Owl Digital Services, LLC
Updated: January 20, 2020
1. Information Collected by Owl Digital Services, LLC
When you use our Website, you may provide Owl Digital Services, LLC with two main types of information: (1) Personal Information or (2) Non-Personal Information and. We collect information from you when you (a) use or access our Website, (b) open or respond to our emails, (c) contact Owl Digital Services, LLC, (c) visit any page online that displays our content, (d) purchase products or services through our Website or phone line, and/or (e) provide information to any of our Service Providers. To view our Website you do not need to submit any Personal Information other than your name, email address, general geographic location, profession and/or industry that you operate in.
1.1 Personal Information
“Personal Information” is personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis. We may ask for certain Personal Information from you for the purpose of providing to you content and/or services that you request.
We collect Personal Information such as your: (i) contact information (including name, address and email); (ii) financial information (such as credit card number, expiration date, verification number and billing address); (iii) contact information of your company and/or other identity information you share with us (including industry or profession); (iv) location information (such as geographic location of the device you are using) and/or (v) preferences and feedback.
1.2 Non-Personal Information
“Non-Personal Information” is general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you use our Website. We collect Non-Personal Information such as:
- Device Data: We use device data, which is information concerning a device you use to access, use, and/or interact with the Website, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.
- Aggregate: We may collect non-identifying and statistical information about the use of our Website, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on. This information represents a generic overview of our users, including their collective habits. Information collected in the aggregate is not associated with you as an individual. We may share user information in the aggregate with third parties.
- Other Tracking Technologies: We may supplement information you provide to us with information from other sources, such as information to validate and/or update your address and/or other demographic information. This information is used to maintain the accuracy of information on our Website and for internal analysis. We may also use clear gifs, pixel tags and web beacons, which are tiny graphic images placed on website pages and/or in our emails that allow us to determine whether you have performed specific actions and are further used to track online movements of our users. In contrast to cookies, which are stored on your computer’s hard drive, clear gifs are embedded invisibly on web pages. We do not tie the information gathered by clear gifs to your Personal Information.
1.3. Information you provide by using the Website
You may submit User Content to the Website, including certain information via online forms. We will not sell the information obtained in any User Content.
1.4. Information you send to other Users
2. How we use and share information
2.1 General Use.
- operate, maintain, and improve our sites, products, and Website;
- respond to comments and questions and provide customer service;
- provide technical support;
- send information including confirmations, invoices, technical notices, updates, security alerts, support and administrative messages;
- communicate about promotions, upcoming events, other news about products and services offered by us and our selected partners;
- send you reminders, support and marketing messages;
- manage our administration of the Website;
- link or combine user information with other Personal Information we get from third parties, to help understand your needs and provide you with better service;
- perform analytics and conduct research;
- protect, investigate, and deter against fraudulent, unauthorized and/or illegal activity;
- to process orders and/or otherwise provide and deliver products and services you request;
- to process and deliver orders for additional services;
- identify you as a user in our system;
- facilitate the creation of and secure your Account on our network; and/or
- develop and improve marketing and advertising for the Website and partner services.
The information collected in the aggregate enables Owl Digital Services, LLC to better understand your use of the Website and to enhance your enjoyment. We may use financial information to process payment for any purchases made on the Website, enroll you in one of our accounts and/or other related services in which you elect to participate. If you use the Website, you agree to receive certain communications from us including but not limited to the following:
Special Offers, Newsletters and Updates. We will occasionally send you information on products, special deals, promotions and newsletters. You can sign up for these emails from us at any time on our website. Out of respect for your privacy, you may elect not to receive these types of communications by changing your account setting through the Website.
Customer Service. Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries, to provide the services you request and to manage your account. We will communicate with you by email or telephone, as you may elect.
Supplementation of Information. In order to process your credit card orders, we use a third party provider to validate and verify your account information. All billing and account information is transmitted via https, which is a secure encrypted protocol system.
2.2 Parties with whom we may share your information:
We also may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. For example, we will disclose your Personal Information in the following circumstances: (i) to investigate and defend Owl Digital Services, LLC members against any third party claims and/or allegations and/or otherwise to protect Owl Digital Services, LLC from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Website and/or (v) to protect the security and/or integrity of the Service. In response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can (and you authorize us to) disclose your name, city, state, telephone number, email address, user ID history, fraud complaints, and usage history, without a subpoena, in connection with an investigation of fraud, intellectual property infringement, piracy, and/or other unlawful activity.
2.4 Business Transitions
3. Information Choices
Depending on the situation, Owl Digital Services, LLC may obtain consent to the collection of Personal Information in different ways. Express consent may be obtained verbally, online and/or in writing. Implied consent may be obtained through your use of our Website and related services, and/or when you approach us to obtain information, inquire about or request services from us. Owl Digital Services, LLC will offer individuals the opportunity to choose (opt out) whether their Personal Information is to be used for any purpose other than what it was collected for. We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to Owl Digital Services, LLC, and you can limit the communications that Owl Digital Services, LLC sends to you. If you visit our Website and volunteer personally identifiable information, you can opt out of receiving notifications, and you may review, modify, update, and/or delete such Personal Information by contacting us and/or by changing your preferences on the Website. Please be aware that even after your request for a change is processed, Owl Digital Services, LLC may, for a time, retain residual information about you in its backup and/or archival copies of its database. Please be aware that we may still email you non-commercial emails related to your account and your transactions through our Website. Owl Digital Services, LLC may retain information (including without limitation your account information) for a commercially reasonable time for backup, archival, and/or audit purposes. In some cases, if you choose not to provide Owl Digital Services, LLC with requested information, you may not be able to use and/or access our Website.
3.1 California Privacy Rights
California residents are entitled to receive: (a) information identifying any third party companies to whom Owl Digital Services, LLC may have disclosed Personal Information for direct marketing, within the past year; and (b) a description of the categories of Personal Information disclosed. To obtain such information, please email your request to firstname.lastname@example.org and we will provide a list of categories of Personal Information disclosed within thirty (30) days after receiving such a request. We reserve the right not to respond to requests submitted in ways other than those specified above.
Notice to California Residents
Under the California Consumer Privacy Act (CCPA), effective January 1, 2020, consumers have the right to:
- Request access to the personal information we hold about them
- Request we delete the personal information from our database
- Not be discriminated against for exercising these rights or requests
RIGHT TO REQUEST ACCESS TO YOUR INFORMATION
Consumers (California residents) have the right to request that Owl Digital Services, LLC disclose certain information to you about our collection and usage of personal information over the past 12 months. Once your request has been received and we confirm your verified consumer request, we will disclose to you:
- What categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our company’s purpose for collecting or selling (if applicable) your personal information.
- The categories of third parties with whom we shared your personal information.
- The specific pieces of personal information we collected about you (AKA: data portability request).
- If we disclosed or sold your personal information for business purposes, disclosing:
– Sales, identifying the personal information categories that each category of recipient purchased, and
– Disclosures for a business purpose, identifying personal information categories that each category of recipient obtained.
RIGHT TO REQUEST DELETION OF YOUR INFORMATION
Consumers have the right to request the deletion of personal information that Owl Digital Services, LLC holds on you. However, this does not apply where we need to retain information in order to do any of the following:
- Comply with a federal or state law(s)
- Safeguard the right to free speech
- Detect or resolve security or functionality-related issues
- Provide goods or services to the consumer
- Carry out any actions for internal purposes that the consumer might expect
- Conduct research in the public interest
RIGHT TO NON-DISCRIMINATION OVER EXERCISING YOUR RIGHTS
Consumers have the right to not be discriminated against for exercising their rights to request access to personal information. Owl Digital Services, LLC may not:
- Deny the consumer goods or services
- Threaten the consumer
- Provide the consumer with a different level of quality of services or goods being provided
- Charge the consumer different prices of services or goods
CATEGORIES OF PERSONAL INFORMATION
The CCPA entails 11 (eleven) Categories of what is considered to be personal information, any/all of which you can request access to. These 11 Categories are as follows:
- Identifiers. Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
- Geolocation data. Physical location, general residency.
- Customer records information. Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, other financial information, medical information, health insurance information.
- Characteristics of protected classifications under California or federal law. Race, religion, sexual orientation, gender identity, gender expression, age.
- Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information. Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data.
- Internet or other electronic network activity information. Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
- Audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment-related information.
- Education information. Information that is not “publicly available personally identifiable information” as defined in the California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
- Inferences. Potential profiling or reflecting of a consumer’s:
– Psychological trends
“Personal information” does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
CATEGORIES OF SOURCES WE COLLECT PERSONAL INFORMATION FROM:
- Directly from you. For example, forms, phone calls, contact information you willfully give to us through our Website, verbal conversation, or written files.
- Indirectly from you. For example, from observing your navigation of our Website or interactions with our staff online or advertisements on the Internet.
- Information we receive as part of routine payment verification fraud checks.
- Social networking information, including Social media; personal information shared with us from a logged-in social media account. The information transferred may depend on your security settings and the privacy policies of your social media networks.
- Publicly accessible databases.
- Joint marketing partners, when/if they share information with us.
USE OF PERSONAL INFORMATION
We may use or disclose personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name, phone number, and/or contact information in your request for a price quote, product or service, informational content from our website or social networks, or general contact question. In these instances, we will use that personal information to respond to you at your request. If you give your personal information to purchase a product or service, that information will be used to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, develop, personalize, or improve our websites, products, or services.
- To create, customize, maintain, monitor, and secure your account with us.
- To provide you with the support and response in relation to your inquiries, including to address or investigate your concerns. We may also use this information to monitor and improve our responses.
- To process your requests, purchases, transactions, and payments; as well as to prevent transactional failure or financial fraud.
- To deliver the appropriate products or services intended according to your expressed needs, as to be facilitated only by staff under the supervision of Owl Digital Services, LLC.
PERSONAL INFORMATION DISCLOSED FOR BUSINESS PURPOSES
Under the CCPA, the 7 (seven) categories of activities that are considered to be “business purposes” are:
- Short-term uses
- Performing services
- Internal research / Tech Development
- Testing or improvements to quality or safety
4. Service Eligibility and Changes
4.1 Children and Minors
Owl Digital Services, LLC does not knowingly collect personally identifiable information from children under the age of thirteen (13). If we learn that we have collected Personal Information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us Personal Information, please contact us at email@example.com. By using the Website, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services we offer in person or through the Website.
5. Other websites and services
6. How we protect information
We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. We periodically review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. Because the internet is not a completely secure environment, Owl Digital Services, LLC cannot warrant the security of any information you transmit to Owl Digital Services, LLC or guarantee that information on the Website may not be accessed, disclosed, altered and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. In addition, while we take reasonable measures to ensure that Service Providers keep your information confidential and secure, such Service Provider’s practices are ultimately beyond our control. We are not responsible for the functionality, privacy and/or security measures of any other organization. By using our Website, you acknowledge that you understand and agree to assume these risks.
8. How to contact us