Privacy Policy

Effective Date: [November 17th 2025] Last Updated: [November 17th 2025]

1. Introduction

We at Oten Inc. (“Oten”, “we”, “us”, “our”) provide the Oten workspace and its product — a developer portal supporting application creation, publishing, monetization, identity/auth, access control, and distribution; a Store as an end user. This Privacy Policy describes how we collect, use, disclose, and protect your personal data when you:

• Use the Oten workspace as a developer or end-user;

• Sign up for, access or publish an application via Oten developer portal; or

• Interact with the workspace's websites, portals, services, or interfaces.

2. What data we collect

2.1 Personal Information Depending on your role (Developer, Workspace Admin, Organization Admin, End User, or Viewer), we may collect:

• Contact and identity details (e.g., name, email address, organization, job title, phone number and so on)

• Account credentials and role assignment information

• Payment and billing information (e.g., billing address, invoice information, payment method metadata and so on)

• Usage data (which apps you publish, subscribe to, access, your role actions and so on)

• Developer and workspace metadata (workspace name, roles granted, permissions assigned)

2.2 Non-Personal / Technical Information We also collect or receive:

• Device and browser information with OS, version, browser type, screen resolution

• Log information and analytics of timestamps, feature usage, subscriber counts, API call volumes

• Cookies and tracking technologies to support authentication, security, analytics, preferences

3. How we use your data

We use your personal and non-personal information to:

• Provide, maintain and improve the Platform’s features with developer portal, marketplace, identify

• Authenticate and authorize users, enforce role-based access control (RBAC) and manage identities via our IDP/IAM services

• Process payments, subscriptions, billing, invoicing and payout flows

• Monitor platform health, usage trends, security threats, audit logs and compliance

• Communicate with you (account notifications, service updates, policy updates)

• Enable app usage: for example, when you publish apps, subscribe, or are granted access by your organization or workspace

4. Data sharing and disclosure

We do not sell your personal information to third parties. We may share data when necessary including:

• With service providers under contract such as payment processors, cloud hosting, analytics providers that support the Platform

• With your organization or workspace administrators (for role/privilege management)

• To comply with legal obligations, respond to lawful requests, protect rights, property, or safety of Oten users or the public

• In the event of merger, acquisition or sale of assets of Oten.

5. Data retention and deletion

We retain personal data only as long as reasonably necessary for the purposes described or as required by law. Upon account termination or role removal, we will securely delete or anonymize your data, except where required for audit, compliance or legitimate business needs.

6. Your rights and choices

Depending on your region, you may have rights including:

• Accessing the personal information we hold about you

• Correcting or updating inaccurate or incomplete data

• Requesting deletion of your personal data (subject to legal or contractual exceptions)

• Withdrawing consent for certain processing (where applicable)

• Choosing or changing your notification preferences, cookies and tracking settings

To exercise any of these rights, please contact us. We will respond in accordance with applicable law.

7. Cookies and tracking

We use cookies and similar tracking technologies to support core functionality (authentication, security), preferences, analytics, and user experience. You may disable or manage cookies via your browser settings, but please note disabling essential cookies may limit your ability to use the Platform fully.

8. Security measures

We implement appropriate technical and organizational safeguards to protect your data of encryption in transit and at rest, access controls, regular security reviews, role-based monitoring, audit logs and multi-factor authentication where applicable. Nevertheless, no system is entirely risk-free, and we cannot guarantee absolute security.

9. International transfers

As a global platform, your personal data may be transferred to, stored and processed in different countries, including where our service providers or operations are located. We ensure that appropriate safeguards are in place of standard contractual clauses, equivalent protections,… when transferring your data internationally.

10. Children and age limits

The Platform is not intended for children under [ 16 or as per local law ]. We do not knowingly collect personal information from children without parental consent. If you become aware that a child has provided us with personal data, please contact us and we will delete that information.

11. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in practices or legal requirements. We will notify you by posting the revised policy with a new “Last Updated” date. We encourage you to review this document regularly.