Legal
Privacy Policy
Effective as of September 1, 2017, ThinkOwl.com GmbH, (“ThinkOwl”) and its subsidiaries, (collectively, the “ThinkOwl Group” or “we” or “us” or “our”) have created our Privacy Policy (“Policy”).
1. Introduction
This Policy details our commitment to protecting the privacy of individuals who visit our Websites (as herein defined) (“Website Visitors”), who register to use our Services, or who attend or register to attend sponsored events or other events at which the ThinkOwl Group participates (“Attendees”). For the purposes of this Policy, the term, “Websites”, shall refer collectively to www.thinkowl.com as well as the other websites that the ThinkOwl Group operates and that link to this Policy..
2. Scope of this Policy
In addition to the Websites that link to this Policy, this Policy applies to the following:
The ThinkOwl.com Developer Portal, which enables Subscribers to create web applications and other integrations with our Services. For the purposes of this Policy, “Subscriber”, as the term is used herein, shall refer to an individual or an entity that has agreed to a Service Agreement for use of our Services.
In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity.
Our Websites may contain links to other websites and the information practices and the content of such other websites are governed by the privacy statements of such other websites.
We encourage you to review the privacy statements of any such other websites to understand their information practices.
With the exception of Account Information (as defined below) and other information we collect in connection with your registration or authentication into our Services (as defined below), this Policy does not apply to our security and privacy practices in connection with your access to and use of the products and services which we market for subscription on our Websites (our “Services”).
These security and privacy practices, including how we protect, collect, and use electronic data, text, messages, communications or other materials submitted to and stored within the Services by You (“Service Data”), are detailed in and governed by our Master Subscription Agreement, or such other applicable agreement between you and any member of the ThinkOwl Group relating to your access to and use of such Services (“Service Agreement”). Subscribers to our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals with whom our Subscribers interact. If you are an individual who interacts with a Subscriber using our Services, then you will be directed to contact our Subscriber for assistance with any requests or questions relating to your personal information.
We collect information under the direction of our Subscribers, and have no direct relationship with individuals whose personal information we process in connection with the use of our Services. If you are an individual who interacts with a Subscriber using our Services (such as a customer of one of our Subscribers) and would no longer like to be contacted by one of our Subscribers that use our Services, please contact the Subscriber that you interact with directly.
We may transfer personal information to companies that help us provide our Services. Transfers to subsequent third parties for these purposes are governed by the Service Agreements with our Subscribers.
3. Account and Registration Information
We ask for and collect personal information about you such as your name, address, phone number, email address, instant messaging ID, and credit card information, as well as certain related information like your company name and website name, when you register for an account to access or utilize one or more of our Services (an “Account”). We also ask for and collect personal information such as an email address and a name or alias from any individual that you authorize to log into and utilize our Services in connection with Your Account.
If you sign-up for a free trial Account, you are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services.
A third-party intermediary is used to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf. We refer to any information described above as “Account Information” for the purposes of this Policy. By voluntarily providing us with Account Information, you represent that you are the owner of such personal data or are otherwise authorized to provide it to us.
4. Log Files
ThinkOwl Group and our third party advertising partners use technologies such as web beacons in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or click stream data. We link this automatically collected data to other information we collect about you.
Do Not Track. Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.
We partner with a third party to either display advertising on our Websites or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this Website and other sites in order to provide you advertising based upon your browsing activities and interests.
5. Social Media Features
Our Websites includes social media features, such as the Facebook “Like” button, the “Share This” button or interactive mini-programs. Where we have your consent, these features may collect your IP address, which page you are visiting on our Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Websites. Your interactions with these features are governed by the privacy policy of the company providing them.
6. Information from Third Party Services
We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Websites. For example, You can log in to our Websites using sign-in services such as Google, Facebook Connect.
These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address. Services like Google, Facebook Connect give you the option to post information about your activities on our Websites to your profile page and to share information with others within your network.
Any access that we may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address(es), current city, profile picture URL, and other personal information that the third party service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services.
7. Communications from the Websites
We may use your email address to send our newsletters and/or marketing communications. If you no longer wish to receive these communications, you can opt out by following the instructions contained in the emails you receive or by contacting us.
We will send you announcements related to the Service(s) on occasions when it is necessary to do so. For instance, if our Service(s) is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of communications which are not promotional in nature. If you do not wish to receive them, you may deactivate your Account.
8. Other Submissions
We ask for and collect personal information from you when you submit web forms on our Websites or as you use interactive features of the Websites, including, participation in surveys, contests, promotions, sweepstakes, requesting customer support, or communicating with us.
9. Protection of Information
The Websites and Service(s) have industry standard security measures in place to protect against the loss, misuse, and alteration of the information under our control. When you provide us with sensitive information (such as credit card information or login credentials), we will encrypt that information via Secure Socket Layer (SSL).
While there is no such thing as “perfect security” on the Internet, we take all reasonable steps to ensure the safety of your personal information. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Websites or via the Service(s) and any transmission is at your own risk. Once we receive your personal information, we will use strict procedures and security features to try to prevent unauthorized access. Additionally, you retain all rights of ownership to your personal data we collect. Except as set forth herein under sections elaborating on use of your personal information above and legal disclosure below we will not sell or share your personal data with any third parties or use your personal data to compete with you. Your privacy and the privacy of your customers are of utmost importance to us. If you have questions about our security you can contact us at support@thinkowl.com.
10. International Transfer of Information Collected
We primarily store personal information about Website Visitors and Subscribers within the European Economic Area (the “EEA”), the United States and in other countries and territories. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which the ThinkOwl Group has operations.
If you are visiting our Websites from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.
11. How We Use Information That We Collect
We use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Services; (b) enable you to access and use the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us or following the unsubscribe instructions included in our marketing communications; (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; (h) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; (i) personalize the Websites and Services, including by providing features or advertisements that match your interests and preferences; (j) training the Artificial Intelligence Models in our Services and (k) for other purposes for which we obtain your consent.
12. Testimonials
We post customer testimonials/comments/reviews on our Websites which may contain personal information. Prior to posting the testimonial, we obtain the customer's consent to post their name along with their testimonial. If you want your testimonial removed, please contact us.
13. Referrals
If you choose to use our referral service to tell a friend about our products and services, we will ask you for your friend’s name and email address. We will automatically send your friend an email inviting him or her to visit the Websites and will store this information for the purpose of sending this initial email, tracking the success of our referral program and other marketing activities.
14. Corrections and Updates
Upon request ThinkOwl Group will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us. We allow users of the Service(s) or Website to access, update or modify their information by clicking on the My Account link in the ThinkOwl navigation menu.
15. Childrens' Personal Information
ThinkOwl Group does not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Websites or Service(s). We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through our Service(s) or Websites without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through our Websites or Service(s), please contact us and we will endeavor to delete that information and terminate the child's account from our databases.
16. Changes to this Policy
If there are any material changes to this Policy, you will be notified by our posting of a prominent notice on the Websites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Websites or the Services constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Websites and the Services.
Provided we will not be notifying you if we amend the Policy to make addition, deletions or modifications to the list of cookies from time to time to keep the list of cookies current and accurate.
17. Legal Disclosure
We reserve the right to disclose your personal data as required by applicable law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process served on us. Your personal data will also be shared between our Group Companies for the activities permitted under this Policy. In the event ThinkOwl Group goes through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account and personal data will likely be among the assets transferred.
18. English Version Controls
Non-English translations of this Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.
19. Contact Us
If you have questions regarding this Policy or about the ThinkOwl Group’s privacy practices, please contact us by email at privacy@thinkowl.com.