NEMO Enterprises Inc. (registered in Delaware, USA hereinafter “OWN, "us ","we " or"our ") has created the following Privacy Policy to communicate to you clearly and conclusively how Own processes (including collection, use, transferring, storage, deletion, etc.) your personal information. The Privacy Policy informs you about your rights as a data subject. The Privacy Policy is an integral part of the agreements between you and Own. At Own, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our informational website or the Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Remember that your use of OWN'S Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
You may print a copy of this Privacy Policy by clicking here.
As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the OWN website, by sending you an email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't OWN or control or people we don't manage. NOTE: OWN's Services are operated in a manner that does not require OWN to store any Personal Data from users long term. You will receive a unique OWN User ID when you sign up for an account. OWN then stores anonymous index data, designating which attributes or features of the OWN Services are activated and used by a respective user to ensure proper functionality of the Services between OWN users. OWN will never store any user Content (including Personal Data) without your consent. OWN may temporarily store your Personal Data during the onboarding and sign up process to activate a new OWN account. This Personal Data is processed temporarily and removed from our servers, after completion of a new account registration. All other Personal Data that you may provide or otherwise use in the process of using the Services, including any Content, details of users you connect with, biometric data, and username and passwords, are stored in a personal, encrypted data cluster at the device level, and are only accessible to you as a user of OWN as well as any other users you choose to share that Personal Data with.
This chart details the categories of Personal Data that we collect and have collected over the past 12 months, in accordance with the description above:
| Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share this Personal Data: |
|---|---|---|
Profile or Contact Data |
| NONE |
Payment Data |
|
|
Location Data |
|
|
Inferences Drawn From Other Personal Data Collected |
|
|
The Services offer you the option to allow OWN access to your mobile device's address book to review your contacts data, in order to facilitate seamless updates to your contacts list whenever you connect with fellow users within the App. This feature enhances the convenience of communication by ensuring your contacts stay up-to-date effortlessly. It's important to note that granting permission for this access is entirely voluntary, requires affirmative opt-in, and won't affect the essential functions of the App. Should you ever wish to manage or revoke this access, you have full control through the App's “Permissions” settings.
By opting to allow OWN access to your phone's address book and phone contacts data, the Services will not generate local nor cloud copies of your phone contacts data under any circumstances.
Categories of Sources of Personal Data We collect Personal Data about you from the following categories of sources:We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
We may disclose your Personal Data in aggregated, anonymized form to the categories of service providers and other parties listed in this section. Excluded from this is all personal data or content that you contributed, uploaded or gained by exchanging personal data with other own users into your own app.
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
The informational website portion of the Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data- usually text files - placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by click here. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. For example, we only retain your email address and phone number so long as required to provision a new account. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
The Children's Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 years of age. We do not knowingly collect or solicit personally identifiable information from a child under 13. In accordance with our Terms, users must be fourteen years of age or older.
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers' end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@iown.app.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient. WE DO NOT CURRENTLY DO EITHER OF THESE THINGS.
DeletionYou have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request. HOWEVER, WE DO NOT STORE YOUR PERSONAL DATA LONG TERM ON OUR SERVERS, SO A DELETION REQUEST IS NOT CURRENTLY NECESSARY OR POSSIBLE.
CorrectionYou have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request. HOWEVER, WE DO NOT STORE YOUR PERSONAL DATA LONG TERM ON OUR SERVERS, SO A CORRECTION REQUEST IS NOT CURRENTLY NECESSARY OR POSSIBLE.
Processing of Sensitive Personal Information Opt-OutConsumers have certain rights over the processing of their sensitive information. HOWEVER, WE DO NOT COLLECT SENSITIVE CATEGORIES OF PERSONAL INFORMATION.
Personal Data SalesWe will not sell your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell the Personal Data of minors under 18 years of age.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPAWe will not discriminate against you for exercising your rights under the CCPA. We will not deny you our services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act ("VCDPA"). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers' end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@iown.app.
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data. HOWEVER, WE DO NOT STORE YOUR PERSONAL DATA LONG TERM ON OUR SERVERS, SO AN ACCESS REQUEST IS NOT CURRENTLY NECESSARY OR POSSIBLE.
CorrectionYou have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data. HOWEVER, WE DO NOT STORE YOUR PERSONAL DATA LONG TERM ON OUR SERVERS, SO A CORRECTION REQUEST IS NOT CURRENTLY NECESSARY OR POSSIBLE.
PortabilityYou have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible. HOWEVER, WE DO NOT STORE YOUR PERSONAL DATA LONG TERM ON OUR SERVERS, SO A PORTABILITY REQUEST IS NOT CURRENTLY NECESSARY OR POSSIBLE.
DeletionYou have the right to delete your Personal Data. HOWEVER, WE DO NOT STORE YOUR PERSONAL DATA LONG TERM ON OUR SERVERS, SO A DELETION REQUEST IS NOT CURRENTLY NECESSARY OR POSSIBLE.
Opt-Out of Certain Processing ActivitiesIf we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.
You may appeal a decision by us using the following methods:To exercise the rights described in this Privacy Policy, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes. We do not currently make such disclosures.
Nevada Resident RightsIf you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting us at support@iown.app with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. However, we do not currently make such sales.
EU Data Subject RightsYou have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at support@iown.app. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. KEEP IN MIND THE LIMITED APPLICABILITY OF MOST OF THESE RIGHTS, GIVEN THAT OWN DOES NOT STORE YOUR PERSONAL DATA ON OUR SERVERS LONG TERM.
The Services are hosted and operated in the United States ("U.S.") through OWN and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to OWN in the U.S. and will be hosted (temporarily) on U.S. servers, and you authorize OWN to transfer, store and process your information to and in the U.S., and possibly other countries.
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: