Thank you for choosing to be part of our community. At OwlApply, we are committed to protecting your personal data and respecting your privacy rights. This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you use our website, chrome extension, AI tools, and related services (collectively, the 'Service').

Personal data is any information relating to an identified or identifiable natural person. It includes things like email addresses, phone numbers, mailing addresses, payment card information, account numbers, and government-issued identification numbers. These are just examples and there are many other types of information that would be considered personal data.

This Policy describes our collection and use practices. To make this easier for you to navigate, please use the links below:

• What Personal Data We Collect and For What Purposes
• Do We Collect Data From Minors?
• How We Handle Your Social Logins
• Use of Cookies and Other Tracking Technologies
• How Your Personal Data is Shared
• Processors and International Data Transfer
• How Long We Keep Your Information
• How We Keep Your Information Safe
• Your Privacy Rights and Choices
• Updates to This Policy
• How to Contact Us About This Policy

We hope you take some time to read through this Policy carefully, because it is important. If there are any terms in this Policy that you do not agree with, please immediately discontinue use of the Service and our services. If you have any questions or concerns about our collection or use of your information, please contact us at privacy@owlapply.com.

What Personal Data We Collect and For What Purposes

OwlApply uses personal data it collects directly from you, automatically from your device, or from third party providers. Below we describe the personal data that we collect from the various sources and the purposes we use the data for.

Personal Data You Disclose To Us

We collect personal data that you provide to us when registering to use the Service, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Service or otherwise contacting us. The personal data that we collect depends on the context of your interactions with us and the Service, the choices you make and the products and features you use, including for the following purposes:

• To facilitate account creation and logon process. We use personal data you provide to create an account with us, including: your first and last name, email address, mailing address, phone number, and other similar contact data; usernames, passwords, password hints, and similar security information used for authentication and account access; and employment, resume or CV and other job related data (e.g. nationality, date of birth, education) that you submit to us or provide us access to in connection with the Service.
• To provide the services. We may use your personal data you decide to share with us in order to create a resume, cover letter or other type of document available on our Service, including: your first and last name, employment history, resume, cover letter, country, social media handles, education history, biography, industry, phone number, and other job related data.
• To send administrative information to you. We may use your personal data to send you information about products or services you have purchased or information about changes to our terms, conditions, and policies, including: first and last name, email address, mailing address, phone number, and other similar contact data.
• To fulfill and manage your orders for services. We may use your personal data to fulfill and manage your orders for services, subscriptions, and payments, and to address any issues with services provided through the Service, including: your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.
• To deliver job alerts via email. We may use your email address and job related preferences to provide you with email job alerts when you sign up for such service.
• To post testimonials. We post testimonials on the Service that may contain personal data, including first name, job title and testimonial which you submitted.
• To send you marketing and promotional communications. We or our third-party marketing partners may use your personal data for our marketing purposes, depending on your marketing preferences. These communications may include information about our new products, services, or features.
• To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising tailored to your interests or location and to measure its effectiveness.
• To request feedback. We may use your personal data to request feedback and to contact you about your use of our Service so that we can improve our products and services and develop additional products and services to better serve our users.
• Interview Recordings – where you voluntarily record yourself, we may collect recordings of you through certain features. In addition, we may choose to record certain group or 1:1 sessions, in which case you will be presented with an on-screen notification that such a recording has started.

Data Automatically Collected By Us

We automatically collect certain information when you visit, use or navigate the Service. For more information about the use of Cookies on our platform and the choices you have, please see our Cookie Policy.

• To send you marketing and promotional communications. We or our third-party marketing partners may use your personal data for our marketing purposes, depending on your marketing preferences, including: device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Service and other technical information.
• To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising tailored to your interests or location and to measure its effectiveness, including: device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Service and other technical information.
• To protect the Service, us, and others. We may use your personal data as part of our efforts to keep the Service safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse, including: device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Service and other technical information.
• To improve the Service. We may use your personal data for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Service, products, services, and your experience, including: device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Service and other technical information.

Data Collected From Other Sources

We may use third party service providers to help us with our day-to-day business activities. Where we use third parties, they may share personal data about you with us.

• To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the personal data you allowed us to collect from those third parties to facilitate account creation and logon process.
• To send system generated communications to you. We may use third parties to send you administrative information about products or services you have purchased.
• To fulfill and manage your orders for services. All payment data is stored by our third-party payment provider when we fulfill and manage your orders for services, subscriptions, and payments.
• To send you marketing and promotional communications. Our third-party marketing partners may share your personal data for our marketing purposes, depending on your marketing preferences.
• To deliver targeted advertising to you. We may use your personal data to develop and display content and advertising tailored to your interests or location and to measure its effectiveness.

Other Purposes For Which We May Use The Personal Data We Collect

We may use any personal data we collect as described above for the following business purposes:

• To develop our products and services. We may use your personal data to further develop our existing products and services, including artificial intelligence tools and features, or to develop new products and services.
• To protect the Service, us, and others. We may use your personal data as part of our efforts to keep the Service safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse.
• To enforce our terms, conditions and policies. We may use your personal data to ensure you and others are complying with our terms, conditions and policies, including providing your information to law enforcement if we believe it is appropriate to do so and using your information in connection with legal proceedings brought by us or against us.
• To respond to legal requests and comply with applicable law. If we receive a subpoena, discovery request, or other legal request, we may need to review and evaluate your personal data and potentially provide your personal data in response to the request.
• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the Service, products, services, and your experience.

Do We Collect Data From Minors?

Our Service is not directed to minors under the age of 16 (or under the age of majority as determined by applicable, local law) and we do not intend to collect personal data from minors under the age of majority. Therefore, we recommend that parents or legal guardians be involved in the online activities of their children in order to prevent the collection of their personal data without parental consent. If you believe that we inadvertently have collected personal data about your child, please contact us at privacy@owlapply.com and we will promptly delete or de-identify this information.

How We Handle Your Social Logins

The Service may offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). If you choose to do this, we will receive certain profile information about you from the social media company. The profile information we receive may vary depending on the social media provider, but will often include your name and email address. We will use the information we receive for the purposes that are described in this Policy. Please note that we do not control, and are not responsible for, other uses of your personal data by the social media company. We recommend that you review their privacy policy to understand how they collect, use and share your personal data, and how you can set your privacy preferences on their sites and applications.

Use of Cookies and Other Tracking Technologies

We may use cookies and similar tracking technologies (like web beacons and pixels) to collect or store information. Specific information about how we use such technologies and how you can refuse or disable certain cookies is set out in our Cookie Policy. The use of cookies other than essential cookies, including for the purposes of targeted advertising, is performed on the basis of your consent.

Do-Not-Track Features (U.S. Residents only) Many web browsers and some mobile operating systems and mobile applications include a "do-not-track" feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing do-not-track signals has been finalized and, as such, we do not currently respond to do not track browser signals or any other mechanism that automatically communicates your choice not to be tracked online. We will update this Policy if that changes in the future. These features are not an alternative to the settings you choose in our cookie banner.

How Your Personal Data is Shared

We may share your personal data with the following categories of third-parties for one or more of the purposes described above and if there is a legal basis:

• Service Providers (or Processors) subject to written agreement to process your personal data consistent with our instructions, including: SMS and other messaging service providers, content optimization service providers, invoice and billing service providers, social media companies to which you enable access, software service providers that parse and match resumes with job postings, email job alert providers, website and application analytics providers, website hosting providers, website testing and optimization service providers.
• Marketing and Advertising Partners: Advertising, direct marketing, and lead generation providers, social media site advertising providers, targeted advertising platforms.

Where we believe it necessary or appropriate to do so, we may share your personal data with: law enforcement; government agencies or regulators; courts; parties to legal proceedings in which a subpoena or legal request has been propounded to which such information would be responsive. In those circumstances we will make reasonable efforts to disclose only that information that is relevant to the reason for disclosure and to protect the privacy of such information to the extent reasonably possible.

Our services may also include distributing your resume, CV, and other related information to enterprise partners and third party job sites with your consent and at your request. Should you elect to receive such services, your information shall be governed by and subject to the privacy policy on the respective sites to which your information is sent.

Finally, we may share or transfer your 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.

Processors and International Data Transfer

We will only engage processors who adequately implement appropriate technical and organizational measures and who guarantee the protection of your rights. In order to ensure this, we enter into data processing agreements with our processors.

If your personal data are transferred to 'third countries' – i.e., countries outside the European Economic Area ("EEA") – we will only do so if the third country offers an adequate level of protection. Where this is not the case, we provide appropriate safeguards to ensure adequate data protection, such as the most recent standard contractual clauses as approved by the European Commission and by additional safeguards, a copy of which can be obtained by sending an e-mail to privacy@owlapply.com.

How Long We Keep Your Information

We will only keep your personal data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as business records, tax, accounting or other legal requirements). In determining data retention periods, we take into consideration the applicable law, contractual obligations, and your expectations.

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it and we will make such determination based on applicable laws. When the processing of personal data is based on your consent, the data will be stored for as long as there is valid consent for the processing.

How We Keep Your Information Safe

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal data we collect, receive, use, or store, including measures designed to protect data transferred to different countries for use or processing in accordance with this Privacy Policy. We will do our best to protect your personal data taking into account the state of art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for your rights and freedoms posed by the processing.

You should however access the Service within a secure environment. If you believe your account has been compromised or you suspect any type of data breach, please contact us at privacy@owlapply.com.

De-identified (Anonymized) and Aggregate Data

OwlApply may de-identify (as also referred to as "anonymize") and aggregate data for its business purposes, including but not limited to, to improve the products and features of its Services, to maintain the security and integrity of its systems, for analytics, and other legitimate business purposes. "De-identified Data" means information that cannot reasonably be used to infer information about, or otherwise be linked to a particular data subject. De-identified Data includes anonymized data and is no longer "personal data" under applicable data protection laws.

Where we process De-identified Data, we commit to maintain and use the information in de-identified form and not attempt to reidentify the information, except where permitted by law. OwlApply may disclose De-identified Data to third parties who commit themselves to maintaining the De-identified Data in anonymized form and not attempt to re-identify the data for any business purpose.

Your Privacy Rights and Choices

The rights described in this section apply to all users. Note: Some data protection laws may use other terms to describe these rights differently. If you have any questions about these rights please contact us at privacy@owlapply.com.

• Right to Access and to Know — You have the right to access the personal data collected about you. You also may request to know the categories of personal data collected about you, the information or categories of information shared with third parties, or the specific third parties or categories of third parties to which the information was shared.
• Right of Complaint — If you believe that the processing of your personal data violates applicable laws and regulations, please contact us at privacy@owlapply.com. We will always try to find a solution together.
• Right to Correct — You have the right to request rectification of any of your personal data provided to us if you consider it to be inaccurate or incomplete.
• Right to Data Portability — Under certain circumstances, you may request us to transfer your personal data to another controller. Also, you have the right to receive your personal data in a structured, commonly used and machine-readable format.
• Right to Delete / Erasure — You generally have a right to request your personal data or part of it to be erased when your personal data are no longer necessary for the stated purposes in this Policy.
• Right to Restriction — Under certain circumstances, you may have the right to restrict a business's ability to process personal data about you.
• Right to Notification of Correction, Deletion or Restriction — Unless it is impossible or involves a disproportionate effort, we will inform the recipients of your personal data about correction, deletion or restriction of processing.
• Right Against Automated Decision Making/ Profiling — You may have the right to not be subject to a decision based solely on an automated process without human input.
• Right of Objection — Under certain circumstances, you may object to the processing of your personal data by us or third parties engaged by us.
• Right to Withdraw Consent — If we have requested your explicit consent for data processing, you have the right to withdraw your consent at any time.
• Right to Opt In for Sensitive Data Processing — Under certain circumstances, you may have the right to opt in (or consent) before we can process your sensitive data.
• Right to Opt Out of Sale or Sharing — Where applicable, you may opt out of the Sale or Sharing of personal data to third parties, as those terms are defined by applicable laws.

In addition, we will not discriminate against you if you exercise your privacy rights under any applicable privacy and data protection laws.

How to Submit a Request to Exercise Your Rights

You may submit a request regarding your personal data by:

• Email us at privacy@owlapply.com – please provide your name, telephone number, and type of request.
• Mail us at our registered address, Attn: Privacy.

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 someone 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.

Your Account and Communication Choices

• Delete or Updating Account Information. If you are a registered user of our Service, you may delete or correct the personal data in your account in your account settings. It is your responsibility to make sure the personal data we hold about you is accurate and up-to-date.
• Opt Out of Email Marketing. We will send you marketing emails about our own products and services if you are our customer or have given your consent. However, you can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send. If you opt out of marketing emails, we may still send you service-related emails that are necessary for the administration and use of your account.

Updates to This Policy

We may update this Policy from time to time. The updated version will be indicated by the "Last Updated" date and the updated version will be effective as soon as it is accessible. If we make any material changes to the Policy, we will notify you by reasonable means, which may be by email or posting a notice of the changes on our website prior to the changes becoming effective. We encourage you to check this Policy from time to time.

How to Contact Us About This Policy

If you have questions or comments about this Policy, you may contact our Data Protection Officer (DPO) by email at privacy@owlapply.com.

We will make every effort to respond to your inquiries promptly and address your concerns.