Information Collected About You
Having said that, when you use the Services, we collect information as follows:
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.
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
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
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
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.
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.
If you prevent or restrict the installation of cookies, not all of the functions on our site may be fully usable.
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:
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.
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/.
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.
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:
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 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 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:
|A. Identifiers||Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name||YES|
|B. Personal information categories listed in the California Customer Records statute||Name or contact information or education or employment or employment history or|
|C. Protected classification characteristics under California or federal law||Gender and date of birth||YES|
|D. Commercial information||Transaction information, purchase history, financial details and payment information||NO|
|E. Biometric information||Fingerprints and voiceprints||NO|
|F. Internet or other similar network activity||Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements||YES|
|G. Geolocation data||Device location||NO|
|H. Audio, electronic, visual, thermal, olfactory, or similar information||Images and audio, video or call recordings created in connection with our business activities||NO|
|I. Professional or employment- related information||Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us||NO|
|J. Education Information||Student records and directory information||NO|
|K. Inferences drawn from other personal information||Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics||NO|
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.
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 firstname.lastname@example.org 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
Contacting ChatOwl About Your Personal Information or Privacy
You can also contact ChatOwl’s Privacy Office at:
Attn: Data Protection Officer
201 Spear Street, Suite 1100
San Francisco, CA 94105