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PRIVACY POLICY

Last Updated: April 24th, 2023

This privacy policy ("Policy") explains how personal data is collected, used,
and disclosed with respect to your use of i) our website located at
www.owler.com (the "Site") and ii) the software and services you have signed up
to, as an online subscription, and use through the Site and your mobile device
(the "Owler Service"). This Policy does not apply to the use of the Owler
platform through a corporate subscription. If you are a corporate user please
refer to the data processing agreement available here. Our Privacy Notice for
Data Subjects in the Sales Intelligence database can be accessed here.

Please read this Policy carefully to understand our policies and practices
regarding your personal data gathered through your use of the Site and the Owler
Service. If you do not agree with this Policy and our practices, do not use the
Site or the Owler Service. By using this Site and the Owler Service, you
represent that you are 16 years old or older. 

We reserve the right to change the provisions of this Policy at any time. We
will alert you that changes have been made by indicating on the top of the
privacy policy the date it was last updated. Your use of the Site or the Owler
Service following the posting of updated policy shall constitute your acceptance
of any changes in our privacy practices, and you expressly waive any right to
receiving notice of such changes except where your affirmative consent is
required.

If we make material changes to how we treat our the personal data of Owler
Service users, we will notify you by email to the email address specified in
your account or through a notice within the Owler Service. You are responsible
for ensuring we have an up-to-date and deliverable email address for you, and
for periodically visiting our Site and this Policy to check for any changes.


WHAT PERSONAL DATA DO WE COLLECT?

This Policy applies to personal data we process in connection with the Site and
the Owler Service, as defined above. Personal data means information that can be
directly or indirectly associated with you by reference to an identifier, such
as a name, an email address, an identification number, or other information by
which you can be identified using reasonable means. 

We collect the personal data you have provided to us during your use of our
Site, as well as statistics about your usage of our Site, your IP address and
geographic location.

If you subscribe to the Owler Service online, we require a password and your
basic contact information, including your name. email address, phone number,
employer, and job function. We receive and store this personal data and use it
to create a user profile and provide you with the Owler Service. We may use your
e-mail address or phone number to contact you about your experience with the
Owler Service and notify you about company news and promotions. 


OUR PURPOSE AND LEGAL GROUND FOR PROCESSING PERSONAL DATA?

Broadly speaking, we use personal data for purposes of administering and
expanding our business activities, providing customer service, making available
other products and services to our users and prospective customers, to allow you
to participate in interactive features on our Site, and to fulfill any other
purpose for which you provide the personal data. We do not collect, share,
disclose or sell sensitive personal data, the following types of personal data:
Social Security number, passport number, medical or financial information.

We process your personal data for the following purposes on the following legal
grounds:

Consent:

Email Subscriptions. We use your email address and any stated subscription
preferences to provide you with email content that we believe will be of
interest to you. If you choose to sign up for an email newsletter, we will send
the newsletter to the email address you register with us. If you wish to
unsubscribe from the newsletter, you may do so by using the unsubscribe link in
the newsletter. 

Direct Marketing. Occasionally, we may use the personal data we collect to
notify you about new services and special offers we think you will find
valuable. You may notify us at any time if you do not wish to receive these
offers by emailing us at privacy@meltwater.com Our goal is to only provide you
with materials that are of interest to you.

Legitimate interest:

Processing of your personal data is necessary for the legitimate interests
pursued by us. We value your fundamental rights and freedoms and carefully
evaluates protection of your personal data with respect to such processing. We
will not engage in processing pursuant to this lawful basis to the extent our
legitimate interest is overridden by your interests or fundamental rights and
freedoms which require protection of your personal data. 

With respect to profiling and third-party advertising, we have concluded the
processing of user information is not likely to result in a high risk because i)
each user profile includes a limited level of detail; ii) the profiles only
extend to business areas that may be of interest to the user; iii) the targeting
of marketing materials is unlikely to have a significant effect on the user; and
iv) our internal processes are intended to promote accuracy, fairness, and
non-discrimination. We value your fundamental rights and freedoms and therefore
do not engage in uses of your information where our legitimate interests are
outweighed by your fundamental rights and freedoms.

Site Usage data. We will not associate any data gathered from Google Analytics
or the other analysis tools with any personally identifiable information from
any source. We use the collected usage statistics to better understand our
customers, measure the performance of the Site, and measure the effectiveness of
our marketing efforts. The vast majority of service usage statistics cannot be
reasonably used to directly or indirectly identify a particular individual.
However, if any usage statistics can be used for such purpose, we will only use
the information for aggregate statistical purposes rather than observing the
behavior of specific users.

Service Usage Statistics. We may use Google Analytics, Google Optimize,
Amplitude, ChartMogul, Squarespace and Pendo to help analyze how users use the
Site and the Owler Service. These tools use cookies to collect standard Internet
log information and visitor behavior information in an anonymous form. The
information generated about your use of the website (including IP Address) is
transmitted to these analysis tools. This information is then used to evaluate
visitors’ use of the Site and the Owler Service and to compile statistical
reports on website activity for us. We will never (and will not allow any third
party to) use the statistical analytics tool to track or to collect any
personally identifiable information of users of the Site and the Owler Service.

Service Content. Users may post reviews, comments, and other content; send
messages and other communications; and submit suggestions, ideas, comments,
questions, or other information. All of these materials are referred to as
Content. We may process your personal data in connection  with your posting or
sharing of Content. For example, comments or messages you send may include your
name, photograph, or other personal data. We may also further process any
Content to anonymize the Content to protect the privacy of our users and promote
our business interests and services using the anonymized Content. We may edit
Content to eliminate identifying personal data. 

Third-Party Advertising. Our advertising processor places ads in the Owler
Service that they believe will be of interest to you. Users are identified
solely using a hashed identifier and no other personal data is available to the
advertising processor. If you do not wish for the advertisements you receive to
be tailored to fit your interests, please email us at support@owler.com. 

Profiling for Relevant Content. We may use the personal data we have collected
from you to enable us to present content that we believe will be of interest to
you. We profile customer interests based on information you provide to us
directly and information developed based on your use of the Owler Service. For
example, we may use your searches on the Owler Service to improve the quality of
the results we provide to you. 

Contract:

User Accounts. We use your personal data to provide a specific user account that
allows you to access the resources available on the Owler Service. Your user
account also allows you to customize your experience and manage your personal
data.  

Customer Support. We use your personal data to provide support in the event you
request assistance. This personal data includes emails, SMS messages, and other
methods of communication you use to provide us with details about any issues you
may be experiencing with the respect to the Owler Service. We may also use
personal data relating to your support requests to improve the Owler Service. We
may retain the historical email or SMS communications in order to better serve
you on future support interactions and help us make decisions about product
improvements and new services.

Payment Management Services:  We use third party payment processors (currently
Stripe) to manage payments for Owler products and services.  Owler does not
collect or store any credit card information within our internal systems. Owler
provides Stripe with an email address, subscription payment amount and duration
only.  Stripe collects name, email and credit card information to complete the
payment. Stripe provides Owler with a unique Stripe ID for the user.  The Stripe
privacy policy can be found here: https://stripe.com/privacy

Legal obligation, vital interest:

Legal Obligations and Claims. In addition to the specific bases for disclosure
of personal data set forth in this section, we may process or disclose your
personal data where such processing or disclosure is necessary for compliance
with a legal obligation to which we are subject. To the extent we are legally
required to disclose information to law enforcement, we will comply with such
requests. We will not otherwise voluntarily disclose your information. We may
disclose your personal data where such disclosure is necessary for the
establishment, exercise or defense of legal claims on behalf of Owler, whether
in court proceedings or in an administrative or out-of-court procedure.


F. HOW DO WE PROTECT YOUR PERSONAL DATA?

We take appropriate security measures to protect against unauthorized access to
all of our data. This includes internal reviews of our data collection, storage
and processing practices, as well as an assessment of our encryption and
physical security measures to guard against unauthorized access to systems where
we store personal data. We restrict access to personal data to a limited number
of our employees, partners and agents. These individuals and entities are bound
by confidentiality agreements and may be subject to discipline, including
termination and criminal prosecution, if they fail to meet any obligations
required under their agreement with us. 

The safety and security of your personal data also depends on you. You must
maintain the security of your email accounts and any other credentials used to
access the Site and the Owler Service. Any personal data you share in public
areas of the Site and the Owler Service may be viewed by any other user or
visitor. Unfortunately, the transmission of personal data via the Internet is
not completely secure. Although we do our best to protect your personal data, we
cannot guarantee the security of your personal data transmitted to our Site. Any
transmission of personal data is at your own risk. We are not responsible for
circumvention of any privacy settings or security measures contained on the
Site.


HOW CAN YOU ACCESS AND CORRECT YOUR PERSONAL DATA?

When you use our Site and the Owler Service, we make every effort to provide you
with access to your personal data and will correct this data if it is inaccurate
or delete it at your request provided to privacy@meltwater.com if it is not
otherwise required to be retained by law or for legitimate business purposes. If
we are unable to comply with your request, you have the possibility of lodging a
complaint with a supervisory authority and seeking a judicial remedy.

As an Owler Service user, you can review and change portions of your personal
data by logging onto the Owler Service and visiting your "Settings" page under
the “Me” menu. We ask individual users to identify themselves and the personal
data requested to be accessed, corrected or removed before processing such
requests, and we may decline to process requests that are unreasonably
repetitive or systematic, require disproportionate technical effort, jeopardize
the privacy of others, would be extremely impractical (for instance, requests
concerning information residing in database backup copies), or for which access
is not otherwise required. In any case where we provide personal data access and
correction, we perform this service free of charge, except if doing so would
require a disproportionate effort.


CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

If you are a California resident, you may have additional privacy rights
regarding your personal data under the California Consumer Privacy Act (the
“CCPA”). These rights include the right to request disclosure of the categories
of personal data collected, the purposes for which that personal data is
collected, and the types of third parties receiving access to your personal
data. You may also request deletion of your data and obtain personal data
relating to any sharing of personal data with third parties. 

To the extent possible, users will receive equal service and price regardless of
whether they exercise their privacy rights under the CCPA. 

California's Shine The Light Law

California Civil Code Section 1798.83, known as the 'Shine The Light' law,
permits our customers who are California residents to request and obtain from us
a list of what personal data (if any) we disclosed to third parties for direct
marketing purposes in the preceding calendar year and the names and addresses of
those third parties. Requests may be made only once a year and are free of
charge. Under Section 1798.83, we currently do not share any personal data with
third parties for their direct marketing purposes.

California Online Privacy Protection Act Notice

1. What is Do Not Track (DNT)? 

DNT is the concept that has been promoted by 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.

2. What is a DNT signal? 

Currently, various browsers (including Internet Explorer, Firefox, and Safari)
offer a DNT option that relies on a technology known as a DNT header that sends
a signal to websites visited by the browser user about the user's DNT
preference. You can usually access your browser's DNT option in your browser's
preferences.

3. Is there a DNT technology standard? 

The World Wide Web Consortium (W3C) has been working with industry groups,
Internet browsers, technology companies, and regulators to develop a DNT
technology standard. While some progress has been made on this issue, it has
been slow, and to date no standard has been adopted. Without an industry
standard for DNT, users cannot know how any given company abides by a DNT signal
they receive from browser headers. Owler is committed to remaining apprised of
the W3C efforts to develop a DNT standard. 

A Do Not Track (DNT) standard has not been adopted to this day, and therefore
Owler does not use DNT signals. Owler does not authorize the collection of
personal data from our members on Owler for third party use through advertising
technologies without separate member consent.

4. How does Owler respond to the DNT signal? 

Owler takes privacy and security very seriously and strives to put our members
first in all aspects of our business. With regard to DNT, Owler currently does
not respond to DNT signals in browsers because no DNT standard has been
adopted. 

5. Does Owler share members' personal data with third parties (like advertisers
and ad networks)? 

In the DNT context, Owler does not authorize the collection of personal data
from Owler's users through advertising technologies deployed in ads that may
appear on Owler without opt-in consent.

You may contact us regarding these rights by calling us at 1-650-242-9253 or
emailing us privacy@meltwater.com.

Access to Specific Information and Data Portability Rights

California consumers may request that we disclose certain information about
Owler’s collection and use of their personal data over the past 12 months,
including:

 * The categories of personal data collected.

 * The categories of sources for the personal data collected.

 * The business or commercial purpose for collecting or selling that personal
   data.

 * The categories of third parties with whom the personal data is shared.

 * The specific pieces of personal data collected about that consumer 

Deletion Request Rights

California consumers may request that Owler delete any of their personal data,
subject to certain exceptions. Upon receipt of a verifiable consumer request,
Owler will delete that consumer’s personal data from Owler’s records, unless
Owler determines that retaining the information is necessary to:

 * Complete the transaction for which Owler collected the personal data, provide
   a good or service that a consumer requested, take actions reasonably
   anticipated within the context of Owler’s ongoing business relationship with
   that consumer, or otherwise perform Owler’s contract with that consumer.

 * Detect security incidents, protect against malicious, deceptive, fraudulent,
   or illegal activity, or prosecute those responsible for such activities.

 * Debug products to identify and repair errors that impair existing intended
   functionality.

 * Exercise free speech, ensure the right of another consumer to exercise their
   free speech rights, or exercise another right provided for by law.

 * Comply with the California Electronic Communications Privacy Act (Cal. Penal
   Code § 1546 seq.).

 * Engage in public or peer-reviewed scientific, historical, or statistical
   research in the public interest that adheres to all other applicable ethics
   and privacy laws, when the information's deletion may likely render
   impossible or seriously impair the research's achievement, if a consumer
   previously provided informed consent.

 * Enable solely internal uses that are reasonably aligned with consumer
   expectations based on a consumer’s relationship with Owler.

 * Comply with a legal obligation.

 * Make other internal and lawful uses of that information that are compatible
   with the context in which a consumer provided it.


GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area, you have the following
rights with respect to your personal data:

 * Right of Access – a right to understand the nature and extent of how your
   personal data is processed;

 * Right to be Rectification – a right to request correction of inaccurate
   personal data;

 * Right to Erasure – a right to request erasure of personal data in some
   circumstances, commonly referred to as the “Right to be Forgotten”;

 * Right to Restriction of Processing – a right to limit how your personal data
   is processed;

 * Right to Data Portability – a right to receive personal data and transfer
   personal data to another controller;

 * Right to Object – a right to object to processing of your personal data based
   on your circumstances and a right to object to direct marketing; and

 * Right to Freedom from Automated Decision-making – a right not to be subject
   to decision-making based solely on automated processing, including profiling,
   that produces legal or similarly significant effects.

 

Data Retention

i) Owler Service users. We retain the personal data you provide when subscribing
to the Owler Service and through your use of the Owler service as long as your
account is in existence or as needed to provide you the Owler Service.

You can also delete your account by choosing the ‘Delete Account’ option on the
‘Settings’ page. Because of the way we maintain certain services, after you
delete your account information, residual copies may take a period of time
before they are deleted from our active servers and may remain in our backup
systems.   After you delete your account, it is removed from the live production
systems immediately along with your personal data. You will no longer be able to
log in and all your associated account information is purged from the production
system.  We retain backup copies of the system for 30 days for disaster recovery
purposes. Your personal data will be completely purged from all our systems
after 30 days.

ii) Website visitors. For our Site, we retain your personal data as long as we
have a legitimate business interest to process it or as long as you have not
withdrawn your consent. This includes personal data you or others provided to us
and data generated or inferred from your use of our Site.

We may retain your personal data even after the deletion if retention is
required to comply with our legal obligations, meet regulatory requirements,
resolve disputes between members, prevent fraud and abuse, or enforce this
Policy or any other applicable agreements. We may retain personal data, for a
limited period of time, if requested by law enforcement.


CHILDREN UNDER THE AGE OF 16

Our Site is not intended for children under 16 years of age. No one under age 16
may provide any personal data to or on the Site. We do not knowingly collect
personal data from or relating to children under 16. If you are under 16, do not
use or provide any personal data on this Site or on or through any of its
features. If we learn we have collected or received personal data from a child
under 16 without verification of parental consent, we will delete that personal
data. If you believe we might have any personal data from or about a child under
16, please contact us at privacy@meltwater.com.


DISCLOSURE OF PERSONAL DATA

We may disclose personal data that we collect or you provide as described in
this Policy:

 1. To our subsidiaries and affiliates who are also subject to the terms of this
    Policy;

 2. To contractors, service providers, and other third parties we use to support
    our business and develop further the Site and Owler Services, subject to
    sufficient guarantees of appropriate technical and organizational measures
    to protect your rights and privacy;

 3. To a buyer or other successor in the event of a merger, divestiture,
    restructuring, reorganization, dissolution, or other sale or transfer of
    some of all of our assets, whether as a going concern or as part of
    bankruptcy, liquidation, or similar proceeding, in which personal data held
    by Owler about our Site users is among the assets transferred;

 4. To fulfill the purpose for which you provide it, including marketing
    communications and provision of the Owler Services; and

 5. For any other purpose disclosed by us and supported by a lawful basis for
    processing when you provide the personal data.


TRANSFERS OF PERSONAL DATA

We are a global company and information that we collect from or about you within
the European Economic Area (“EEA”), or within any country located outside of the
EEA, may be transferred across international borders to third countries outside
of the EEA, or the country in which you are located, that do not have laws
providing an adequate level of data protection. We as the data controller will
do our best to ensure that your information is protected no matter where it is
transferred to.

To ensure adequate protection for personal information we enter into data
processing agreements with our suppliers, including the ones who process your
personal information outside of the non-EEA country in which you are located, or
the EEA. When necessary, we utilize approved transfer mechanisms (such as
adequacy decisions or the Standard Contractual Clauses in the EU) to ensure the
necessary protection of your personal information. 


WHAT ABOUT OTHER WEBSITES LINKED TO OUR SITE?

We are not responsible for the practices employed by websites linked to or from
our Site or the Owler Service nor the information or content contained therein.
Often, links to other websites are provided solely as pointers to information on
topics that may be useful to the users of our Sitem or the Owler Service. Please
remember that when you use a link to another website, this Policy is no longer
in effect. Your browsing and interaction on any other website, including
websites which have a link on our Site or the Owler Service, is subject to that
website's own rules and policies. Please read over those rules and policies
before proceeding.


THIRD-PARTY MARKETING CONSENT

If at any time, you do not want us to use personal data that we collect or that
you provide to us to deliver advertisements according to our advertisers’
target-audience preferences, you can revoke your consent by sending us an email
stating your request to support@owler.com. For this revocation to function, you
must have your browser set to accept browser cookies.


WHAT ARE COOKIES?

A browser cookie is a very small text document, which often includes an
anonymous unique identifier. When you visit a web site, that site’s computer
asks your computer’s web browser for permission to store this file in a part of
your hard drive specifically designated for cookies. Each web site can send its
own cookie to your browser if your browser's preferences allow it, but (to
protect your privacy) your browser only permits a web site to access the cookies
it has already sent to you, not the cookies sent to you by other sites. You can
configure your browser to notify you whenever a cookie is being sent, or to
refuse all cookies. Please note that some features for the Site or the Owler
Service may not function properly if cookies are disabled for your browser.
Unless you have adjusted your browser settings so that it will refuse cookies,
our system will issue cookies when you direct your browser to our Site.    


HOW DO WE USE PERSONAL DATA WE COLLECT FROM COOKIES?

As you browse through our Site, the Site uses its cookies to differentiate you
from other website visitors and Owler Service users. In some cases, we also use
cookies to prevent you from seeing unnecessary advertisements or requiring you
to log in more than is necessary for security. Cookies, in conjunction with our
web server's log files, allow us to calculate the aggregate number of people
visiting the Site and which parts of the Site are most popular. This helps us
gather feedback in order to constantly improve our Site and better serve our
customers. 

Cookies serve as an identifier with which your information may be associated,
although we do not store any personal data that you provided to us in your
cookies. Some content or applications, including advertisements, on the Site are
served by third parties, including advertisers, ad networks and servers, content
providers, and application providers. These third parties may use cookies alone
or in conjunction with web beacons or other tracking technologies to collect
information about you when you use our website. The information they collect may
be associated with your personal data or they may collect information, including
personal data, about your online activities over time and across different
websites and other online services. They may use this information to provide you
with interest-based (behavioral) advertising or other targeted content. We do
not control these third parties’ tracking technologies or how they may be used.
If you have any questions about an advertisement or other targeted content, you
should contact the responsible provider directly.


COOKIES USED ON THE SITE AND IN THE OWLER SERVICE

The following cookies are used:

 * Paved

 * LiveRamp

 * Google Analytics

 * Google Tag Manager

 * Signals - https://getsignals.ai/

 * Google Ads

 * LinkedIn Campaign Manager

 * Instapage


PUBLISHED INFORMATION

As part of the Owler Service we gather information, including details about the
leadership team, about companies.  We compile our company profile information
from a variety of sources including: publicly available databases, any other
sites or applications operated by us, other sources of public information, and
third-party data vendors. The user community of Owler Service has the option to
contribute additions and corrections to the Owler company profiles. These
profiles may include personal data, such as name, photograph and profile
picture, and it is made available to the users of the Owler Service enabling
them to view  a complete profile of the companies included in our database. 

Based on our assessment we have a legitimate interest in providing access to our
community-driven business insights platform and information published on the
platform. Allowing online access to personal data relating to individuals who
are leaders of the company listed on the Owler Service, is an essential part of
the Owler Service and Owler has a legitimate interest in offering such
information. If you are  a member of a company leadership team, and do not wish
for us to use your personal data in the Owler Service, please email us at
privacy@meltwater.com. 


DATA CONTROLLER

Meltwater News US, Inc. is the data controller of the personal data processed in
connection with the Siteand the Owler Service. Meltwater News US, Inc. is
located in the United States of America, with a mailing address of 555 Twin
Dolphin Drive, Suite 165, Redwood City, California 94065, United States. The 
data controller can be contacted at privacy@meltwater.com.

Owler Inc.
465 California Street,
San Francisco, CA, 94104,
United States
650-242-9253 support@owler.com
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