone. We will not share any
of your personal data with any third party unless you have given us
explicit permission to do so.

The second category includes information that enables us to offer you
additional features and advice. Amongst other applications, this data
enables us to give you advice on courses of action to achieve your
goals in life. While using our platform you will be able to choose
exactly which data you wish to commit and therefore which features
you wish to enable. Given your explicit permission, we may share
some of this data with any of our Users, Partners or Clients to enable
them to offer you relevant opportunities that fit into your preferences.
Here are some examples:
Non-sensitive demographic data: such as age group, nationality,
language, and city of residence.
Professional profile related data related to your career and
personal development over time:
oProfessional background, companies you have worked for,
roles you have had.
oEducational background, schools you went to, courses you
followed, grades.
oData related to the preferences you may have for your
future career or education but also for your social
environment and general wishes.
Any form or survey information gathered through our research or
platform:

oWork attitudes, cultural profile, working behavior, work style
preferences, matching preferences, your interests.
oCompanies you are interested in, schools you are
interested in, skills you want to learn.
oPersonality and other standardized testing data such as g-
factor.
Your photos: we will only access images that you specifically
choose, and we will never scan or import your photo library or
camera roll. This allows you to choose individual pictures to
change your profile picture. You can stop sharing photos and
revoke access at any time.
Your contacts: we will never scan or import your contacts unless
you ask us to. If you choose to do so, we will only use your
contact information to help you find or nominate friends or
contacts who use Oka.
The distinction between these two categories is important. Information
in the first category is information you must provide in order to use
Oka. When you agree to our Privacy Policy, you give us the right to
collect this information and use it for the purposes described.
Information in the second category is information we will only collect if
you explicitly give us permission to do so in the future. For this second
category of information, we will ask for your permission before first
accessing it, we will describe how we will use it if you give us

permission, we will only use the information for the purpose we
described, and you will always have the ability to change your mind
and revoke that permission. Acceptance of our Privacy Policy does
not mean you have granted us permission to access or use
information in the second category; we’re just explaining to you that
one day we might ask you for that permission.
The final category includes any non-copyrighted information, not
hosted or facilitated by Oka or any of its websites, that is made
accessible, retrievable. or publicly available online by the Data
Subject. According to article 9 paragraph 2 of the General Data
Protection Regulation (EU 2016/697) this data falls under the
responsibility of the Data Subject and, as long as this data remains
public or publicly available, no direct rights, privileges, or liabilities can
be inferred from any data stored or derived from this category.
We will be clear with you about how and when we might share
information. In some contexts, we will share certain information. For
example, like most services, if you sign up for Oka through a third
party like LinkedIn, Gmail, or Facebook, we share some information
with them and they share some information with us in order to enable
your account. And we also share de-identified (anonymous)
information with our Human Resources Industry and Academia
partners to help them understand how the company they run is

performing, with research partners who help us with knowledge
creation efforts, and with advertisers that allow us to offer a free
service. There also may be times when you want us to share
information. For example, when you want to nominate or invite a
friend, you might want some data to be visible to your friends… and
you might not. Similarly, you can ask us to share information (like your
email address) with employers or job search sites, or other partners
who may want to directly send you opportunities, news or promotional
offers, but you can also revoke that permission at any time.
We hope this helps you to understand our privacy commitments to
you. Now, the remaining details await you below, but please
remember that this Summary is part of the Privacy Policy itself — it’s
our promise to you. If you ever have any questions or concerns, then
please let us know at info@oka.life.
Throughout this Privacy Policy, we refer to the Oka Service or the
Service. These terms are defined in our Terms and Conditions of Use
(the “Terms and Conditions of Use”).
DATA PROTECTION OFFICER
Zal Dordi

Little Court Penshurst Road Bidborough, Tunbridge Wells, England
TN3 0XJ
Email: zal@oka.life
Tel. +44 7583 102225
USAGE
All data mentioned above can be used for different purposes. By
signing up to our services you agree to our Privacy Policy and allow
us to generate reports and different sets of analyses on your profile.
Unless given explicit permission, all data stemming from this initial
agreement shall exclusively be used to generate your private profile
that, without explicit permission, will remain invisible to third parties,
partners, or other users.
Given further permission, your data will be used to match you with
different events, opportunities, partners, and users. In accordance with
Article 13 and 15 of the General Data Protection Regulation (EU
2016/697) you retain the right to choose which data you will use for
these operations.
SHARING

Only given explicit permission we share Personal Data with
classmates, colleagues, employers, universities, vendors, third-party
service providers and agents who work on our behalf and provide us
with services related to the purposes described in this Privacy Policy
or our Terms of Service.
We also share Personal Data when necessary to complete a
transaction initiated or authorized by you or provide you with a product
or service you have requested. In addition to those set forth above,
these parties also include:
Other users (where you post information publicly or as otherwise
necessary to effect a transaction initiated or authorized by you
through the Services)
Social media services (if you interact with them through your use
of the Services)
Third-party business partners who you access through the
Services (e.g. third party applications)
Other parties authorized by you
We also share information with third parties when you have given us
consent to do so (as indicated at the point such information is
collected).
We also share Personal Data when we believe it is necessary to:

Comply with applicable law or respond to valid legal process,
including from law enforcement or other government agencies
Protect us, our business or our users, for example, to enforce
our Terms of Service, prevent spam or other unwanted
communications and investigate or protect against fraud
Maintain the security of our products and services
If we choose to buy or sell assets, user information is typically one of
the transferred business assets. Moreover, if we, or substantially all of
our assets, were acquired, or if we go out of business or enter
bankruptcy, user information would be one of the assets that are
transferred or acquired by a third party, and we would share Personal
Data with the party that is acquiring our assets. You acknowledge that
such transfers may occur and that any acquirer of us or our assets
may continue to use your Personal Information exclusively as set forth
in this policy.
RETAINING
We retain Personal Data about you for as long as you have an open
account with us and for three years after you close your account. In
some cases we retain Personal Data for longer, if doing so is
necessary to comply with our legal obligations, resolve disputes or
collect fees owed, or is otherwise permitted or required by applicable

law, rule or regulation. Afterward, we retain some information in a
depersonalized or aggregated form but not in a way that would identify
you personally. However, user signup data (your name, your email
address, and the fact that you were an Oka user) may be retained in
third-party analytics services beyond closure of your account, unless
you request that your data be deleted.
COOKIES
Whenever you interact with our Services, we automatically receive
and record information on our server logs from your browser or device
which may include “cookie” information. “Cookies” are identifiers we
transfer to your browser or device that allow us to recognize your
browser or device and tell us how and when pages and features in our
Services are visited and by how many people.
SECURITY
We seek to protect Personal Data using appropriate technical and
organizational measures based on the type of Personal Data and
applicable processing activity. For example, Oka is continuously
implementing and updating administrative, technical, and physical
security measures to help protect your information against

unauthorized access, loss, destruction or alteration. Some of the
safeguards we use to protect Personal Data are firewalls, data
encryption, and information access controls. For additional information
and requests, please contact: info@oka.life
YOUR RIGHTS
You have, according to article 13 and article 15 of the General Data
Protection Regulation (EU 2016/697), certain rights with respect to
your Personal Data, including those set forth below. For more
information about these rights, or to submit a request, please
email info@oka.life. Please note that in some circumstances, we may
not be able to fully comply with your request, such as if it is frivolous or
extremely impractical, if it jeopardizes the rights of others, or if it is not
required by law, but in those circumstances, we will still respond to
notify you of such a decision. In some cases, we may also need you to
provide us with additional information, which may include Personal
Data, if necessary to verify your identity and the nature of your
request.
Access: You can request more information about the Personal
Data we hold about you and request a copy of such Personal

Data. You can also access certain of your Personal Data by
accessing your account settings.
Rectification: If you believe that any Personal Data we are
holding about you is incorrect or incomplete, you can request
that we correct or supplement such data. You can also correct
some of this information directly by accessing your account
settings.
Erasure: You can request that we erase some or all of your
Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal
Data based on your consent (as indicated at the time of
collection of such data), you have the right to withdraw your
consent at any time. Please note, however, that if you exercise
this right, you may have to then provide express consent on a
case-by-case basis for the use or disclosure of certain of your
Personal Data, if such use or disclosure is necessary to enable
you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a
machine-readable format. You can also request that we transmit
the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to
the further use or disclosure of your Personal Data for certain
purposes.

Restriction of Processing: You can ask us to restrict further
processing of your Personal Data.
Right to File Complaint: You have the right to lodge a
complaint about Oka’s practices with respect to your Personal
Data with the supervisory authority of your country or the UK.
TRANSFERS
The Services are hosted and operated in the United Kingdom through
Oka and its service providers, and if you do not reside in the UK, laws
in the UK may differ from the laws where you reside. By using the
Services, you acknowledge that any Personal Data about you,
regardless of whether provided by you or obtained from a third party,
is being provided to Oka in the UK and will be hosted on UK servers,
and you authorize Oka to transfer, store and process your information
to and in the UK, and possibly other countries. You hereby consent to
the transfer of your data to UK pursuant to the GDPR.
Oka is committed to the General Data Protection Principles
(“Principles”) of (1) notice, (2) consent, (3) accountability for onward
transfer, (4) security, (5) data integrity and purpose limitation, (6)
access and (7) recourse, enforcement and liability with respect to all
Personal Data. The Principles require that we remain potentially liable

if any third party processing Personal Data on our behalf fails to
comply with these Principles (except to the extent we are not
responsible for the event giving rise to any alleged damage). Oka’s
compliance with the GDPR is subject to the investigatory and
enforcement powers of the European Commission.
LINKS
Our Service may contain links to other sites that are not operated by
us. If you click on a third party link, you will be directed to that third
party’s site. We strongly advise you to review the Privacy Policy of
every site you visit. We have no control over and assume no
responsibility for the content, privacy policies, or practices of any third
party sites or services
CHANGES TO THE POLICY
We may update our Privacy Policy from time to time. We will notify
you of any changes by posting the new Privacy Policy on this page.
You are advised to review this Privacy Policy periodically for any
changes. Changes to this Privacy Policy are effective when they are
posted on this page. If a revision is material the new terms will enter

into force at least 30 days after they’ve been noticed. What constitutes
a material change will be determined at our sole discretion.