Legal

Privacy Policy

Effective date: 14 May 2026

Last updated: 9 September 2026

Operator / service provider: OC Global Technology Sdn Bhd, Johor Bahru, Malaysia

Controller roles: Participating Schools are controllers for school-provisioned student, staff, and parent records. O’Care is controller for account operations, security, support, and legal-compliance data.

Applies to: O’Care mobile application (iOS & Android) and the O’Care administration dashboard.

This Privacy Policy explains how OC Global Technology Sdn Bhd ("O’Care", "we", "us", or "our") collects, uses, discloses, retains, and protects personal data of students, parents, teachers, school coordinators, and administrators who use the O’Care platform (the "Service"). We act as a data processor on behalf of participating schools (the "School", which is the data controller for student, staff, and parent records) and as an independent data controller for the limited operational data we collect directly (account credentials, support requests, technical logs).

Summary for parents and guardians. O’Care is a school safety and wellbeing app. We collect only what the School and the app need to keep students safe. We do not sell personal data. We do not use student content to train third-party AI models. You can review, correct, or delete an account at any time — see Section 10.
Not a medical device or emergency service. O’Care is a wellbeing and safeguarding support tool for schools. It is not a medical device, diagnostic tool, emergency-response service, or substitute for professional counselling, medical advice, or emergency assistance. AI-generated risk scores are screening signals only, may be inaccurate, and are used to assist authorised human reviewers. Content assessed as high or critical risk is withheld from other users pending that review — an automated step described in Section 6. No clinical, disciplinary, or enforcement decision is ever made automatically; those are always made by a person. In a life-threatening emergency, contact your local emergency number (Malaysia: 999) first. We do not display third-party advertising, do not use personal data for advertising or marketing profiling, and do not track users across apps or websites operated by other companies.

1. Scope & Roles

This policy covers personal data processed through the O’Care iOS and Android applications, the O’Care administration dashboard, the O’Care API, and the O’Care AI content-moderation service.

For data uploaded or generated by School users in the course of using the Service, the School is the data controller and O’Care is the data processor under a written Data Processing Addendum (DPA). For account-level data (login credentials, audit logs, support correspondence), O’Care is the data controller.

2. Data We Collect

The categories below align with Apple App Privacy and Google Play Data Safety disclosures.

CategoryExamplesLinked to identity?
Contact InfoName, email, school affiliation, roleYes
IdentifiersUser ID, device ID (for push), session tokensYes
User ContentDiary entries, posts, chat messages, attachments, mood check-ins, SOS alertsYes
Health & WellbeingSelf-reported mood scores, distress indicators from AI moderationYes
Sensitive InfoEmergency contacts, AI-derived safety risk levelsYes
LocationWhen you trigger an SOS, O’Care attaches your device’s location to that alert so responders can find you. We request the lowest accuracy that still serves that purpose. Location is stored only with the SOS alert and any case opened from it, is visible only to the responders your School has authorised, and is retained for as long as that alert or case is retained — see the retention schedule in Section 10.Yes
Contact Info (device)When you choose to add an emergency contact by importing it, O’Care reads your device’s contact list on your device to show you a picker. Only the contact you select is saved to your account. You can add emergency contacts by typing them instead, and you can revoke contacts access in your device settings at any time.Yes
Photos & MediaAvatar uploads, post and message attachments, voice notesYes
Usage DataScreens viewed, feature interactions, crash logs, performance metricsYes
DiagnosticsApp version, OS, device model, error stack tracesYes
Administrative & audit dataRole, permissions, school affiliation, alert review actions, case escalation status, timestamps, IP/device/session logs, communications with supportYes

We do not collect: precise GPS coordinates outside SOS, calendar, microphone or camera streams (only user-initiated captures), browsing history, or financial data.

3. Sources of Data

4. Purposes & Legal Bases

PurposeLegal basis (GDPR Art. 6)
Provide and operate the Service (accounts, feed, chat, diary)Performance of a contract; legitimate interests
Safety features — SOS, emergency contacts, AI moderationVital interests of the data subject; legitimate interests of the School
Wellbeing analytics for schools and parentsPerformance of a contract; legitimate interests
Authentication, audit logging, abuse preventionLegitimate interests; legal obligation
Push notifications for messages, alerts, and announcementsPerformance of a contract; consent (where required)
Service improvement, debugging, security monitoringLegitimate interests
Comply with court orders, regulators, child-protection lawLegal obligation; vital interests

Where processing relies on consent, you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Health and wellbeing data

O’Care processes wellbeing-related data, such as mood check-ins, distress indicators, SOS alerts, and AI-derived risk signals, solely to provide school safeguarding and wellbeing support. O’Care does not provide medical diagnosis, treatment, or clinical decision-making, and does not use or share wellbeing data for advertising, marketing profiling, or any unrelated purpose.

5. Device Permissions

O’Care requests the following device permissions on a strict need-to-use basis. Each can be revoked from the operating system's settings.

PermissionWhyWhen asked
CameraProfile photo, posts, chat attachmentsWhen you tap the camera button
Photo LibraryUpload media to posts, chat, profileWhen you tap the gallery button
MicrophoneVoice notes in chatWhen you start a voice recording
NotificationsDeliver messages, SOS responses, and admin alertsAt first launch
LocationAttach your location to an SOS alert so responders can find youWhen you trigger SOS
ContactsImport an emergency contact without retyping itWhen you tap to import a contact

6. AI Content Moderation

To support safeguarding, O’Care runs automated content moderation on diary entries, posts (including any images attached to a post), chat messages (including any attachments), and status/story content. The AI service is operated by us on infrastructure we control. User content is not used to train any third-party model.

Whose content is moderated. Content authored by students and by teachers is screened. Teachers are data subjects in their own right: posts and chat messages you author as a teacher run through the same distress, toxicity and cyberbullying classifier as a student’s, and are subject to the same automated withholding described below. Content authored by parents, coordinators and administrators is not screened by this pipeline.

How it works

In-app disclosure

This Privacy Policy is the disclosure, and it is reachable in the app from Settings → Privacy Policy. In addition, every diary entry, post and message you author carries an AI badge showing the risk level the analysis assigned and a short machine-generated reason, and the badge opens a sheet explaining what the assessment does and does not do. From that sheet you can submit "Tell us this is wrong" feedback. AI scores do not automatically create disciplinary action or formal cases.

What we send and what we keep

Human oversight

Only named school coordinators and O’Care administrators with role-based access can open alerts.

Automated withholding. Where the analysis indicates a high or critical risk, the content is withheld from other users pending human review. This is an automated step, taken to prevent harm while a person assesses the content. It does not by itself create a case, impose any penalty on your account, or result in disciplinary or law-enforcement action — those decisions are always made by a person. You may contest any AI assessment using the "Tell us this is wrong" control in the app, and request human review under Section 11.

Crisis support

When an own diary entry is rated CRITICAL, O’Care surfaces an in-app sheet with crisis resources (Talian Kasih 15999, Befrienders Malaysia +60 3-7956 8145, and a link to your school counsellor) before any other action is taken.

7. User-Generated Content Safety

O’Care hosts user-generated content (posts, diary entries, chat messages, media attachments, and voice notes). To reduce harm we combine automated filtering (see Section 6) with human moderation and in-app safety controls.

For urgent content-safety concerns email support@ocare.ocgt.app.

8. Disclosure & Sub-processors

We do not sell personal data and do not share it for cross-context behavioural advertising. We disclose personal data only to:

Website analytics cookies

The public website at ocare.ocgt.app — the homepage, the download page, and these legal pages — uses Google Analytics 4, loaded through Google Tag Manager, to measure aggregate traffic: pages viewed, referring source, approximate location by country and city, device and browser type, and whether a visitor submitted the contact form. This applies to the public website only. The O’Care mobile app and the administration dashboard do not load Google Analytics, and no student, parent, or staff account data is sent to it.

Google Analytics sets first-party cookies (_ga and _ga_<id>) holding a randomly generated visitor identifier, which expire after 24 months. The legal basis is legitimate interests — understanding which channels bring schools to us. We have configured the property so that:

Because of that configuration, our commitment not to track users across apps or websites operated by other companies still holds: the measurement is first-party and confined to this one website.

To opt out, install Google's Analytics Opt-out Browser Add-on or block cookies for this domain in your browser. Nothing on the website depends on analytics cookies — the contact form, the legal pages, and the app download links all work with them blocked.

Website contact form

The contact form on the public website is protected by Cloudflare Turnstile, which receives your IP address and behavioural signals from your browser in order to distinguish you from an automated bot. Your submission is then delivered to an O’Care mailbox using the Google Gmail API. The delivered message contains the details you typed together with your IP address and browser user agent, which we record so that we can identify and block abuse of the form. Enquiries are retained in that mailbox for as long as needed to answer them and to keep a record of the correspondence. This applies to the public website only — email sent by the app and the dashboard uses AWS Simple Email Service and does not pass through Gmail.

Categories of sub-processor

We use sub-processors in the following categories. The register — every named vendor, with its purpose, the data categories it receives, the region it processes in, and its data-processing-agreement status — is maintained as an annex to this policy at ocare.ocgt.app/subprocessors and forms part of it. Keeping the names there rather than here means a vendor change updates the annex without re-issuing this notice; we still give schools at least 30 days' notice before adding a new sub-processor.

9. International Transfers

Personal data is primarily hosted in Malaysia. A defined set of sub-processors processes data outside Malaysia: Cloudflare R2 (media storage), Expo Push Service together with Firebase Cloud Messaging and Apple Push Notification service (push delivery), Sentry (mobile crash reporting), AWS Simple Email Service (transactional email), and Google Analytics 4, Google Tag Manager, Google Fonts, Cloudflare Turnstile and the Gmail API (public website only).

The transfer condition we rely on for those recipients is a Transfer Impact Assessment together with contractual safeguards, under the Personal Data Protection Commissioner’s Cross-Border Personal Data Transfer Guidelines. Where a recipient is in the EEA or the United Kingdom, or receives data originating there, transfers additionally rely on Standard Contractual Clauses or another mechanism permitted under the GDPR and the UK GDPR.

10. Retention & Account Deletion

DataRetention
Active account profile and contentUntil account deletion or School termination
Deleted account — soft-delete grace period30 days, then permanent erasure
Diary entries and private messages of a deleted accountErased at end of 30-day grace period
Public posts authored by a deleted accountDeleted at the end of the 30-day grace period, together with the account.
Comments left by a deleted account on another user’s postThe link to the account is removed. The comment text and the display name shown with it are kept, so that the post they sit on still reads coherently for the people in that conversation.
SOS alerts and SOS status updates, including any location attached to themRetained with the account, and erased when the account is erased
Safeguarding cases, including any location copied into the case recordRetained with the student's account, and erased when that account is erased
Resolved admin alerts (AI moderation)90 days
Unresolved admin alertsUntil reviewed
AI alert metadata (linkage to source content)Resolved alerts purged after 90 days; unresolved retained until reviewed. Raw user content associated with an alert remains governed by the retention period of the underlying diary entry, post, message, media attachment, or voice note — it is not held in a separate review copy.
Security audit logsAudit records tied to a deleted account are erased with the account. Identity-reveal audit records are retained for 12 months in pseudonymised form.
BackupsBackup copies, once established, are retained no longer than 35 days and are then overwritten.

How to delete your account

From the app: Settings → Account → Delete Account. Your account is immediately locked and you are signed out. After 30 days the deletion is irreversible.

To cancel a deletion during the 30 days: open the app and attempt to sign in with your usual password. Sign-in itself is refused while the account is locked — instead the app shows you the date the deletion becomes final and offers a Restore account action. Confirming that action reactivates the account. Signing in does not by itself cancel the deletion; you must confirm the restore.

Certain records survive erasure where the law requires or permits it — see the table above and the safeguarding and legal-retention exceptions in Section 16 of the Terms & Conditions.

From the web: https://ocare.ocgt.app/delete-account. You may also email privacy@ocare.ocgt.app with the subject line "Account deletion request" — we respond within 30 days.

11. Your Rights

Subject to your jurisdiction you may have the right to:

To exercise any right, email privacy@ocare.ocgt.app. We verify identity before responding and reply within 30 days (extendable by a further 60 days for complex requests). Student requests are processed in coordination with the School where required by law.

12. Children & Minimum Age

O’Care is intended for users aged 13 and older. We do not knowingly create accounts for, or collect personal data from, children under 13.

O’Care is not intended for Apple's Kids Category and is not marketed as "for kids" or "for children." It is a school-provisioned safeguarding platform for authorised school communities and users aged 13 or older, unless a higher local minimum age applies.

Student accounts are provisioned by the school administrator. Schools are responsible for confirming each student's age before requesting an account, and for obtaining any parental or guardian authorisation their local law requires. Accounts created through our individual-registration flows are checked against this minimum. Every user must confirm they are 13 or older before signing in.

Where local law sets a higher minimum age (for example, GDPR-K in the European Union, where the age may range from 13 to 16 depending on member state), the higher local minimum applies and the School must record appropriate parental authorisation before creating the account.

For US users: O’Care complies with the Children's Online Privacy Protection Act (COPPA). Schools provide consent for student users under applicable school-authorisation provisions. Parents may review, refuse, or request deletion of their child's data by contacting the School or privacy@ocare.ocgt.app.

If you become aware that a child under 13 has been registered, contact us at privacy@ocare.ocgt.app and we will delete the account and associated data promptly.

13. Security

No method of transmission or storage is 100% secure. We continuously improve our controls and invite responsible disclosure at security@ocare.ocgt.app.

14. Data Breach Notification

If we become aware of a personal-data breach likely to result in a risk to the rights and freedoms of natural persons, we will notify the affected School(s) without undue delay and, where required by law, the relevant supervisory authority within 72 hours of becoming aware of it.

Where we are required to notify the Personal Data Protection Commissioner of Malaysia, we will notify the affected individuals within 7 days of that notification. If notice is given late, we will record the reasons in writing. Affected users in the EEA and the United Kingdom are notified directly without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

15. Region-Specific Disclosures

15.1 Malaysia (PDPA 2010)

O’Care is operated by OC Global Technology Sdn Bhd, a Malaysian company, and processing under this policy is subject to the Personal Data Protection Act 2010. You may lodge a complaint with the PDP Commissioner at www.pdp.gov.my.

15.2 European Economic Area & United Kingdom (GDPR / UK GDPR)

Our EU/UK representative can be reached at eu-rep@ocare.ocgt.app. Supervisory authorities: EDPB members (EU) and the Information Commissioner's Office (UK).

15.3 California, USA (CCPA / CPRA)

California residents have the right to know, delete, correct, and limit the use of sensitive personal information, and to opt out of "sale" or "sharing". O’Care does not sell or share personal information as those terms are defined under the CPRA. To exercise California rights, email privacy@ocare.ocgt.app.

15.4 Other US states

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws have equivalent rights and may contact us at the same address.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified in the app and/or by email at least 14 days before they take effect. The "Last updated" date at the top reflects the most recent revision. Continued use of the Service after the effective date constitutes acceptance, except where the law requires your consent — in which case we will ask for it separately.

17. Contact & Complaints

Data controller: OC Global Technology Sdn Bhd
Privacy enquiries: privacy@ocare.ocgt.app
General support: support@ocare.ocgt.app
Security disclosure: security@ocare.ocgt.app
Postal address: OC Global Technology Sdn Bhd, Unit 09-04, Level 9, City Plaza, Jalan Tebrau, 80300 Johor Bahru, Johor Malaysia

If you are not satisfied with our response, you have the right to complain to the Personal Data Protection Commissioner (Malaysia) or your local supervisory authority.