OWNIT PRIVACY POLICY

Last Updated: September 8, 2022

INTRODUCTION

Your privacy is important to us. This Privacy Policy ( “Policy”) applies to services provided by Ownit Commerce Inc. (“we” , “us”, or “Company”) and our website, product pages, mobile or web applications, or other digital products that link to or reference this Policy (collectively, the “Services”) and explains what information we collect from users of our Services (a “user”, “you”, or “your”), including information that may be used to personally identify you ( “Personal Information”) and how we use it. We encourage you to read the details below.

We reserve the right to change this Policy at any time. We will notify you of any changes to this Policy by posting a new Policy to this page, and/or by sending notice to the primary email address specified in your account. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically reviewing this Policy to check for any changes. Changes to this Policy are effective when they are posted on this page. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of your Personal Information is subject to the updated Policy

Scope and Applicability

Please note that this Policy does not apply to the extent that we process Personal Information in the role of a processor (or a comparable role such as a “service provider” in certain jurisdictions) on behalf of our customers, including where we offer to our customers various services, through which our customers (and/or their affiliates) connect their product page to connected checkout functionality, sell or offer their own products and services, send electronic communications to other individuals, or otherwise collect, use, share or process Personal Information via our Services.

Each of our customers, not Company, controls what information about you is collected by the Services on behalf of such customer. This content may include contact information (such as your first and last name, email address, and/or phone number), billing address, other types of information that our customer makes available to us via the Shopify app, and, if elected by our customer, information automatically collected through a web beacon placed via the customer's product page or brand page. Use of this content by Company is governed by agreements between Ownit and the customer.

For detailed privacy information applicable to situations where an Ownit customer (and/or a customer affiliate) who uses the Services is the controller, please reach out to the respective customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those set forth in this Privacy Policy. If not stated otherwise either in this Privacy Policy or in a separate disclosure, we process such Personal Information in the role of a processor or service provider on behalf of a customer (and/or its affiliates), who is the responsible controller of the applicable Personal Information.

What Information Do We Collect?

When you visit our website or otherwise communicate with us, we collect information that you provide to us directly. The information you provide to us directly may include, without limitation, the following information that may, alone or in combination with other data, constitute Personal Information:

Information you provide in order to subscribe to our marketing communications.
Information you provide when communicating with us or that you otherwise voluntarily provide to us.

Furthermore, we may automatically collect in and through the Services the following “Technical Information”:

Device data: including, but not limited to, the type of device you use, data on device advertising ID's and similar hardware qualifiers, the browser you use, your operating system, and approximate geographic location data.
Usage data: including, but not limited to, your browsing actions and site usage patterns that are collected automatically when you visit or interact with our website and if you visit brand pages that we host on behalf of our customers (collectively our website and brand pages we host on behalf of our customers as hereinafter referred to as the “sites”). This data, which, depending on where you are located, can include Personal Data, and may include: log data (such as internet protocol (IP) address, operating system, browser type, browser ID, the URL entered and the referring page/campaign, date/time of visit, time zone, the amount of time spent on the sites, pages viewed, errors that occurred during the your visit, analytics data (such as the electronic path taken to the sites, through the sites and when exiting the sites, as well as usage and activity on the sites), location data (such as general geographic location based on the log data we or our third-party providers collect) and other usage behavior identified by analytics events.
Network and internet information: including, but not limited to, URLs, Internet Protocol addresses, bounce rates, use of spoofing, active (TCP/IP) ports, number of sessions initiated, click streams, location information and network/Wi-Fi access points.
Information we collect on the use of the Services via cookies and other tracking technologies: please see the “How Do We Use Tracking Technologies” section below for more information.

How Do We Use The Information We Collect?

We use the information we collect:

To deliver and improve the Services and your overall user experience.
To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
To link or combine user information with other Personal Information.
To compare and verify information for accuracy and update our records.
To email, message, or otherwise contact you with information and updates about us and the Services.
To respond to your comments and questions and provide customer service.
To send you information including confirmations, technical notices, updates, security alerts, and support and administrative messages.
To analyze how you use the Services with tools such as Google Analytics and other tools to help us understand traffic patterns and know if there are problems with the Services.
In connection with a merger, acquisition, reorganization or similar transaction.
When required by law or to respond to legal process.
To protect our users, other individual lives, and/or the rights or property of Company.
To maintain the security of the Services.
For any other purpose with your consent.

Do We Share Your Personal Information?

In addition to the specific situations discussed elsewhere in this privacy policy, we disclose Personal Information in the following circumstances:

With our corporate affiliates and subsidiaries.
With third parties that perform services to support our core business functions and internal operations, which may include database administrators, cloud computing services, payment processors, advertising services, and application services providers.
To support our audit, compliance, and corporate governance functions.
With third parties that we have partnered with, such as to jointly create and offer a product, service or joint promotion.
In connection with a change of ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy).
If we have a good-faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to detect or protect against fraud or security issues.
If required or permitted by applicable law or regulation, including laws and regulations of the United States and other countries, or in the good faith belief that such action is necessary to: (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities wherever Company may do business; (b) protect and defend the rights or property of Company; (c) act in urgent circumstances to protect the personal safety of users, customers, and contractors/employees of Company or others; or (d) enforce our Terms of Use or otherwise protect against any legal liability.
With your consent or at your direction.

How Do We Use Tracking Technologies?

Some of the features on the Services may require the use of “cookies” - small text files that are stored on your device's hard drive. You may delete and block all cookies from our Services, but parts of the Services may not work. We want to be open about our cookie use. The following sets out how we may use different categories of cookies and your options for managing cookie settings:

How Do We Secure Your Personal Information?

We take reasonable steps to protect your Personal Information against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We protect your Personal Information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your Personal Information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using the Services, you acknowledge that you understand and agree to assume these risks.

Managing Your Privacy

All users may submit requests regarding their Personal Information that has been collected directly by Company as described in this Privacy Policy by contacting us at privacy@ownit.co . If your Personal Data has been collected by us on behalf of a customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly.

Data Retention

We will retain your Personal Information for as long as is reasonable or appropriate for the purposes set out in this Privacy Policy. We will also retain and use your Personal Information to the extent necessary or reasonable 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.

We will also retain certain Technical Information for internal analysis purposes or to improve the functionality of our Services.

Links to Third Party Websites

We may provide links to other websites. We have no control over these websites and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, these third party websites.

By using the Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third party websites.

How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor's browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit allaboutdnt.com .

Children Under 16

The Services are not directed to individuals who are under age of sixteen (16) and we do not solicit nor knowingly collect Personal Information from children under the age of sixteen (16). If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at privacy@ownit.co and the information will be deleted.

Third Party Direct Marketing

We currently do not share Personal Information with third parties for their direct marketing purposes without your consent.

A Note to Users Outside the United States

Our Company is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the laws of the country(ies) where the Services are controlled. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Contact Us

If you have any questions about this Policy, your Personal Information, or the Services, you can contact privacy@ownit.co .

Type of Cookies	Description	Managing Settings
Required cookies	Required cookies enable you to navigate the Services and use their features, such as accessing secure areas of the Services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. These cookies allow us to uniquely identify you when you are logged into the Services and to process your online transactions and requests.	Because required cookies are essential to operate the Services, there is no option to opt out of these cookies.
Performance cookies	These cookies collect information about how you use our Services, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identify you. Information is only used to improve how the Services functions and performs. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information relating to individuals who visit the Services.	To learn how to opt out of performance cookies using your browser settings, click here .
Functionality cookies	Functionality cookies allow our Services to remember information you have entered or choices you make and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.	To learn how to opt out of performance cookies using your browser settings, click here .