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Privacy Policy

 

Effective as of: June 5, 2023

Last updated: N/A

This Privacy Policy describes the privacy practices of Owl Tower Group, Inc. (“OTG”, “we”) in connection with OTG’s online products and services (collectively, “Services”).

Our Privacy Policy explains what information about you we collect, how we collect it, how we use it and for what purposes. This Privacy Policy is an integral part of our Terms of Service.

If you have any questions about our privacy practices or our Services, please contact us by email at info@owltower.group, or by post at 5425 Grosvenor Blvd, Los Angeles, CA 90066.

 

1. Personal Information We Collect

The information we collect depends on the context of your interaction with our Services and the choices you make (including your privacy settings), the Services and features you use, your location, and applicable law. 

When you interact with our Services, we may collect the following information about you:

 

  • Name and contact information, such as first and last name, phone number, email address, postal address and other similar information, when you contact us, register an account with us, or provide your existing account ID associated with a third-party platform to access our Services.

 

  • Usage information, such as information about how you use the Services and interact with us, including your preferred language, the date and time when you first used the Services and the date and time you last used the Services. 

 

  • Social media information, if you use your third-party platform or social media network account, or otherwise connect your account on the third-party platform or network to the Services. We may collect information from that platform or network, such as your social media alias, first and last name, number of “friends'' on the social media platform and, depending on your network settings, a list of your friends or connections. Our collection and processing of the information we obtain from social media platforms is governed by the requirements these social media platforms impose on us in their relevant terms and conditions.

 

  • Device data, such as your computer and mobile device operating system type and version number, manufacturer and model, device ID, push tokens, browser type, screen resolution, IP address (and the associated country and town in which you are located), the websites you visited before visiting our Services; and other information about the device you are using to visit the Services.

 

  • Online activity data, such as information about your use of and actions on the Services, including pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and certain third parties (e.g., online advertising networks and their clients) also may collect this type of information over time and across third-party websites and mobile applications. This information may be collected on our Services using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies. We may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our App.

 

2. How We Use Your Information


We may use your information for the following purposes:

To operate and improve the Services:

 

  • Enable you to use the features of the Services;

 

  • Establish and maintain your account, if you choose to login to the Services using your social media account;

 

  • Communicate with you about the Services, including by sending you announcements, updates, and security alerts, which we may send through a push notification, and responding to your requests, questions and feedback;

 

  • Provide technical support and maintenance for the Services;

 

  • Perform statistical analysis about use of the Services (including through the use of Google Analytics).

 

To send you marketing and promotional communications. We may send you marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the “Opt out of marketing” section below.

To display advertisements to you. We may work with advertising partners to display advertisements within the Services. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the “Targeted online advertising” section below.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes.

 

3. How We Share Your Information

 

We may share your personal information with third parties who may use it only as directed by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose. 

We may share your personal information in the following circumstances:

Affiliates. We may share “Services usage information” with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with service providers that perform services on our behalf or help us operate the Services (such as customer support, hosting, analytics, email delivery, marketing, and database management services). 

Advertising partners. When we use third-party cookies and other tracking tools, our advertising partners may collect information from your device to help us analyze use of the Services, and advertise the Services (and related content) elsewhere online.

Third-party platforms and social media networks. Some of our Services may be accessible only through third-party platforms or may have features or functionality that connect the Services to a third-party platform or social media network (such as by logging into the Services using your account with the third-party, providing your API key or similar access token for the Services to a third-party, or otherwise linking your account with the Services to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third-party platforms’ use of your personal information, which is governed by that third party’s privacy policy and terms and conditions.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

To comply with the law. We may be required to use and share your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

 

4. Your Choices

 

In this section, we describe the rights and choices available to all users. Users who are located within the European Union can find additional information about their rights below.

Opt out of marketing communications and other push notifications. You may opt out of marketing-related communications and other notifications we may send you via push notification by changing the settings on your device.

Device permissions. You may revoke any permissions you previously granted to us through the settings on your device.

Cookies & Browser Web Storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Services may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Services may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Website users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. App users may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your device.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Services. We will tell you what information you must provide to use the Services by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the Services via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third party at the time you login to the Services using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.

 

5. Other Sites, Mobile Applications and Services

 

The Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

 

6. Security Practices

 

We use commercially reasonable security practices to help keep the information collected through the Services secure and take reasonable steps to verify your identity before granting you access to your account (if you have an account with us). However, we cannot ensure the security of any information you transmit to us or guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed.

Please do your part to help us. You are responsible for maintaining the confidentiality of your login information and device identifiers, and for controlling access to communications between you and OTG, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.

 

7. Retention

 

With respect to personal information that we may collect, we will retain such information in a personally identifiable format only for as long as necessary to fulfill the purposes we have set out in this Privacy Policy, such as to the extent necessary to comply with our legal obligations, resolve disputes, enforce our legal agreements and policies, and for internal analysis purposes. You may also ask that we delete your information by contacting us at info@owltower.group.

 

8. Transfer of Your Personal Information

 

We do not store the information we collect in connection with the Services. However, if you are accessing Services through a third-party platform, that platform may store some of your information in a location and on terms specified in that platform’s Terms of Service or elsewhere. 

We will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and not transfer of your personal information will take place to an organization or country unless there are adequate controls in place including the security of your information.

Your consent to this Privacy Policy followed by your submission of personal information represents your consent to the transfer.

 

9. Children

 

The Services are not directed at children under the age of 13, and our Terms of Service do not allow children under 13 years of age to use the Services. We may offer additional Services that may require you to be older than 13 years old to access or use them. If we learn that we have collected personal information of a child under the age of 13, we will delete it. We encourage parents with concerns to contact us. 

 

10. Do Not Track Signals

 

We do not sell your personal information, so our Services do not respond to Do Not Track signals.

 

11. Changes to the Privacy Policy

 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services. We may, and if required by law, will provide notification of changes in another way that we believe is reasonably likely to reach you, such as through the Services.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

 

Notice to European Users

 

The information provided in this “Notice to European Users” section applies only to individuals who reside in the European Union.

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller and EU Representative. OTG is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described below.

 

Processing Purpose

 

  • To operate and improve the Services

 

  • To send you marketing and promotional communications

 

  • To display advertisements to you

 

  • To create anonymous, aggregated or de-identified data

 

  • With your consent

 

Legal Basis

 

  • Processing is necessary to perform the contract governing our provision of services in connection with the Services, or to take steps that you request prior to using for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Services you access and request.

 

  • For compliance, fraud prevention, and safety

 

  • These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

 

  • Processing is based on your consent. Where we rely on your consent, you have the right to withdraw it any time in the manner indicated when you consent or in the Privacy Policy.

 

YOUR RIGHTS

European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:

  • Right of Access. Provide you with information about our processing of your personal information and give you access to your personal information.

 

  • Right to Rectification. Update or correct inaccuracies in your personal information. We may refuse to change your data if the proposed change contains inaccurate information.

 

  • Right to Erasure. Delete your personal information under certain circumstances.

 

  • Right to Data Portability. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

 

  • Right to Restrict Processing. Restrict the processing of your personal information.

 

  • Right to Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

 

You may submit these requests by email to info@owltower.group or our postal address provided above.

If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.