Octave Privacy Protection Policy
Version 5.0
This Privacy Protection Policy (“Policy”) applies to IMC Octave Holdings and its subsidiaries, including but not limited to Living Octave (Shanghai) Management Consulting Company, Octave (Shanghai) Management Co., Ltd., Octave Suzhou Property Development Co., Ltd, Octave Real Estate (Shanghai) Management Co., Ltd, Octave Real Estate (Shanghai) Management Co., Ltd, Suzhou AtOne Cosmetic Clinic Co., Ltd, AITIA Institute (Shanghai) ("Octave," "we," or "us"). At Octave, we strive to deliver outstanding products, services, and experiences around the world. We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Policy to explain our practices regarding the personal information we collect from you or about you on this site or via our apps (e.g., SANGHA Journey App, SANGHA Journey Mini-App, ATONE Festival Mini-App, E-learning Website), through written or verbal communications with us, when you visit one of our properties, or from other sources.
本隐私保护政策(本政策)适用于IMC Octave Holdings及其子公司,包括但不限于八律(上海)企业管理咨询有限公司、玉理(上海)管理咨询有限公司、苏州万邦置业发展有限公司,苏州万邦意美医疗美容门诊有限公司,意澄(上海)管理咨询有限公司(音昱我们)。音昱致力于提供卓越的全球化产品、服务和体验。我们重视您的事务,尤其是您的忠诚度。同时我们也认可隐私的重要性。我们制定本政策,旨在解释我们在本网站或通过我们的APP(例如,水中天之旅APP、水中天之旅小程序、合一文化节小程序、量子领导力网站),或者通过书面或口头交流,或者在您访问我们的经营场所时,或者通过其他渠道,收集与您有关的个人信息或者从您这里收集个人信息的相关做法。

- What data we collect about you?
- Sensitive Information
- How do we use your info?
- Cookies Statement
- Links to Third-Party Websites and Services
- How can I exercise my rights over my data?
- Personal Data From Children
- International Transfers of Personal Data
- Protection Personal Data
- Other Uses and Disclosures
- Policy Modifications
- Application Permission Lists
- Contact us

- What data we collect about you?
We collect personal information at every touch point or guest interaction, and in conducting every aspect of our business, we may collect personal information. This personal information (“Personal Data”) may include: your name, mailing address, billing address, email address, phone number, information related to your reservation, stay or visit to a property; participation in a membership or loyalty program (including Octave co-branded payment cards or other co-branded programs); participation in marketing program (even if you do not stay at one of our hotels); information related to the purchase and receipt of products or services; personal characteristics, nationality, income, passport number and date and place of issue; travel history; payment information, such as your payment card number and other card information, as well as authentication information and other billing and account details associated with mobile billing; guest preferences; marketing and communication preferences; information about vehicles you may bring onto our properties; reviews and opinions about our Portfolio of Brands or properties (if they are identified or associated with you); frequent flyer or travel partner program affiliation and member number; hotel, airline and rental car packages booked; groups with which you are associated for stays at hotels; information provided on membership and account applications; and other types of information that you choose to provide to us or that we may obtain about you.
- Sensitive Information
In some jurisdictions, the term "sensitive information" refers to information related to your identification number, mobile phone numbers, racial or ethnic origin, political opinions, religious or philosophical beliefs, personal health, genetic information, and any biometric data used for the purpose of unique identification.
We do not generally collect sensitive information unless it is volunteered by you or unless we are required to do so pursuant to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular needs.
- How do we use your info?
Octave uses the data we collect to provide you with rich, interactive experiences. In particular, we use data to:
 Improve and develop our products and service.
 Personalize our products and make recommendations.
 Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers.
We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.
In carrying out these purposes, we combine data we collect from different contexts (for example, from your use of two Octave products) or obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes.
- Cookies Statement
Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. We use cookies and similar technologies for storing and honoring your preferences and settings, enabling you to sign in, providing interest-based advertising, combating fraud, analyzing how our products perform, and fulfilling other legitimate purposes.
We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers.
You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.
- Links to Third-Party Websites and Services
Our site and our mobile applications may contain links to third parties' websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties ( e.g.YouZan platform, Xiaoetong platform, Jingshuju platform). If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.
Octave may also partner with a limited number of Internet providers to offer Internet access to our guests. Your use of on-property Internet service is subject to the third-party Internet provider’s terms of use and privacy policy. You can access those terms and policies using the links on the service sign-in page, or by visiting the Internet provider’s website.
- Third-Party SDK
(1) GaoDe Map SDK: We don't use this sdk to get UserInfo. We just use this to show the location of our hotel for users.
高德地图SDK: 我们未使用该SDK获取用户相关信息,仅用于向用户展示我们的酒店位置
- How can I exercise my rights over my data?
The information you provided to us at the time of registration may be accessed, reviewed and updated at any time by signing in to your Octave profile.
For your protection, we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.
Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or reservation, or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase, reservation, or promotion). There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security, or other reasons.
- Personal Data From Children
We recommend that minors encourage their parents or guardians to read this Policy, and recommended that minors seek the consent and guidance of their parents or guardians before submitting information. We will protect the relevant information of minors in accordance with the applicable laws and regulations.
- International Transfers of Personal Data
Octave is a global organization and provides a global service. Sharing data cross-border is essential to the Services so that you receive the same high-quality service wherever you are in the world. As a result, we may, subject to law, transfer Personal Data and other data collected in connection with the services, to entities in countries where data protection standards may differ from those in the country where you reside. By making a reservation, visiting or staying at an Octave branded property or using any Octave Group branded service, you understand that we may transfer your Personal Data globally.
In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your Personal Data.
- Protection Personal Data
We do not, and will not, sell, rent, lease or release your personal data to third parties. Your personal data will be retained for as long it is necessary to fulfil the purpose for which it is collected or for business or legal purposes, or in accordance with applicable laws.
We will take reasonable measures to: (i) protect Personal Data from unauthorized access, disclosure, alteration or destruction, and (ii) use industry-standard security measures, including the establishment of a rational system specifications, safety technology to protect your information from unauthorized access, use or modification, or to avoid damage or loss of data.
We only allow Octave employees who need to know this information to access your Personal Data, and set up strict access control and monitoring mechanisms for this purpose. We also require all personnel who may be exposed to your Personal Data to perform the appropriate confidentiality obligations. We will take all reasonable and practicable steps to ensure that no relevant information is collected.
We also seek to require our service providers with whom we share Personal Data to exercise reasonable efforts to maintain the confidentiality of Personal Data about you.
If you want to cancel your account, please click “My” – “My Account” – “Cancel Account”, we will cancel your account within 15 days, please be aware that all your information will be cleared after this operation and There is no way to recover, be fully informed before doing this.
如果您想要进行账号注销,请点击我的- 账号信息 – 账号注销中提出申请,我们将在15日内对您的账号进行注销处理,请悉知此操作后您的所有信息将会被清除且无法恢复,在做此操作前进行充分的了解。
- Other Uses and Disclosures
To the extent permitted by laws and regulations, we may use and disclose your Personal Data in the following circumstances without your authorized consent:
(1) national security, national defense and security-related;
(2) related to public safety, public health, and major public interests;
(3) related to criminal investigation, prosecution, trial and execution of judgments;
(4) to protect your or other persons’ life, assets and other important legal rights and interests but it is difficult to obtain your consent;
(5) the Personal Data is made by you available to the public;
(6) the Personal Data is collected from the legally disclosed source;
(7) it is requisite to sign and perform the contract as requested by you;
(8) it is requisite to maintain the safe and stable operation of our products or services;
(9) as otherwise permitted by applicable laws and regulations.
- Policy Modifications
We may modify this Policy from time to time. When we make material changes to this Policy we will post a link to the revised Policy on the homepage of our site, and if you have registered for any of our products or services, will may also inform you through a communications channel that you have provided. You can tell when this Policy was last updated by looking at the link and at the date at the top of the Policy. Any changes to our Policy will become effective upon posting of the revised Policy on our site. Use of the site, any of our products and services, and/or providing consent to the updated Policy following such changes constitutes your acceptance of the revised Policy then in effect.
- Application Permission List
Permission                      Description                      Usage
Read mobile/phone status                      Obtain IMEI, IMSI, and other identifiers, as well as the phone number                                Push messaging and account security
Storage                     Read from and write to internal storage and SD cards.                   Saving images and files to the local directory, etc.
Making phone calls                        Invoke the system’s phone call permission.               Making phone calls directly through the app, facilitating customer service calls
Network                    Establish connection with the server                Executing the mandatory permission to connect the application to the server
Manage accounts              Update account activity logs                  Operations related to user account registration and login history, or carrying out “Select all and Proceed”
Read user’s phone call status                 Synchronize related video and audio settings, etc.              Prevent process preemption with video and live streaming during phone calls
Android ID                 Collecting User Statistics                 User data statistics
权限名称                    权限功能说明                 使用场景或目的
读取手机/电话状态               获取IMEI和IMSI等设备识别信息以及手机号码                        为实现信息推送,保障账户安全
存储                读取和写入SDCard数据                     保存图片或文件到本地等
获取SIM序列号      识别用户设备信息       用于用户主数据管理
拨打电话                    调用系统拨打电话权限                    用于在应用内直接拨打电话,方便联系客服
网络                实现和服务端的网络连接                APP网络连接的必要权限,确保应用能够连接服务端
管理账号列表                        用于用户账号的记录                        用户的账号注册登陆记录或一键带入
读取用户的电话状态                        主要用于视频,音频等相关设置处理                    保证在用户通话时不会与视频和直播抢占进程
安卓ID                 统计用户数量                 应用本身的用户统计
- Contact us
If you have any questions about this Policy or how Octave processes your Personal Data, or if you wish to either provide a compliment or a complaint, please contact us by email at Privacy@livingoctave.com.