Privacy Policy

ChatOwl understands how important the privacy of personal information is to our users. We invest a great deal of thought, effort, tools, resources and procedures in place and update these as technology develops to protect and safeguard your privacy. This document is our “Privacy Policy” and will tell you what information we collect about you and issues related to your privacy when using our Services. This Privacy Policy applies to visitors to our Sites and Apps and the registered users of ChatOwl Sites and Apps. Please read this Privacy Policy carefully. We refer to the ChatOwl Sites and Apps, along with the information and services made available to you through the ChatOwl Sites and Apps, as the “Services.”

If you do not want us to collect, use or disclose information about you and your use of the Services as described in this Privacy Policy, then you should not use the Services. By using the Services, you must agree to the ChatOwl Terms of Use, which is the contract between us and users of the Services. By accepting the ChatOwl Terms of Use, you confirm that you have read and understand this Privacy Policy and you acknowledge that we will store, use and otherwise process your information in the United States where we are located. References to “ChatOwl,” “we” or “us” mean ChatOwl Inc. Except as otherwise noted in this Privacy Policy, ChatOwl is the data controller responsible for the processing of your personal information as described in this Privacy Policy.

Information Collected About You

Some of our Services do not retain your personal information (such as simply visiting our website or App), while others (such as our registration-driven ChatOwl digital counselor) store your personal email you use to register your account with us in accordance with this Privacy Policy. Even if you do not register with or provide any personal information to ChatOwl, we collect information about your use of the ChatOwl Services. We may also acquire information about our users from external sources.

Having said that, when you use the Services, we collect information as follows:

Registration

While you may use some of our Services without registering, but our main Services requires that you register with ChatOwl by using an email address that you select. It is possible that we may allow you to sign on by means of the use of single-sing-on services (“SSO”) like “Facebook Connect” or “Sign in with Twitter” or “Sign in with Google” or “Sign in with LinkedIn” or by use of the connectors to social media networks, and these types of sign-ins are indirectly retrieved via such services. By using a SSO-service or social media connector, you accept the general terms and conditions of business and data protection of such service providers. To the extent legally permissible, you release ChatOwl from all liability and guarantee should you choose to use SSO-service sign-ins.

Having said that, we will always allow you to register with an email. Currently, this is the only way we will connect you to your account, so please remember the email that you use to register an account with us. For your privacy, we store your email separate from you account. You may give your account a name if you like, and we will assign your account a random code. This code is kept separate from your email. If you choose to register or update an existing account with ChatOwl or access certain Services, you may be required to provide certain personal information, such as your gender or verify you are over the age of sixteen (16). You are responsible for ensuring the accuracy of the personal information that you submit to ChatOwl. To let us operate your ChatOwl digital counselor, we may collect, use, and store the information below. The information ChatOwl digital counselor collects is received directly or indirectly from you and generated in the course of your use of the ChatOwl digital counselor. The data is not used for marketing or any other purposes except as specified in this Privacy Policy.

Interactive Services

Some of our Services, such as the ChatOwl virtual counselor, are interactive and may request that you submit health-related information, along with other information such as your age and gender. Although it is not required for you to register with us to use portions of our website and Services, please know that if you are registered with us, we will only connect the information you exchange with the ChatOwl virtual counselor and the requested information the ChatOwl virtual counselor provides you based on your input with the email address and password you submit with your registration information; all other personal information you provide to us will not be associated with your ChatOwl virtual counselor information, as we do not store your email with your account, but use the random code we assign to your account. This is why we ask that you please remember your registration email. ChatOwl virtual counselor provides you with a secure place to store and manage your ChatOwl sessions. However, ChatOwl does not allow any third parties to gather any data about you in connection with your use of the ChatOwl virtual counselor. ChatOwl may also collect, use and store certain general data regarding your sessions such as when your sessions are or were accessed and whether your session was completed or abandoned.

Emails You Send to ChatOwl

We collect any information you give us voluntarily, such as information you write to us in an email, leave on a voice mail, or send to us in a letter. We do this for several reasons, like knowing how to respond to you if you ask us a question. If you want to keep information, content, business information, ideas, concepts or inventions private or proprietary, do not send them in an email or otherwise provide the information to ChatOwl.

Services and Device Information

When you access and use the Services, ChatOwl automatically collects and stores in its server logs information from your browser or mobile device such as your IP address or unique device identifier, browser information (including referring URL), your preferences and settings, cookies and information about the content you have viewed and actions taken (e.g., search queries, ad engagement, clicks and the associated dates and times). ChatOwl may also collect device-specific information when you install and use an App including your device model, operating system information, advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device) and App version and usage information. When enabled by you, we collect precise location information provided by your mobile device, which you may disable through the device settings.

Cookies and Other Tracking Technologies

We use cookies to collect information about your use of the Services. “Cookies” are small data files assigned to your browser when you visit the ChatOwl website or an App page (“Sites”) which enable recognition of your browser and collect and store information about your use of the Services, as described above. In addition to cookies, we use other tracking technologies that collect information about your use of the Services, including mobile identifiers and “web beacons” which are small graphic files (sometimes called “clear GIFs” or “web pixels”) embedded in a web page or email typically used to monitor activity and send relevant information back to a home server (which can belong to the host site, a network advertiser or some other third party).

Websites you come from before you visit our Sites or go to after you visit our Sites may use cookies and other tracking technologies to collect information about you and your visit to ChatOwl, including any links we may have to social media sites, such as Facebook, Instagram, Twitter, etc. We do not have any control over these third parties. We recommend you review privacy policies on the sites you visit so you are familiar with their polices because we do not have control over what information these sites gather about you.

How Information Collected About You Is Used

Information about your use of the Services may be used for the following purposes:

• to provide, improve and create new Services,
• to respond to your inquiries and to send you administrative communications about the ChatOwl Sites and Services,
• to obtain your feedback about the ChatOwl Sites and Services,
• to send you secure electronic messages and personalized emails pertaining to your interests as inferred from your use of the Services and messages you may submit to us,
• to statistically analyze trends and user behavior and activity including how frequently areas of the ChatOwl Sites are visited, how the Services are being used and how many emails are received and opened,
• to detect and defend against fraud and other threats to the Services and our users,
• to identify issues with the Services,
• to conduct research and measurement activities, including those described below, and
• to administer your account.
• In addition, ChatOwl may use personal information about you for other purposes that are disclosed to you at the time we collect the information and/or with your consent. Having said that, ChatOwl may aggregate information, which is not able to be identified back to an individual user of the ChatOwl Sites, to our business partners, for such matters as research and measurement purposes, including measuring the effectiveness of content or programs.

Sharing Your Information

ChatOwl Affiliates

We may share your information with our affiliates with your permission . In the event of a corporate change in control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale of assets or a bankruptcy, ChatOwl reserves the right to transfer your personal information to the new party in control or the party acquiring assets. In the event of such a change, your personal information will continue to be treated in accordance with this Privacy Policy unless any changes to the Privacy Policy are made in accordance with the section below that discusses “Changes to This Privacy Policy.”

Companies and Contractors that Work with ChatOwl

Sometimes ChatOwl works with third party companies and contractors that help us provide the Services and to otherwise assist in the operation of the ChatOwl Sites and Apps. ChatOwl contractors sometimes have limited access to your information in the course of providing products or services to ChatOwl. We contractually require that our third party service providers and contractors not use or disclose your information for any purpose other than providing the limited service or function for ChatOwl.

Compliance with Law, Regulation, and Law Enforcement Requests

To cooperate with government and law enforcement officials and private parties to enforce and comply with law, we may release personal information to third parties: (1) to comply with legal requirements such as a law, regulation, search warrant, subpoena or court order; (2) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; or (3) in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights. In addition, we may disclose personal information as described below.

How Your Information is Secured and Retained

We take reasonable security measures to protect the security of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personally identifiable information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website or other service.

The security of your personal information is important to us. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process from accidental loss and from unauthorized access, use, alteration, and disclosure. For example, we use security software to protect the confidentiality of your personally identifiable information. We use a Secure Socket Layer/Transport Layer Security technology when information is submitted to us on line. We do not store any of your personal data at our location, but instead use secure cloud storage. However, please know that when we access your personally identifiable information from our computers, it is protected in several ways with firewalls, data encryption, physical security for our buildings, files and information contained therein and other current industry standards. In addition, our business practices are reviewed periodically for compliance with policies and procedures governing the security and confidentiality of our information. Our business practices limit employee access to confidential information, and limit the use and disclosure of such information to authorized persons. Non-personal information that you provide or that we collect also resides on a secure server in our processor and sub processor and cloud infrastructure mentioned above and is only accessible via password. We also use old fashioned lock and key with locking office doors, locking desks, building security systems, and other physical security measures.

We will retain your personal information as long as your account is active or as needed to provide you Services. At any time, you request us to remove your personal information, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to ChatOwl from our servers. See “Your Choices and Rights” below for more information on how you can update or remove your personal information. Having said that, we will retain your personal information as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

We do not process or respond to “Do Not Track” signals or other similar transmissions that indicate a request to disable online tracking of users who visit our site or who use our services.

Your Choices and Rights

Your personal data is yours and you have rights over it, including but not limited to:

• the right to be informed about the collection and use of your personal data;
• the right of access to your personal data and any supplementary information;
• the right to have any errors in your personal data rectified;
• the right to have your personal data erased (“right to be forgotten”);
• the right to block or suppress the processing of your personal data;
• the right to move, copy or transfer your personal data from one IT environment to another;
• the right to withdraw your consent of our processing of your personal and data;
• the right to file a complaint with your local supervisory authority;
• the right to object to processing of your personal data in certain circumstances;
• the right to non-discrimination for the same prices and service as those who have and have not exercised their privacy rights (although, as mentioned above, exercising rights such as the right to be forgotten, may prevent you from using our services and certain aspects of our website); and,
• rights related to automated decision-making (i.e., where no humans are involved) and profiling (i.e., where certain personal data is processed to evaluate an individual).

However, after saying all of that, please know there are exceptions to these rights, many examples of which we have listed in this policy.

Updating/Removing Your Personal Information

If you do not want your personal information used by ChatOwl as provided in this Privacy Policy, you should not use the ChatOwl Sites, Apps and Services. You can correct, update or review personal information you have previously submitted by going back to the specific Service, logging-in and making the desired change. You can also update any personal information you have submitted by contacting us using the contact information listed below or through the Contact Us link provided at the bottom of every page of the ChatOwl Sites.

If you have registered and desire to delete any of your registration information you have provided to us from our systems, please contact us through the Contact Us information provided at the bottom of this privacy policy page. Upon your request, we will delete your registration information from our active databases and where feasible from our back-up media. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to the ChatOwl Sites from our servers.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We may also deny your request if the information in question is not subject to the CCPA or similar law. To exercise the rights listed in this Privacy Policy, please submit a written request to us at the contact information provided below. Only you, or the person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may make a request on behalf of a minor if you are the legal parent or guardian. Having said that, we cannot respond to such requests if we cannot verify your identity or the person making the request on your behalf. We will only use the personal information in a request to identify you or authority to make the request. We will also deny requests or charge for these otherwise free requests if you make multiple requests more than once every six months (excessive), repetitive, unfounded, or otherwise unreasonably burdensome. If we do assess a fee, we will let you know before we fulfil your request and time to respond. We really try to respond to such requests within forty-five (45) days, but if we need more time (up to 90 days) we will let you know and the reason for needing more time to respond.

Cookies

Most browser software can be set to reject Cookies. Most browsers offer instructions on how to reset the browser to reject Cookies in the “Help” or “Settings” or “Preferences” section of your browser’s toolbar.

Session Cookies

We use cookies on our website. Cookies are small text files or other storage technologies stored on your computer by your browser. These cookies process certain specific information about you, such as your browser, location data, or IP address. This processing makes our website more user-friendly, efficient, and secure, allowing us, for example, to display our website in different languages or to offer a shopping cart function. When you close your browser, these session cookies are deleted.

Third-Party Cookies

If necessary, our website may also use cookies from companies with whom we cooperate for the purpose of advertising, analyzing, or improving the features of our website. Please refer to the following information for details, in particular for the legal basis and purpose of such third-party collection and processing of data collected through cookies.

Disabling Cookies

You can refuse the use of cookies by changing the settings on your browser. Likewise, you can use the browser to delete cookies that have already been stored. However, the steps and measures required vary, depending on the browser you use. If you have any questions, please use the help function or consult the documentation for your browser or contact its maker for support. Browser settings cannot prevent so-called flash cookies from being set. Instead, you will need to change the setting of your Flash player. The steps and measures required for this also depend on the Flash player you are using. If you have any questions, please use the help function or consult the documentation for your Flash player or contact its maker for support.

If you prevent or restrict the installation of cookies, not all of the functions on our site may be fully usable.

Google Analytics

We use Google Analytics on our website. This is a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google). The Google Analytics service is used to analyze how our website is used. Usage and user-related information, such as IP address, place, time, or frequency of your visits to our website will be transmitted to a Google server in the United States and stored there. However, we use Google Analytics with the so-called anonymization function, whereby Google truncates the IP address before it is transmitted to us. The data collected in this way is in turn used by Google to provide us with an evaluation of visits to our website and what visitors do once there. This data can also be used to provide other services related to the use of our website and of the internet in general. Google states that it will not connect your IP address to other data. In addition, Google provides further information with regard to its data protection practices at:

https://www.google.com/intl/en/policies/privacy/partners including options you can exercise to prevent such use of your data. In addition, Google offers an opt-out add-on at:

https://tools.google.com/dlpage/gaoptout?hl=en in addition with further information. This add-on can be installed on the most popular browsers and offers you further control over the data that Google collects when you visit our website. The add-on informs Google Analytics’ JavaScript (ga.js) that no information about the website visit should be transmitted to Google Analytics. However, this does not prevent information from being transmitted to us or to other web analytics services we may use as detailed herein.

Google Fonts

Our website uses Google Fonts to display external fonts. This is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).

To enable the display of certain fonts on our website, a connection to the Google server in the USA is established whenever our website is accessed. When you access our site, a connection to Google is established from which Google can identify the site from which your request has been sent and to which IP address the fonts are being transmitted for display.

Google offers detailed information at: https://adssettings.google.com/authenticated and https://policies.google.com/privacy in particular on options for preventing the use of data.

Facebook Plug-In

Our website uses the plug-in of the Facebook social network. Facebook.com is a service provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. In the EU, this service is also operated by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, hereinafter both referred to as “Facebook.” Further information about the possible plug-ins and their respective functions is available from Facebook at https://developers.facebook.com/docs/plugins/.

If the plug-in is stored on one of the pages you visit on our website, your browser will download an icon for the plug-in from Facebook’s servers in the USA. For technical reasons, it is necessary for Facebook to process your IP address. In addition, the date and time of your visit to our website will also be recorded. If you are logged in to Facebook while visiting one of our plugged-in websites, the information collected by the plug-in from your specific visit will be recognized by Facebook. The information collected may then be assigned to your personal account at Facebook. If, for example, you use the Facebook Like button, this information will be stored in your Facebook account and published on the Facebook platform. If you want to prevent this, you must either log out of Facebook before visiting our website or use an add-on for your browser to prevent the Facebook plug-in from loading. Further information about the collection and use of data as well as your rights and protection options in Facebook’s privacy policy found at https://www.facebook.com/policy.php.

Advertising and App Stores

We do not currently advertise in our mobile App, but like many Apps we may in the future (we will let you know if we ever decide to advertise in our App). For example, your App store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the App, such as Personal Information, Payment Information, Geolocational Information, and other usage-based data or advertise. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

The App may contain links to third-party websites. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

but if you wish to opt out of third-party interest-based advertising, please visit http://www.networkadvertising.org and http://www.aboutads.info/choices for details on how to do so. Additionally, users of mobile Devices can follow the below instructions:

Android Users

For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising.”

iOS Users

iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting.

iOS 6: Go to your Settings > Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting.

California Residents

California residents have the right to request and obtain from us specific information about disclosures about our privacy practices, including categories of personal information (if any) we disclosed to third parties for direct marketing purposes (such as the right to non-discrimination) and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. To make this request you will need to provide us enough information to identify you, proof of your identity and address, and a description of what right you want to exercise and the information to which your request relates.

If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to access your personally identifiable information and manage your date, including your request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.). Please note that the personally identifiable information and non-personal information that we maintain will be securely deleted or anonymized after we determine there is no longer any reason to process your information or otherwise fulfill our contractual obligations to you, whichever is more appropriate. While we do not hold personal data any longer than we need to, the duration will depend on your relationship with us. Also, if you request us to delete your information, you should realize that that deleting personal information may affect our ability to deliver Services or may result in deleting your account completely.

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as: every individual who is in the State of California for other than a temporary or transitory purpose and every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. All other individuals are defined as “non-residents.” If this definition of “resident” applies to you, we adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of: receiving help through our customer support channels; participation in customer surveys or contests; and, facilitation in the delivery of our Services and to respond to your inquiries. This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to you.

Children

We are committed to protecting the privacy of children. The ChatOwl Sites are not designed or intended to attract children under the age of 16. The ChatOwl Sites do not collect personal information from any person we actually know is under the age of 16. By using the Website, you represent that you are at least 16 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected without verification of parental consent, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any date we may have collected from children under age 18, please contact us at dataprotection@chatowl.com so we can delete that information.

If a parent or guardian assists a minor under 18 to register with ChatOwl, that parent or guardian is solely responsible for providing supervision of the minor’s use of ChatOwl. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through ChatOwl Health Manager for the minor.

Note to Users Outside of the United States

ChatOwl and our technical infrastructure are located in the United States. The personal information that you provide to us is stored on servers located in the United States. If you are located in another jurisdiction, you should be aware that in order to provide the Services to you, we must transfer your personal information to the United States where it will be stored and processed in accordance with this Privacy Policy. We may transfer your information outside the United States to service providers with operations in other countries. By using the Services, you consent to such collection, storage and processing in the United States and elsewhere, though the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal information. Note that your personal information may be available to the United States government or its agencies under legal process made in the United States.

We will retain your personal information for as long as necessary to provide the Services to you and fulfill the purposes described in this Privacy Policy. This is also the case for third parties within whom we share your information to perform services on our behalf. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it. If you have registered with ChatOwl and you no longer want us to use your registration information to provide the Services to you, you may close your account.

Changes to this Privacy Policy

We reserve the right to change or modify this Privacy Policy and any of our Services at any time and any changes will be effective upon being posted unless we advise otherwise. We encourage you to review this policy frequently for changes. If we make any material changes to this Privacy Policy, we may notify you by means of a notice on the ChatOwl Sites and/or by email to our registered users (sent to the email address specified when you register) as a courtesy, but it is your responsibility to check this privacy policy, and our other policies (such as our terms and conditions as well as cookie policy) when you visit our Site and/or use Services. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes. If you do not accept the terms of this Privacy Policy, we ask that you do not register with us and that you do not use the ChatOwl Sites. Please exit the ChatOwl Sites immediately if you do not agree to the terms of this Privacy Policy.

Contacting ChatOwl About Your Personal Information or Privacy

Please send us an email by using the Contact Us link at the bottom of every page of the ChatOwl Sites if you have any questions about this Privacy Policy or the personal information we maintain about you. We will respond to your request within a reasonable timeframe.

You can also contact ChatOwl’s Privacy Office at:

ChatOwl, Inc.
Attn: Data Protection Officer
201 Spear Street, Suite 1100
San Francisco, CA 94105
Phone: 888-997-7570
dataprotection@chatowl.com