Privacy Policy

Privacy Policy

Updated August 24, 2022

Owwll (“Owwll”, “we”, “us”, or “our”) is a new type of social network and online platform for professionals and experts. Our platform and its Services (described below) allow users to find and be found for business opportunities and their expertise, and to connect with others and have access to them for their expertise and information. We help you and others come together to learn, talk, and listen from each other. We provide a direct, easy way for people to meet with experts and with new professionals to seek knowledge, ask questions, teach, advice, debate, learn, and have conversations and interactions with others.

This Privacy Policy (“Policy”) informs you our policies and procedures for the collection, use, and disclosure of information through www.Owwll.com (“Site”). It includes our website(s), features, applications, and/or online services owned or controlled by us (collectively with the Site, “Service” or “Services”). This Policy also includes any information we collect and retain offline in connection with our Services (e.g., we combine the information we collect from you from the Site, through the Services generally, or offline). This Policy applies when you use our Services. We offer our users choices about the information we collect, use, disclose, and share as described in this Policy. This Privacy Policy also informs you about your rights to access, control, revise, and delete your information.

This Privacy Policy describes the choices available to you for the use of, your access to, and how to update and correct your personal information. This Policy incorporates by reference our Terms of Service Agreement. We reserve the right in our sole discretion to make changes to how we operate and provide our Services, including adding new services, modifying existing services, or suspending, discontinuing, or terminating your access to any or all portions of our Services, as described below.

All provisions in this Privacy Policy will govern all information we may gather about you throughout your use of and interaction with our Services, including but not limited to, all electronic communications and/or user submissions as necessary for us to comply with applicable laws and provide a satisfactory experience for our users. To that end, we are not responsible for the privacy practices of any third-parties, as that information is beyond our reach, and you should not contact us for any rights, claims, or concerns regarding Privacy Policies of any given third-party. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that are not under our supervisory control directly or indirectly.

The terms and definitions used in this Policy have the same meanings as in our Terms of Service Agreement, which is accessible on the Site unless otherwise defined in this Privacy Policy. Below is a list of key terms and their respective definitions as they apply to this Policy:

  • Owlet. Users seeking advice on the Site or based on our Services.
  • Owwll. Users who are professionals and/or experts that seek to share (or monetize) their expertise and provide advice.
  • Members. Our registered users (including all Owlets and Owwlls) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn, and develop skills, and find business and career opportunities.
  • Visitors. Content and information on some of our Services is or may be viewable to non-members.
  • Designated Countries. Refers to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.
  • Users. Any person(s) who classifies as Member(s) and/or Visitor(s) who use our Services.

TABLE OF CONTENTS

  • Information We Collect. If you choose to use our Services, you agree to the collection, use, and disclosure of your information as described in this Policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy. We collect information about you, directly from you when you register on the Site and use our Services; fill out forms or fields such as when you request to be registered as an expert of an advice seeker and use in-app call feature to seek or provide advice in real time; through the Services you opt in to, such as when you choose account funding and withdrawals; and your communications with us.
    • 1.1. Information You Provide. The types of personal information we collect depends on the products and portions of the Services you use. The information includes:

      • Your name, physical address, phone number, email address, age, gender date of birth, documents or other demographic information and media that verifies your identity.
      • Information we receive from third party data partners for verification purposes including to verify your identity and manage risk.
      • Your bank information such as your bank, your account numbers, bank account credentials, and transaction information.
      • Information about your computer, mobile phone or other access device and anonymous information about your web request, Internet Protocol (“IP”) address, geolocation data, browser type, referring /exit pages and URLs, number of clicks and how you interact with links on the Site, domain names, landing pages, pages viewed, your use of third-party applications, and other information that assists us in analyzing and improving the Services.
      Automatically from you when you visit the Site or use any available Services, we collect certain information from the mobile device by automatically recording certain log information (“Log Data”). This Log Data may include information such as your device IP address, device name, operating system version, the configuration of the app when utilizing our service, the time and date of your use of the service, and other statistics.
      • 1.1.1. Registration. To use some features of the Services, you must first complete the registration process. During registration, you are required to provide certain Personally Identifiable Information, including, but not limited to the information described herein. This information will periodically be used by us to contact you about site news, updates, and changes to this Policy, and to enable you to retrieve your password, if necessary.
      • 1.1.2. User Accounts. We allow Users to register a personal account (“User Profile”). You can edit your User Information at any time and may deactivate or delete your account at your convenience. Under no condition will we share your User Account Information with another individual, business, or government entity, unless we are required to respond to court orders, subpoenas, or other legal process.
      • 1.1.3. User Profiles. Users may create a profile, with certain or all information publicly available. Clients and Agencies may also create organization profiles. You may have the opportunity to create a profile, which consists of information about you, and may include Personal Information, photographs, examples of your work, information on work previously performed via our Services and outside our Services, skills, tests taken, test scores, hourly pay rates and earnings information, feedback/rating information and other information, including your username (“Profile”).

        The information in your Profile may be visible to all Owwll members and the general public, such as Visitors, subject to the privacy choices you make within your Profile. If you choose to make your profile publicly visible, your profile will be visible to the entire Internet, including clients, freelancers, visitors, and search engines such as Google and Bing, and may appear on our partners’ sites. You may edit certain information in your User Profile via your account and may choose to limit who is able to view certain content you post to your Profile. If, in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us feedback@owwll.com .

      • 1.1.4. Identity Verification. We place a premium on trust in the Services, so we may take steps to verify your identity. Before a User can complete registration on the Services, or at any time thereafter, we may request or re-request identity verification. Without limiting the manner in which we request identity verification, we may require Users to participate in a video call after submitting their government issued ID to enable us to confirm that the User is indeed the individual in the ID. We may record such video calls and take screenshots of the User during the call. We may use the information obtained from Identity Verification for purposes of verifying your identity, enforcing our Terms of Service and other agreements, and preventing fraud.
      • 1.1.5. General Audience Service. The Services are general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that Owwll has collected Personal Information from your child, please contact us at: feedback@owwll.com . These Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from persons under 18. In the case we discover that a person under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
      • 1.1.6. Posting and Uploading. We collect personal information from you when you provide, post, or upload it to our Services, such as when you fill out a form, (e.g., with demographic data or salary), respond to a survey, or submit a resume or fill out a job application on our Services. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).

        If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about events, e.g., times, places, attendees, and contacts.

        You don’t have to post or upload personal information; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

    • 1.2. Information We Collect When You Use Our Services. When you use our Services, we collect additional personal information based on your activity and other personal information you might choose to provide. This includes:
      • 1.2.1. Log Data And Device Information. We receive information through cookies and similar technologies. We may collect information from and about the devices you use. We may collect information about your hardware and software, such as the hardware model, operating system version, device memory, unique application identifiers, apps installed, unique device identifiers, browser type, and information about your wireless and mobile network connections, such as mobile phone number, service provider, IP address, and signal strength.

        When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us information about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

      • 1.2.2. Cookie Information. We collect information through cookies and similar technologies. We use cookies (small text files sent by your computer each time you visit our website, unique to your Clubhouse account or your browser) to get log data. Some of these cookies are used to help us understand how many people use our service, and how they use it. Other cookies are used to help us track the efficiency of our advertising campaigns on other platforms. For more detailed information about cookies, please see our Cookie Policy.

        As further described in our Cookie Policy, we use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. If you are outside the Designated Countries, we also collect (or rely on others who collect) information about your device where you have not engaged with our Services (e.g., ad ID, IP address, operating system, and browser information) so we can provide our Members with relevant ads and better understand their effectiveness. You can opt out from our use of information from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.

    • 1.3. Information From Others. Others may post or write about you.
      • 1.3.1.Content and News. You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. We also may collect public information about you, such as professional-related news and accomplishments, and make it available as part of our Services, including, as permitted by your settings, in notifications to others of mentions in the news.
      • 1.3.2. Content and Calendar Information. Others may sync their contacts or calendar with our Services. We receive personal information (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with Member profiles, scan, and upload business cards, or send messages using our Services (including invites or connection requests). If you or others opt-in to sync email accounts with our Services, we will also collect “email header” information that we can associate with Member profiles.
      • 1.3.3. Partners. Customers and partners may provide information to us. We receive personal information (e.g., your job title and work email address) about you when you use the services of our customers and partners, such as employers or prospective employers and applicant tracking systems providing us job application information.
      • 1.3.4. Related Companies and Other Services. We receive information about you when you use some of the other services provided by us or our affiliates, including Microsoft. For example, you may choose to send us information about your contacts in Microsoft apps and services, such as Outlook, for improved professional networking activities on our Services.
    • 1.4. Links to Other Sites. Our Services may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites because our Privacy Policy does not apply to those third-party websites or services. You’re browsing and interaction on any third-party website or service, including those that have a link or advertisement on the Site, are subject to that third party’s own rules and policies, including their terms and conditions and privacy practices. In addition, you agree that we are not responsible, and we do not control over any third parties that you authorize to access your user content. If you are using a third-party website or service (like Owwll) and you allow such a third-party access to your user content, you do so at your own risk.
    • 1.5. Third-Party Service Providers. For a better experience, while using the Services, we may require you to provide us with certain personally identifiable information, including but not limited to your full name, email, and public social media profile details. The information that we request will be retained by us and used as described in this Privacy Policy.

      Our Services use third-party services that may collect information used to identify you. We encourage you to review the privacy policy of any third-party website before disclosing any information to the Service. Below are links to the privacy policies of third-party service providers used by the Services:

  • How We Use Your Information. Finally, we agree that we will never use or share the Personal Information provided to us by you in any way that violates or is otherwise unrelated to the means described in this Privacy Policy, without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses.

    We take your privacy very seriously. Accordingly, we agree that we will only use the information you provide for the following specific purposes:

    • to effectuate a registration made by you;
    • to fulfill your requests for services while using the Services;
    • to provide you and other users with access to the services offered through the Services;
    • to improve our insights so we can tailor our content and advertising;
    • to provide you with offer recommendations and/or insights that are most relevant to you;
    • to contact you, conduct research, and provide anonymous reporting for internal and external clients, when necessary;
    • to provide notices and other information to you about, or in connection with, these Services;
    • to provide customer support;
    • to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, fulfill legal requirements and enforce our agreements;
    • to debug to identify and repair errors that impair existing intended functionality;
    • to provide, maintain, develop, and improve our Services, your experience and to provide, maintain, develop, and improve our Services, your experience, and to protect us and our Members;
    • to improve your experience accessing our services offered through the Services by recognizing you as a Member and remembering information you previously provided so that you will not have to re-enter it; and
    • to improve the content and overall look and feel of the Site and our Services.

    We agree that we will not share, sell, rent, or otherwise distribute your Personal Information with outside parties, except to provide Services you’ve requested through us, or in response to a validly issued subpoena, court order, or other legal process, or when necessary to establish or exercise our legal rights or defend against legal claims made by you or on your behalf.

    From time to time, we may employ the use of return email addresses to answer the email we receive from you. Such addresses are not used for any other purpose and are not shared with outside parties.

    • 2.1. Services. Our Services help you connect with others, find and be found for work and business opportunities, stay informed, get training and be more productive. We use your information to authorize access to our Services and honor your settings.
    • 2.2. Communications. We contact you and enable communications between Members. We offer settings to control what messages you receive and how often you receive some types of messages. We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your Owwll inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices. We also enable communications between you and others through our Services, including for example invitations, newsletters, groups, and messages between connections.
    • 2.3. Advertising. We serve you tailored ads both on and off our Services. We offer you choices regarding personalized ads, but you cannot opt-out of seeing other ads.

      We target (and measure the performance of) ads to Members, Visitors, and others both on and off our Services directly or through a variety of partners, using the following information, whether separately or combined:

      • Information from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers;
      • Member-provided information (e.g., profile, contact information, title, and industry);
      • Information from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.);
      • Information from advertising partners, vendors, and publishers; and
      • Information inferred from your personal information described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender; using your feed activity to infer your interests; or using device information to recognize you as a Member).

      We will show you ads called sponsored content which look similar to non-sponsored content, except that they are labeled as advertising (e.g., as “ad” or “sponsored”). If you take a social action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser.

      Subject to your settings, if you take a social action on Owwll’s Services, that action may be mentioned with related ads. For example, when you like a company we may include your name and photo when their sponsored content is shown.

    • 2.4. Ad Choices. We adhere to self-regulatory principles for interest-based advertising and participate in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self-regulatory tools. You can also opt-out specifically from our uses of certain categories of information to show you more relevant ads.
    • 2.5. Info to Ad Providers. We do not share your personal information with any third-party advertisers or ad networks except for: (i) hashed IDs or device identifiers (to the extent they are personal information in some countries); (ii) with your separate permission (e.g., in a lead generation form), or (iii) information already visible to any users of the Services (e.g., Profile). However, if you view or click on an ad on or off our Services, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of mechanisms such as cookies, determine it is you. Advertising partners can associate personal information collected by the advertiser directly from you with hashed IDs or device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing
    • 2.6. Marketing. We promote our Services to you and others. In addition to advertising our Services, we use Members’ information and content for invitations and communications promoting membership and network growth, engagement, and our Services, such as by showing your connections that you have used a feature on our Services.
    • 2.7. Developing Services and Research. We develop our Services and conduct research. We collect public and private feedback from Users about their experience with other Users of the Services. Please note that any public feedback that you provide via the Site about your experience with other Users of our Services or that is provided about you by other Users is publicly viewable via the Site. On rare occasions, we may remove feedback pursuant to the relevant provisions of our Terms of Service , including Account Deletion and Deactivation provisions of this Privacy Policy. Any private feedback that you provide via the Site about your experience with other Users of the Site (and/or Services) or that is provided about you by other Users will not be publicly viewable via the Site.

      We also collect feedback from Me about our Services. We use this information to respond to your inquiries, improve the Service(s) and how our Site functions, and develop new products and features.

    • 2.8. Customer Support. We use information to help you and fix problems. We use information (which can include your communications) to investigate, respond to and resolve complaints and for Services’ issues (e.g., bugs).
    • 2.9. Statistics That Do Not Identify You. We use information to generate statistics (e.g., models, insights, projections, etc.) that do not identify you. We use your information to produce and share statistical insights that do not identify you. For example, we may use your information to generate statistics about our Members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service(s).
    • 2.10. Security and Investigative Purposes. We use information for security, fraud prevention and investigations. We use your information (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our user or platform-related Agreements and/or attempts to harm our Members, Visitors, and/or others.
    • 2.11. Messaging. Users may communicate with each other through the Services. For example, Owlets may wish to discuss their needs with Owwlls. If an Owlet communicates with an Owwll (or vice-versa), that Owwll or Owlet will also be a “data controller” with respect to such communications.
    • 2.12. Testimonials. We display information such as personal testimonials of satisfied Users on our Services, in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us feedback@owwll.com .
    • 2.13. Posting Rates and Services Through the Service. If you choose to post your expertise, rates, and any other information related to your providing of advice as an Owwll via the Service, the contents of such listing will be viewable publicly to all Users. These listings include information such as rate(s), areas of expertise, location, number of followers, calls taken, a bio, User feedback and rating information and timing of project performance, current employment, videos, links to social media accounts, and any other information voluntarily added to facilitate your use of the Site and our Services.
  • How We Disclose and Share Your Information. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from us at all times. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information may not be accessed, disclosed, altered, or destroyed.

    If any information under our control is compromised because of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

    • 3.1. Our Services. Any information that you include on your Profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services will be seen by others, consistent with your settings.
      • 3.1.1. Profile. Any information that you include on your profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services will be seen by others, consistent with your settings.
      • 3.1.2. Posts, Likes, Follows, Comments, Messages. Our Services allow viewing and sharing information including through posts, likes, follows, and/or comments. When you share an article or a post (e.g., an update, image, video, or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Users and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
        • In a group, posts are visible to others in the group. Your membership in groups is public and part of your profile, but you can change visibility in your settings.
        • Any information you share through companies’ or other organizations’ pages on our Site (or Services) will be viewable by it and others who visit those pages.
        • When you follow a person or organization, you are visible to others and that “page owner” as a follower.
        • We let senders know when you act on their message, subject to your settings where applicable.
        • When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile, and photo if you provided it).
    • 3.2. Communication Archival. Some Members (e.g., Owlets or Owwlls) need, for legal or professional compliance, to archive their communications and social media activity, and will use services of others to provide these archival services. We enable archiving of messages by and to those Members outside of our Services. For example, a financial advisor needs to archive communications with her clients through our Services to maintain her professional financial advisor license.
    • 3.3. Others’ Services. Subject to your settings, other services may look up your Profile. When you opt to link your account with other services, personal information will become available to them. The sharing and use of that personal information will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Apple account to share content from our Services into these other services, or your email provider may give you the option to upload your contacts into its own service. Third-party services have their own privacy policies, and you may be giving them permission to use your information in ways we would not. You may revoke the link with such accounts.

      Subject to your settings, excerpts from your Profile will appear on the services of others (e.g., search engine results, mail and calendar applications that show a user limited profile information of the person they are meeting or messaging, social media aggregators, talent, and lead managers). “Old” profile information remains on these services until they update their data cache with changes you made to your Profile.

    • 3.4. Related Services. We will share your personal information with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, we may personalize your feed (with highlighting a list of particular Owwlls with a particular expertise) based on your recent seeking advice history.
    • 3.5. Service Providers. We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing, and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
    • 3.6. Legal Disclosures. We may need to share your information when we believe it’s required by law or to help protect the rights and safety of you, us, or others. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); and/or (5) exercise or protect the rights and safety of Owwll, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
    • 3.7. Change in Control or Sale. We may share your information when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy. We can also share your personal information as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us, or part of our business will have the right to continue to use your information, but only in the manner set out in this Privacy Policy unless you agree otherwise.
  • Your Choices and Rights.
    • 4.1. Information Retention. We keep most of your personal information for as long as your account is open. We generally retain your personal information as long as you keep your account open or as needed to provide you Services. This includes information you or others provided to us, and information generated or inferred from your use of our Services. Even if you only use our Services when looking for a particular type of expertise every few years, we will retain your information and keep your Profile open, unless you close your account. In some cases, we choose to retain certain information (e.g., statistics about Services use) in a depersonalized or aggregated form.
    • 4.2. Rights to Access and Control Your Personal Information. You can access or delete your personal information. You have many choices about how your information is collected, used, and shared. We provide many choices about the collection, use and sharing of your information, from deleting or correcting information you include in your Profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal information we have about you.


      For personal information that we have about you, you can:

      • Delete Information. You can ask us to erase or delete all or some of your personal information (e.g., if it is no longer necessary to provide Services to you).
      • Change or Correct Information. You can edit some of your personal information through your account. You can also ask us to change, update or fix your information in certain cases, particularly if it’s inaccurate.
      • Object to, or Limit or Restrict, Use of Information. You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal information is inaccurate or unlawfully held).
      • Right to Access and/or Take Your Information. You can ask us for a copy of your personal information and can ask for a copy of personal information you provided in machine readable form.

      You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

      Residents in the Designated Countries and other regions may have additional rights under their laws.

      • 4.2.1. Correction of Personally Identifiable Information. So that we may best serve you, you are responsible for ensuring that all Personally Identifiable Information you provide on this Site (and/or for our Services) is maintained and kept current.
      • 4.2.2. Opt-Out Policy. Users are automatically added to receive newsletters and updates regarding Owwll, the Site, Profiles and User Information, and Services. You may “opt-out” from receiving newsletters, promotional offers, and other types of emails. To unsubscribe from our mailings (except important system and content update information detailed below), you may go to an email you received from us, scroll down to the bottom of the email, and select “update your preferences” to manage all email preferences or “unsubscribe from this list” to unsubscribe from that certain type of email. After selecting one of those two links, you will be prompted to complete certain steps to complete your request.
    • 4.3. Account Closure. We keep some of your information even after you close your account. If you choose to close your Owwll account, your personal information will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

      We retain your personal information even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our professional community policies), enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

      Information you have shared with others (e.g., through updates, likes, comments, or group posts) will remain visible after you close your account or delete the information from your own Profile or mailbox, and we do not control information that other Members have copied out of our Services. Your Profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

      4.3.1. Account Deactivation. Impact on our Services after an “Account Deactivation” request is approved.

      4.3.1.1. Impact on Owlets.

      • Deactivated user will not be able to log in to the Site or use our Services.
      • An appropriate message should be displayed to the deactivated user to let them know why they can’t log in.
      • Deactivated user will not receive any notification
      • Deactivated user will not receive any email
      • All the pending bonuses of the deactivated user will be expired.
      • Deactivated user’s given ratings and reviews should be visible on relevant Owwll’s profile as ‘Anonymous’.
      • The deactivated user will still be visible in followers of other experts, but deactivated user’s name will be replaced with the moniker anonymous.
      • If the deactivated user was referred by any other Users, then this deactivated user will not be visible in his referrals list
      • Username reference in active users’ Transaction History should remain as-is.
      • Username reference in active users’ My Bonuses list should remain as-is.
      • Upon reactivation of the account:

        • This user’s given ratings and reviews should be visible on relevant Owwll profiles with their details (name).
        • This user should be visible in the followed Owwlls’ followers list.
        • If the owlet was referred by any other user of the Owwll app then this owlet should be visible in his referrals list.
      4.3.1.2. Impact on Owwlls.
      • Deactivated users will have the same impact as detailed above for the Owlets’ deactivated users.
      • Deactivated user will not be able to log in to the Site or use our Services.
      • Deactivated user will not be visible on the homepage and in these categories:
        • Active Owwlls,
        • Featured Owwlls, and
        • Recently Active.
      • Tap on view all on any of these categories above and the deactivated user will not be visible.
      • Deactivated user will not be visible in My Owwlls’ list.
      • Active users should not be able to search for the deactivated user under the My Owwlls, Featured, or All Owwlls’ categories.
      • The videos section will not show any videos uploaded by the deactivated user.
      • Public profile of the deactivated user will not open, either tapped from shared link or a notification.

      4.3.2. Account Deletion. Impact on our Services after an “Account Deletion” request is approved.

      • 4.3.2.1. Impact on Owlets.
        • Deleted user will not be able to log in to the Site or use our Services.
        • An appropriate message will be displayed to the deleted user to let them know why they can’t log in.
        • Deleted user will not receive any notifications.
        • Deleted user will not receive any emails.
        • All the pending bonuses of the deleted user should be expired.
        • Deleted user’s given ratings and reviews should be visible on relevant Owwll’s profile as “Anonymous”.
        • You will still be visible in followers of other experts, but your name will be replaced with the moniker anonymous.
        • If the deleted user was referred by any other Users, then this deleted user wil not be visible in his referrals list.
        • Username reference in active users’ Transaction History will remain as-is.
        • Username reference in active users’ My Bonuses list should remain as-is.
      • 4.3.2.2. Impact on Owwlls.
        • Deleted user will not be able to log in to the Site or use our Services.
        • Deleted user will not be visible on the homepage and in these categories:
          • Active Owwlls,
          • Featured Owwlls, and
          • Recently Active.
        • Tap on view all on any of these categories above and the deleted user will not be visible.
        • Deleted user will not be visible in My Owwlls’ list.
        • Active users should not be able to search for the deleted user under the My Owwlls, Featured, or All Owwlls’ categories.
        • The videos section will not show any videos uploaded by the deleted user.
        • Public profile of the deleted user will not open, either tapped from shared link or a notification.
  • Security. We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. However, remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

    We implement security safeguards designed to protect your information, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please visit our Supplemental Privacy Policies below for additional information about safely using our Services.

    We care about the security of your information and take reasonable measures designed to protect your personal information from unauthorized access and use by maintaining physical, electronic, and procedural safeguards in compliance with applicable law. These measures include computer safeguards and secured files and buildings.

    All Owwll employees and agents are required to safeguard such Personal Information. Access to this information is limited only to those who need to see the information to provide the Services and other products and services within the Site to Users of the Services.

  • Cross-Border Information Transfers. We store and use your information outside your country. We process information both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer information across borders. Countries where we process information may have laws which are different from, and potentially not as protective as, the laws of your own country.
  • Lawful Bases for Processing Your Information. We have lawful bases to collect, use and share information about you. You have choices about our use of your information. At any time, you can withdraw consent you have provided by going to settings. We will only collect and process personal information about you where we have lawful bases. Lawful bases include consent(where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Owwll Services you have requested) and “legitimate interests.”

    Where we rely on your consent to process personal information, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal information, please contact: feedback@owwll.com.

  • Changes to This Policy. We may update our Privacy Policy from time to time to reflect the changes in our business and practices. Thus, you are advised to review this page periodically for any changes. The revised version will be effective at the time we post it. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “This policy is effective as of” date below.
  • Contact Us. If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at feedback@owwll.com.
  • Supplemental Privacy Notices. Our privacy practices are described in more detail above, and we have provided a summary of how we handle non-public personal information below:
  • FACTS What does Owwll do with your personal information?
    Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
    What? The types of personal information we collect, and share depend on the product or service you have with us. This information can include:
    • Social Security number and other identity information;
    • Account balances and payment history;
    • Credit history, credit scores, education, and employment information;
    • Bank account, financial and income information; and
    • Information about how you access and use our website and other services.
    How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Owwll chooses to share; and whether you can limit this sharing.
    Reasons to share your personal information Does Owwll share? Can you limit what’s is shared?
    For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No
    For our marketing purposes – to offer our products and services to you Yes No
    For joint marketing with other financial companies No We don’t share
    For our affiliates’ everyday business purposes – information about your transactions and experiences No We don’t share
    For our affiliate’s everyday business purposes – Information about your creditworthiness No We don’t share
    For our affiliates to market to you No We don’t share
    For our non-affiliates to market to you No We don’t share
    Questions? Email us at feedback@owwll.com
    Other important information
    For California residents We will not share information we collect about you with nonaffiliated third parties, except as permitted by California law, such as to process your transactions or to maintain your account. We do not share with our affiliates.
    For Nevada residents If you would like to review and request changes to any of your covered information that is collected through the Internet website or online service, feedback@owwll.com.
    For Vermont residents We will not share information we collect about you with nonaffiliated third-parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account and with your consent.
    Who we are
    Who is providing this notice? You are receiving this notice from Owwll.
    How does Owwll protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
    How does Owwll collect my personal information? We collect your personal information, for example, when you:
    • Open an account
    • Give us your contact information
    • Give us your income information
    • Show your government-issued ID
    • Request a loan offer or purchase securities We also collect your personal information from others, such as expertise levels, affiliates, or other companies.
    Why can’t I limit all sharing? Federal law gives you the right to limit only:
    • sharing for affiliates’ everyday business purposes—information about your creditworthiness
    • affiliates from using your information to market to you
    • sharing for nonaffiliates to market to you
    Definitions
    Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.
    • Owwll does not share with our affiliates.
    Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.
    • Nonaffiliates we can share with include our marketing service providers.