Privacy Policy

Last updated: March 16, 2022

This Privacy Policy describes Our policies and procedures on the collection,

use and disclosure of Your information when You use the Service and tells You

about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the

Service, You agree to the collection and use of information in accordance with

this Privacy Policy.

Interpretation and Definitions

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Interpretation

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The words of which the initial letter is capitalized have meanings defined

under the following conditions. The following definitions shall have the same

meaning regardless of whether they appear in singular or in plural.

Definitions

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For the purposes of this Privacy Policy:

* Account means a unique account created for You to access our Service or

parts of our Service.

* Affiliate means an entity that controls, is controlled by or is under

common control with a party, where "control" means ownership of 50% or

more of the shares, equity interest or other securities entitled to vote

for election of directors or other managing authority.

* Application means the software program provided by the Company downloaded

by You on any electronic device, named Owly Personal Document Manager

* Company (referred to as either "the Company", "We", "Us" or "Our" in this

Agreement) refers to Owly Personal Document Manager.

For the purpose of the GDPR, the Company is the Data Controller.

* Country refers to: Baden-Württemberg, Germany

* Data Controller , for the purposes of the GDPR (General Data Protection

Regulation), refers to the Company as the legal person which alone or

jointly with others determines the purposes and means of the processing of

Personal Data.

* Device means any device that can access the Service such as a computer, a

cellphone or a digital tablet.

* Do Not Track (DNT) is a concept that has been promoted by US regulatory

authorities, in particular the U.S. Federal Trade Commission (FTC), for

the Internet industry to develop and implement a mechanism for allowing

internet users to control the tracking of their online activities across

websites.

* Personal Data is any information that relates to an identified or

identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to

You such as a name, an identification number, location data, online

identifier or to one or more factors specific to the physical,

physiological, genetic, mental, economic, cultural or social identity.

* Service refers to the Application.

* Service Provider means any natural or legal person who processes the data

on behalf of the Company. It refers to third-party companies or

individuals employed by the Company to facilitate the Service, to provide

the Service on behalf of the Company, to perform services related to the

Service or to assist the Company in analyzing how the Service is used. For

the purpose of the GDPR, Service Providers are considered Data Processors.

* Usage Data refers to data collected automatically, either generated by the

use of the Service or from the Service infrastructure itself (for example,

the duration of a page visit).

* You means the individual accessing or using the Service, or the company,

or other legal entity on behalf of which such individual is accessing or

using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as

the Data Subject or as the User as you are the individual using the

Service.

Collecting and Using Your Personal Data

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Types of Data Collected

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Personal Data

~~~~~~~~~~~~~

While using Our Service, We may ask You to provide Us with certain personally

identifiable information that can be used to contact or identify You.

Personally identifiable information may include, but is not limited to:

* Email address

* Usage Data

Usage Data

~~~~~~~~~~

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol

address (e.g. IP address), browser type, browser version, the pages of our

Service that You visit, the time and date of Your visit, the time spent on

those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect

certain information automatically, including, but not limited to, the type of

mobile device You use, Your mobile device unique ID, the IP address of Your

mobile device, Your mobile operating system, the type of mobile Internet

browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our

Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

While using Our Application, in order to provide features of Our Application,

We may collect, with Your prior permission:

* Pictures and other information from your Device's camera and photo library

We use this information to provide features of Our Service, to improve and

customize Our Service. The information may be uploaded to the Company's

servers and/or a Service Provider's server or it may be simply stored on Your

device.

You can enable or disable access to this information at any time, through Your

Device settings.

Use of Your Personal Data

-------------------------

The Company may use Personal Data for the following purposes:

* To provide and maintain our Service , including to monitor the usage of

our Service.

* To manage Your Account: to manage Your registration as a user of the

Service. The Personal Data You provide can give You access to different

functionalities of the Service that are available to You as a registered

user.

* For the performance of a contract: the development, compliance and

undertaking of the purchase contract for the products, items or services

You have purchased or of any other contract with Us through the Service.

* To contact You: To contact You by email, telephone calls, SMS, or other

equivalent forms of electronic communication, such as a mobile

application's push notifications regarding updates or informative

communications related to the functionalities, products or contracted

services, including the security updates, when necessary or reasonable for

their implementation.

* To provide You with news, special offers and general information about

other goods, services and events which we offer that are similar to those

that you have already purchased or enquired about unless You have opted

not to receive such information.

* To manage Your requests: To attend and manage Your requests to Us.

* For business transfers: We may use Your information to evaluate or conduct

a merger, divestiture, restructuring, reorganization, dissolution, or

other sale or transfer of some or all of Our assets, whether as a going

concern or as part of bankruptcy, liquidation, or similar proceeding, in

which Personal Data held by Us about our Service users is among the assets

transferred.

* For other purposes : We may use Your information for other purposes, such

as data analysis, identifying usage trends, determining the effectiveness

of our promotional campaigns and to evaluate and improve our Service,

products, services, marketing and your experience.

We may share Your personal information in the following situations:

* With Service Providers: We may share Your personal information with

Service Providers to monitor and analyze the use of our Service, for

payment processing, to contact You.

* For business transfers: We may share or transfer Your personal information

in connection with, or during negotiations of, any merger, sale of Company

assets, financing, or acquisition of all or a portion of Our business to

another company.

* With Affiliates: We may share Your information with Our affiliates, in

which case we will require those affiliates to honor this Privacy Policy.

Affiliates include Our parent company and any other subsidiaries, joint

venture partners or other companies that We control or that are under

common control with Us.

* With business partners: We may share Your information with Our business

partners to offer You certain products, services or promotions.

* With other users: when You share personal information or otherwise

interact in the public areas with other users, such information may be

viewed by all users and may be publicly distributed outside.

* With Your consent : We may disclose Your personal information for any

other purpose with Your consent.

Retention of Your Personal Data

-------------------------------

The Company will retain Your Personal Data only for as long as is necessary

for the purposes set out in this Privacy Policy. We will retain and use Your

Personal Data to the extent necessary to comply with our legal obligations

(for example, if we are required to retain your data to comply with applicable

laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage

Data is generally retained for a shorter period of time, except when this data

is used to strengthen the security or to improve the functionality of Our

Service, or We are legally obligated to retain this data for longer time

periods.

Transfer of Your Personal Data

------------------------------

Your information, including Personal Data, is processed at the Company's

operating offices and in any other places where the parties involved in the

processing are located. It means that this information may be transferred to —

and maintained on — computers located outside of Your state, province, country

or other governmental jurisdiction where the data protection laws may differ

than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such

information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data

is treated securely and in accordance with this Privacy Policy and no transfer

of Your Personal Data will take place to an organization or a country unless

there are adequate controls in place including the security of Your data and

other personal information.

Disclosure of Your Personal Data

--------------------------------

Business Transactions

~~~~~~~~~~~~~~~~~~~~~

If the Company is involved in a merger, acquisition or asset sale, Your

Personal Data may be transferred. We will provide notice before Your Personal

Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

~~~~~~~~~~~~~~~

Under certain circumstances, the Company may be required to disclose Your

Personal Data if required to do so by law or in response to valid requests by

public authorities (e.g. a court or a government agency).

Other legal requirements

~~~~~~~~~~~~~~~~~~~~~~~~

The Company may disclose Your Personal Data in the good faith belief that such

action is necessary to:

* Comply with a legal obligation

* Protect and defend the rights or property of the Company

* Prevent or investigate possible wrongdoing in connection with the Service

* Protect the personal safety of Users of the Service or the public

* Protect against legal liability

Security of Your Personal Data

------------------------------

The security of Your Personal Data is important to Us, but remember that no

method of transmission over the Internet, or method of electronic storage is

100% secure. While We strive to use commercially acceptable means to protect

Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

============================================================

The Service Providers We use may have access to Your Personal Data. These

third-party vendors collect, store, use, process and transfer information

about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

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We may use third-party Service providers to monitor and analyze the use of our

Service.

* Google Analytics

Google Analytics is a web analytics service offered by Google that tracks

and reports website traffic. Google uses the data collected to track and

monitor the use of our Service. This data is shared with other Google

services. Google may use the collected data to contextualize and

personalize the ads of its own advertising network.

You may opt-out of certain Google Analytics features through your mobile

device settings, such as your device advertising settings or by following

the instructions provided by Google in their Privacy Policy:

<https://policies.google.com/privacy>

For more information on the privacy practices of Google, please visit the

Google Privacy & Terms web page: <https://policies.google.com/privacy>

* Firebase

Firebase is an analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device

settings, such as your device advertising settings or by following the

instructions provided by Google in their Privacy Policy:

<https://policies.google.com/privacy>

We also encourage you to review the Google's policy for safeguarding your

data: <https://support.google.com/analytics/answer/6004245>

For more information on what type of information Firebase collects, please

visit the How Google uses data when you use our partners' sites or apps

webpage: <https://policies.google.com/technologies/partner-sites>

* Matomo

Matomo is a web analytics service. You can visit their Privacy Policy page

here: <https://matomo.org/privacy-policy>

* Mixpanel

Mixpanel is provided by Mixpanel Inc.

You can prevent Mixpanel from using your information for analytics

purposes by opting-out. To opt-out of Mixpanel service, please visit this

page: <https://mixpanel.com/optout/>

For more information on what type of information Mixpanel collects, please

visit the Terms of Use page of Mixpanel: <https://mixpanel.com/terms/>

Payments

--------

We may provide paid products and/or services within the Service. In that case,

we may use third-party services for payment processing (e.g. payment

processors).

We will not store or collect Your payment card details. That information is

provided directly to Our third-party payment processors whose use of Your

personal information is governed by their Privacy Policy. These payment

processors adhere to the standards set by PCI-DSS as managed by the PCI

Security Standards Council, which is a joint effort of brands like Visa,

Mastercard, American Express and Discover. PCI-DSS requirements help ensure

the secure handling of payment information.

* Stripe

Their Privacy Policy can be viewed at <https://stripe.com/us/privacy>

Usage, Performance and Miscellaneous

------------------------------------

We may use third-party Service Providers to provide better improvement of our

Service.

* Mouseflow

Mouseflow is a session replay and heatmap tool that shows how visitors

click, move, scroll, browse, and pay attention on websites. The service is

operated by ApS.

Mouseflow service may collect information from Your device.

The information gathered by Mouseflow is held in accordance with its

* FreshDesk

FreshDesk is a customer support software. The service is operated by

Freshworks, Inc.

FreshDesk service may collect information from Your Device.

The information gathered by FreshDesk is held in accordance with its

GDPR Privacy

============

Legal Basis for Processing Personal Data under GDPR

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We may process Personal Data under the following conditions:

* Consent: You have given Your consent for processing Personal Data for one

or more specific purposes.

* Performance of a contract: Provision of Personal Data is necessary for the

performance of an agreement with You and/or for any pre-contractual

obligations thereof.

* Legal obligations: Processing Personal Data is necessary for compliance

with a legal obligation to which the Company is subject.

* Vital interests: Processing Personal Data is necessary in order to protect

Your vital interests or of another natural person.

* Public interests: Processing Personal Data is related to a task that is

carried out in the public interest or in the exercise of official

authority vested in the Company.

* Legitimate interests: Processing Personal Data is necessary for the

purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis

that applies to the processing, and in particular whether the provision of

Personal Data is a statutory or contractual requirement, or a requirement

necessary to enter into a contract.

Your Rights under the GDPR

--------------------------

The Company undertakes to respect the confidentiality of Your Personal Data

and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the

EU, to:

* Request access to Your Personal Data. The right to access, update or

delete the information We have on You. Whenever made possible, you can

access, update or request deletion of Your Personal Data directly within

Your account settings section. If you are unable to perform these actions

yourself, please contact Us to assist You. This also enables You to

receive a copy of the Personal Data We hold about You.

* Request correction of the Personal Data that We hold about You. You have

the right to have any incomplete or inaccurate information We hold about

You corrected.

* Object to processing of Your Personal Data. This right exists where We are

relying on a legitimate interest as the legal basis for Our processing and

there is something about Your particular situation, which makes You want

to object to our processing of Your Personal Data on this ground. You also

have the right to object where We are processing Your Personal Data for

direct marketing purposes.

* Request erasure of Your Personal Data. You have the right to ask Us to

delete or remove Personal Data when there is no good reason for Us to

continue processing it.

* Request the transfer of Your Personal Data. We will provide to You, or to

a third-party You have chosen, Your Personal Data in a structured,

commonly used, machine-readable format. Please note that this right only

applies to automated information which You initially provided consent for

Us to use or where We used the information to perform a contract with You.

* Withdraw Your consent. You have the right to withdraw Your consent on

using your Personal Data. If You withdraw Your consent, We may not be able

to provide You with access to certain specific functionalities of the

Service.

Exercising of Your GDPR Data Protection Rights

----------------------------------------------

You may exercise Your rights of access, rectification, cancellation and

opposition by contacting Us. Please note that we may ask You to verify Your

identity before responding to such requests. If You make a request, We will

try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our

collection and use of Your Personal Data. For more information, if You are in

the European Economic Area (EEA), please contact Your local data protection

authority in the EEA.

"Do Not Track" Policy as Required by California Online Privacy Protection Act

(CalOPPA)

========================================================================

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities.

If You are visiting such websites, You can set Your preferences in Your web

browser to inform websites that You do not want to be tracked. You can enable

or disable DNT by visiting the preferences or settings page of Your web

browser.

Children's Privacy

==================

Our Service does not address anyone under the age of 13. We do not knowingly

collect personally identifiable information from anyone under the age of 13.

If You are a parent or guardian and You are aware that Your child has provided

Us with Personal Data, please contact Us. If We become aware that We have

collected Personal Data from anyone under the age of 13 without verification

of parental consent, We take steps to remove that information from Our

servers.

If We need to rely on consent as a legal basis for processing Your information

and Your country requires consent from a parent, We may require Your parent's

consent before We collect and use that information.

Links to Other Websites

=======================

Our Service may contain links to other websites that are not operated by Us.

If You click on a third party link, You will be directed to that third party's

site. We strongly advise You to review the Privacy Policy of every site You

visit.

We have no control over and assume no responsibility for the content, privacy

policies or practices of any third party sites or services.

Changes to this Privacy Policy

==============================

We may update Our Privacy Policy from time to time. We will notify You of any

changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior

to the change becoming effective and update the "Last updated" date at the top

of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.

Changes to this Privacy Policy are effective when they are posted on this

page.

==========

If you have any questions about this Privacy Policy, You can contact us:

* By email: info@owly.one

* By phone number: +4962213543276

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