Site Privacy Policy

OwlPay Site Privacy Policy

OwlTing cares about the security and privacy of your personal data. This Privacy Policy is between you and OwlTing USA, Inc. ("OwlTing" "we," "us," or "our") and explains how we collect, use, and share information we collect about you. This Privacy Policy describes our practices in connection with information collected through our OwlPay website ("Site").

1. Personal Data We Collect

We may collect the following types of information when you visit or interact with our Site:

• Personal Information: Your name, email address, phone number, mailing address, or other identifiers that you provide voluntarily (e.g., through forms, account sign-ups, or customer support inquiries).
• Usage Data: Information about your interactions with the Site, such as IP address, browser type, device information, pages visited, and time spent on pages.
• Cookies and Tracking Technologies: We may use cookies, web beacons, and other tracking tools to personalize your experience and analyze Site traffic.

2. How We Use Personal Data

We rely upon a number of legal grounds to enable our use of your personal data. We use personal data to facilitate the business relationships we have with our users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. The information we collect allows us to:

• Contractual and Pre-Contractual Business Relationships: To enter into and manage business relationships with you, and to perform our contractual obligations under any agreements we may have with you.
• Business Development and Outreach: Where permitted by applicable law, to contact you directly—by email, phone, or other means—to respond to your inquiries or to discuss potential products or services that may be relevant to your business or interests.
• Advertising: To deliver interest-based advertising for our Site and services on this and other websites. This includes using cookies or similar technologies to recognize your device and tailor ads to your interests.
• Marketing: To send you marketing communications, promotions, and advertisements tailored to your interests and preferences, including on social media platforms. You can opt out of receiving marketing emails at any time by clicking the "Unsubscribe" link in any message.

3. How We Disclose Personal Data

We value your privacy.  We do not share, sell, lease, transfer or otherwise disclose your personal data to third parties unless otherwise stated below.

• Service Providers: We may share your personal data with third-party vendors who assist us in operating our Site, delivering services, supporting advertising and marketing efforts, and improving functionality. These providers are only authorized to use your information as necessary to provide services to us.
• Law Enforcement and Regulatory Authorities: We may disclose personal data if required to:

(i) comply with applicable laws or legal obligations;
(ii) enforce our rights under contracts;
(iii) protect the safety, rights, property, or privacy of OwlTing, our users, or others; or
(iv) respond to lawful requests from public authorities, including courts, law enforcement, and regulators—even if located outside your country of residence.

• Third Parties: We may choose to sell, transfer, or merge parts of our business or our assets to third parties. Alternatively, we may acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
• With Your Consent: We may share your personal data when you provide explicit consent—for example, when you authorize a third-party application to access your account, or when you agree to share information in a survey or contact form.

4. How We Protect Personal Data

We implement reasonable technical and organizational measures to safeguard your personal data against unauthorized access, use, disclosure, or loss. Access to personal data is limited to employees, contractors, and service providers who need it to perform their duties and are bound by confidentiality obligations.

We cannot, however, guarantee your personal data may not be accessed, disclosed, altered, or destroyed by any attacks from hackers or any skilled computer experts. If you have reason to believe that your interaction with us is no longer secure (e.g., you feel that the security of your account has been compromised), please contact us immediately.

5.Data Retention Policy

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, regulatory, accounting, or reporting obligations. When data is no longer required, we securely delete or anonymize it.

If you request deletion of your data and we are not legally required to retain it, we will honor your request in accordance with applicable laws.

6. Your Rights and Choices

You may have choices regarding our collection, use and disclosure of your personal data:

• Email Communications: You may opt out of receiving marketing emails from us at any time by clicking the "Unsubscribe" link in the email. We will process your request as soon as reasonably practicable.
• Your Data Protection Rights: Depending on your location and subject to applicable law, you may have the following rights with regard to the personal data we control about you:
  • The right to request confirmation of whether OwlTing processes personal data relating to you, and if so, to request a copy of that personal data;
  • The right to request that OwlTing rectifies or updates your personal data that is inaccurate, incomplete or outdated;
  • The right to request that OwlTing erase your personal data in certain circumstances provided by law;
  • The right to request that OwlTing restrict the use of your personal data in certain circumstances, such as while OwlTing considers another request that you have submitted (including a request that OwlTing make an update to your personal data);
  • The right to request that we export your personal data that we hold to another company, where technically feasible;
  • Where the processing of your personal data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or
  • In some cases, you may also have the right to object to the processing of your personal data.
• Process For Exercising Data Protection Rights:
  • No fee usually required.  You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
  • What we may need from you.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
  • Time limit to respond.  We try to respond to all legitimate requests within one month or in accordance with applicable law. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

7. Link to Other Websites

Our Site may contain links to third-party websites or services. These are provided for convenience and do not imply our endorsement. We are not responsible for the privacy practices or content of any third-party websites. We encourage you to review their privacy policies before providing personal data.

8. Used by Minors

Our Site is not directed to individuals under the age of 13 (or a higher age where required by applicable law), and we do not knowingly collect personal data from children. If we become aware that a child has provided us with personal information, we will delete it promptly.

9. Updates To This Privacy Policy

We may change this Privacy Policy from time to time. When we do make updates, we will let you know by changing the "Last updated" legend at the top of this Privacy Policy. If it is a big update, we will send you a notification or post a notice on our website. If you ever have any questions about changes made to the Privacy Policy, please contact us.

If applicable law requires that we obtain your consent or provide notice in a specified manner prior to making any changes to this Privacy Policy applicable to you, we will provide such required notice and will obtain your required consent.

10. California Consumer Privacy Act (CCPA)

If you are located in California, we process your personal data in accordance with the California Consumer Privacy Act (CCPA). This section provides additional details about the personal data we collect and use for purposes of CCPA.

• How We Collect, Use, and Disclose Your Personal Data.  The Personal Data We Collect section describes the personal data we may have collected about you, including the categories of sources of that information. We collect this information for the purposes described in the How We Use Personal Data section. We share this information as described in the How We Disclose Personal Data section.
• Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal data:
  • Exercising the right to know: You may request the following information about the personal information we have collected about you:
    • the categories and specific pieces of personal information we have collected about you;
    • the categories of sources from which we collected the personal information;
    • the business or commercial purpose for which we collected the personal information;
    • the categories of third parties with whom we shared the personal information; and
    • the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.
  • Exercising the right to delete: You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.
  • Exercising the right to opt-out from a sale: You may request to opt out of any "sale" of your personal information that may take place.
  • Non-discrimination: The CCPA provides that you may not be discriminated against for exercising these rights.

To submit a request to exercise any of the rights described above, please contact us.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our Site, improve performance, analyze usage, and support marketing efforts.

Cookies are small data files stored on your device that allow the Site to remember your actions and preferences over time. We may also use web beacons, pixels, and similar tools to track how you interact with the Site and emails we send.

The types of cookies we use may include:

• Essential Cookies: Necessary for the Site to function properly (e.g., login, page navigation, and security).
• Performance and Analytics Cookies: Help us understand how visitors use the Site so we can improve its functionality and user experience.
• Functional Cookies: Remember your preferences, such as language or region, to personalize your experience.
• Advertising Cookies: Allow us or our partners to deliver relevant ads and measure the effectiveness of marketing campaigns.

You can manage your cookie preferences through your browser settings. Please note that disabling cookies may affect certain features or performance of the Site.

By continuing to use our Site, you consent to the use of cookies and tracking technologies as described in this Privacy Policy.

 12. Contact Us

To submit questions regarding this Privacy Policy, you can contact OwlTing by emailing us at owlpaysupport@owlting.com or at our mailing address at:

OwlTing USA, Inc.
ATTN: Legal Department
4250 N Fairfax Drive, Suite 600, Arlington, VA 22203