1. Data Controller

OctaGrid (sole proprietorship, Japan)
Contact: legal@octagrid.net

2. Personal Data We Collect

• Account data: first name, last name, email address, and hashed password

• Organization data: organization name, description, contact details, and location

• Usage data: scenario transcripts, AI persona interactions, performance evaluation results, and metric scores

• Technical data: IP address, browser type, and session information

• Analytics data: page interaction data collected via Microsoft Clarity on the landing page (see Section 7)

3. Purpose of Use

We collect and use personal data for the following purposes:

• To provide, operate, and maintain the Service

• To authenticate users and manage accounts

• To generate AI persona interactions and performance evaluations

• To communicate with users regarding their account, support requests, and Service updates

• To monitor and improve platform performance and user experience

• To comply with applicable legal obligations

• To detect and prevent fraud, abuse, or violations of our Terms of Service

4. Third-Party Data Processors

We use the following third-party processors to deliver the Service. These processors act on our behalf and are bound by appropriate data processing agreements:

Conversation data processed through Azure AI Foundry (Azure OpenAI) is subject to Microsoft’s data processing addendum. We encourage you to review Microsoft’s Trust Center for details on how Microsoft handles this data.

5. Data Storage and International Transfers

Personal data is primarily stored in Microsoft Azure Japan East. Some data may currently reside in Azure India Central as part of an ongoing infrastructure migration. We take appropriate measures to ensure that all data transfers comply with applicable data protection laws, including APPI requirements regarding the provision of personal information to third parties in foreign countries.

6. Data Retention

• Account and organization data: retained for the duration of the active account, and for a reasonable period thereafter as required by law or for dispute resolution purposes.

• Scenario and evaluation data: retained for the duration of the subscription and a reasonable period following account termination.

• Analytics data: subject to Microsoft Clarity's own retention policies.

• You may request deletion of your data at any time by contacting us (see Section 9).

7. Cookies and Analytics

We use Microsoft Clarity on our landing page to understand how visitors interact with our site and to improve performance. Microsoft Clarity may use cookies and similar tracking technologies to collect behavioral data such as mouse movements, clicks, and session replays.

You can manage cookie preferences through your browser settings. To opt out of Microsoft Clarity specifically, you may use Microsoft’s opt-out tool.

We plan to introduce additional analytics tools in the future to better understand platform usage and performance. This policy will be updated accordingly before any such tools are activated.

8. Your Rights under APPI

In accordance with Japan’s Act on the Protection of Personal Information, you have the right to:

• Request disclosure of your retained personal data

• Request correction of inaccurate or incomplete personal data

• Request cessation of use or erasure of your personal data where the data is no longer necessary or was collected unlawfully

• Request cessation of provision of your personal data to third parties

• Lodge a complaint with the Personal Information Protection Commission (PPC) of Japan

To exercise any of these rights, please contact us at legal@octagrid.net. We will respond within a reasonable timeframe and in accordance with our obligations under APPI.

9. Data Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, or disclosure. This includes leveraging Microsoft Azure’s security infrastructure, access controls, and encrypted data storage. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of significant changes via email or a prominent notice within the Service. The effective date at the top of this page indicates when the policy was last revised. We encourage you to review this policy periodically.

11. Contact

For privacy-related inquiries, requests, or complaints, please contact:

OctaGrid
Email: legal@octagrid.net