Privacy Policy
(May 2024)
This statement discloses our practices for gathering and processing of information we collect when you visit this website or use any services, devices or mobile applications Owl Labs may make available. We have created this Privacy Policy to demonstrate our firm commitment to your privacy and the protection of your information.
A. General
1. Personal Information
We use the term “Personal Information” to mean both “Personal Data” as defined by the EU General Data Protection Regulation (“GDPR”) and the UK General Data Protection Regulation (“UK GDPR”) and “Personally Identifiable Information” as that term is understood in the United States. In order for you to access certain portions of our website or services, we may require you to provide us with information that personally identifies you, such as your name, mailing address, email address and home and/or business telephone numbers or that is automatically collected from your device and browser (together “Personal Information”). If you communicate with us by email or otherwise complete online forms or the like, any information provided in such communication may be collected as Personal Information. You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the website. You, however, will not be able to access or use those portions of the website as well as services that require your Personal Information.
2. Data Integrity and Security
Owl Labs uses security measures to protect against the loss, misuse and/or alteration of data located on our systems. We implement appropriate measures and processes, such as using encryption when transmitting certain sensitive information, to help us to keep your information secure and to maintain its quality. We regularly review our security and related policies to adapt the technology as new threats evolve and monitor our systems to help ensure a high level of availability. If you have any questions about the security at Owl Labs, you can send an email to support@owllabs.com.
3. Sharing and Usage
We will never sell or rent Personal Information with anyone without your advance permission or unless ordered by a court of law. However, we can share your Personal Information with third parties in order to:
meet any applicable law, regulation, legal process or enforceable governmental request;
enforce applicable terms of service, including investigation of potential violations;
detect, prevent, or otherwise address fraud, security or technical issues;
protect against harm to the rights, property or safety of Owl Labs, our users or the public as required or permitted by law.
If we are involved in a merger, acquisition, or asset sale, we may be required to share your Personal Information but will continue to ensure the confidentiality of any Personal Information.
Otherwise, information submitted to or collected by us is only available to our employees managing this information for purposes of providing you with the services you requested, e.g., by contacting you and sending you emails based on your request for information. In addition, Personal Information will be shared with contracted service providers in order to provide you with our website, services or products (e.g., hosting providers to provide you with our website) or if required for any data processing where you gave consent (e.g., sending of newsletters) or that can be based on other legal bases (e.g., prevention of misuse of our services). Such service providers will process Personal Information on our behalf.
These employees and contracted service providers have been trained to handle such data properly and in accordance with our security protocols and strict standards of confidentiality. Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alteration or destruction of data, we take reasonable precautions to prevent such unfortunate occurrences.
4. Transfer
Owl Labs may receive information from all over the world. Owlllabs will transfer the data to the US, Canada or process in the UK and Europe.. Consequently, your Personal Information may be used, stored and processed outside of the country where you entered that information. If we transfer your Personal Information to processors of Owl Labs or other third parties in countries outside the EU/EEA without adequate decision of the EU Commission, we will do so only on the basis of Standard Contractual Clauses or other adequate safeguards according to applicable law. You can request a copy of such contracts by contacting us.
5. Disclaimer
No data transmission over the internet can be guaranteed to be entirely secure. As a result, while we always use all reasonable efforts to protect the Personal Information you provide to us, we cannot guarantee the security of your information and the submission of data is thus at your own risk. Please be aware that in certain circumstances, it is possible that Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders.
6. Children's Privacy
The Children’s Online Privacy Protection Act or other applicable laws on the protection of minors restricts the collection and use of Personal Information pertaining to children under a certain age (age 13 under the Children’s Online Privacy Protection Act; age 16 under UK GDPR and EU GDPR, unless EU member state laws provide for a different age). We do not allow such children to register as users and will not knowingly collect or solicit Personal Information from anyone under such age. No one under such age should provide any Personal Information on or through this site or otherwise. In the event we learn that we have collected Personal Information from a child under the minimum age, we will terminate the account and delete the information. If you believe that we might have any information from or about a child under minimum age, please contact us at support@owllabs.com.
7. Consent and Notification of Changes
By using the website or any Owl Labs’ services, you agree with the collection, use and storage of your information by us in the manner described in this Privacy Policy. We reserve the right to make changes to this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes on our website so our users are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
B. Data processed when using our website
1. Data that is automatically collected by our website
When using our website, certain Personal Information, including data sent by your browser (e.g., your IP address, domain server, type of computer, type of web browser, access times, referring websites addresses, time and date, content displayed - collectively “Traffic Data”) are temporarily stored. We use this log data to enable you to use our website and, if necessary, to check and enforce our rights and the rights of third parties in the event of damage or infringement of legal regulations, our terms of use and the rights of third parties. In addition, we also use this data to secure our website and services against unauthorized use, manipulation and IT security threats. The log files are stored for as long as is necessary for the respective purpose.
2. Data processed to communicate with us
If you contact us, we may keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our products and services, such as letting you know about upcoming changes or improvements.
3. Data processed to communicate with others
If you use a blog, bulletin board, chat room or comment function on our website, you should be aware that any Personal Information you submit there can be read, collected, or used by other users, and could be used to send you unsolicited messages. We are not responsible for the Personal Information you choose to make publicly available.
4. Data used for special features of our website
Certain features of our website may collect additional information from you. For example, if you use our online shop to buy our products, we will require your name, contact details, address as well as payment information to process your orders. Such information remains stored until claims against us can no longer exist or legal storage obligations require storage.
5. Surveys and Responsive Requests
From time to time, our website may request information from users via surveys or similar responsive requests. Participation in these surveys or responsive requests is completely voluntary and the user therefore has a choice whether or not to disclose information in such surveys or requests. Information requested may include contact information (such as name, email and shipping address), and demographic information (such as zip code, age level). If you give us Personal Information about somebody else, such as a spouse or work colleague, we will assume that you have their permission to do so. Survey information may be used to monitor or improve the use and satisfaction of this website.
6. Newsletters and Email Privacy
We may, from time to time, contact you with regard to our products and services or with other information that you may be interested in receiving. You can at any time request that no further contact be made, e.g., by emailing us at support@owllabs.com. In addition, you may opt-in to receive a newsletter from Owl Labs.
If you received a mailing from us, (a) your email address is therefore either listed with us as someone who has expressly shared this address for the purpose of receiving information in the future ("opt-in"), or (b) you have registered or purchased or otherwise have an existing relationship with us. Each email sent contains an easy way for you to cease receiving email from us. If you wish to do this, simply follow the instructions at the end of any email. If you have received unwanted, unsolicited email sent via this system or purporting to be sent via this system, please forward a copy of that email with your comments to support@owllabs.com.
7. Data processed to improve our website and services
We use log- and metadata to analyze trends, administer the website, track users’ movements on our website, and gather broad demographic information for aggregate use. We use this data to design and arrange our web pages in the user-friendliest manner and to continually improve our website and services to better meet the needs of users.
8. Cookies
In order to provide our website and to improve our website and our visitors’ experience while at our website, we use cookies or similar technologies (such as web beacons, i.e., small pieces of data that are embedded in images on the pages of websites) that access and store information on your terminal device. Cookies are small pieces of data that are stored by a user’s web browser on the user’s hard drive to recognize the computer used to access a website. Most web browsers automatically accept cookies, but you can change your browser to prevent the browser from accepting cookies.
We use such technology to provide you with special functionality such as the shopping cart function in the online shop or language selection. In addition, we may use such information to track page views and entry and exit points to and from the website to better understand our users and improve our website and services. We may also use web beacons, cookies, customized links and/or similar technologies to determine whether electronic newsletters sent by us to those who have requested them from us have been opened and which links are clicked. Any data collected will only be used in an aggregate form.
A user who does not accept cookies from our website may not be able to access certain areas of the website.
9. Further information
a) Data in residual copies and backups
We aim to maintain our website in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our website, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. In addition, we may also retain information subject to retention requirements under applicable laws.
b) Links to Other websites
This website may contain links to other sites that are not operated by Owl Labs. Please be aware that we are not responsible for the privacy practices or content of such other sites. We encourage our users to be aware when they leave our website and to read the privacy statements of each website that collects personally identifiable information. We do not make any warranty or representation regarding, nor do we endorse, any linked third-party websites or the information appearing thereon or any of the products or services described thereon. If you decide to access linked third-party websites, you do so at your own risk. This privacy statement applies solely to information collected by the Owl Labs’ website and services.
C. Data processed when using our products and services
1. Data processed for using Owl products, the Owl app as well as "The Nest"
Owl Labs provides technologies for smart conferencing that is powered by AI. In its products, Owl uses technologies such as 360° cameras, microphones and speakers to allow users to connect via external video conferencing software such as Microsoft Teams or Zoom. For this purpose, Owl products offer special features such as motion and voice-activated focus on speakers, panoramic views of everyone in the room as well the option to capture notes on whiteboards in real-time and share it with colleagues.
Owl products are designed in a way that they can be used without in-depth technical knowledge. For this purpose, Owl offers smartphone/tablet/desktop computer applications for the initial setup, configuration and control of the Owl products. In addition, Owl offers an online management console, called "The Nest", that allows more advanced settings such as MHQ Zoom Integration, the option to add team members and to grant administrator rights to users as well as the possibility to display connected devices' online status, serial numbers, software versions, location and information about whether they are currently used in conference calls. "The Nest" also allows to check if any devices need firmware updates as well as how Owl products are used over time (in how many meetings and with how many participants in average).
To provide our users with such functionalities, the Owl devices process Personal Information, including:
content data such as images captured by the cameras and audio captured by the microphones;
user data such as names and email addresses of registered users;
data collected from Owl products such as IP addresses, serial numbers, firmware versions and the connection status of Owl products;
data collected from end user terminal devices on which the Owl apps are installed and used such as IP addresses, device identifiers, software versions of the Owl apps.
While camera and audio data are processed directly in-device, some Personal Information are sent to and processed by Owl Labs servers, in particular to provide users with remote management functionalities, e.g., through "The Nest".
2. Additional analytics data processed with your consent
With your consent, you may also allow Owl products to collect device usage data (information about the devices used such as model names, software versions, serial numbers, information about how often the devices were used) as well as meeting analytics (how many persons in average did participate in meetings) that will be used by Owl Labs to improve its products. Please note that no audio or camera image data will be used for such purposes.
D. Specific Provisions
1. Additional Information for Users under California Consumer Privacy Act (CCPA)
a) General
This Privacy Policy for California Residents supplements this Privacy Policy for users to which the California Consumer Privacy Act (“CCPA”) applies, and any terms defined in the CCPA have the same meaning when used in this Notice.
Information We Collect. Our website collects the above information, in the following categories:
Identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Commercial information.
Internet or other similar network activity.
Personal information under the CCPA does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Owl Labs, Inc. obtains the categories of Personal Information listed above from the following categories of sources:
Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our website.
Use of Personal Information. We may use or disclose the Personal Information we collect for one or more of the following business purposes:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide customer support.
For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Sharing Personal Information. Owl Labs, Inc. does not disclose your Personal Information to a third party other than for law enforcement requests and as required by applicable law, court order, or governmental regulations.
Disclosures of Personal Information for a Business Purpose:
In the preceding twelve (12) months, Owl Labs has not disclosed Personal Information for a business purpose.
In the preceding twelve (12) months, Owl Labs has not sold Personal Information.
Your Rights and Choices. The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Delete. You have the right to request that Owl Labs deletes the Personal Information we currently hold about you. To exercise this right, contact us @ privacy@owllabs.com.
Right to Opt-Out of ‘Sales’ of Personal Information. If you are a California resident, the CCPA allows you to request that a company no longer “sells” your Personal Information. Insofar as Owl Labs does not sell or otherwise transfer Personal Information, this provision is not applicable to Owl Labs.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
b) California Notices
Users who reside in California and have provided Personal Information to Owl Labs have the right to receive: (a) information identifying any third party to whom we may have disclosed, within the past year, Personal Information pertaining to you and your family for that party’s direct marketing purposes; and (b) a description of the categories of Personal Information disclosed. To obtain such information, please email your request to support@owllabs.com. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.
2. Additional Information for Users under GDPR and UK GDPR
a) General
This additional information supplements the Owl Privacy Policy for users to which the General Data Protection Regulation (GDPR) or the UK GDPR applies.
b) Legal bases for processing Personal Information
Unless otherwise set out in this Privacy Policy or required by law, we will process your Personal Information on the grounds of the following legal bases:
Art. 6 (1) lit. b GDPR / UK GDPR: We will process your Personal Information if this is required for providing services that are part of a contractual agreement with you. This particularly is the case where core functionalities of the Owl products require the processing of Personal Information for the services to work (as set out in clause C.1. above). In addition, we need to process your Personal Information to provide you with other services that you requested, e.g., if you contact us (as set out in clause B.2. above), use functionality to get in contact with other users (as set out in clause B.3. above) or order products on our website or use other special functionality (as set out in clause B.4. above).
Art. 6 (1) lit. f GDPR / UK GDPR: We will also process your Personal Information where we have overweighing legitimate interests to do so. In particular, we may process information that is automatically collected by our web servers to secure our website and services against unauthorized use, manipulation, IT security threats as well as to defend or assert legal claims (as set out in clause II.1. above). Under our legitimate interests, we may, from time to time, contact you with regard to our products and services or with other information that you may be interested in receiving.
Art. 6 (1) lit. a GDPR / UK GDPR: In other cases, we will ask you for your prior consent before we process your data. For example, you can subscribe to our newsletters (as set out in clause B.6. above) or allow us to collect additional analytics data from our website and/or Owl products to improve our products and services (as set out in clause B.7. and B.2. above).
c) Additional information on the use of cookies
In addition to the processing purposes mentioned above, we also use cookies if this is technically necessary to offer our website or certain services or if we are obliged to do so. Cookies that are not technically necessary (e.g., for analysis purposes) are only processed with your consent.
Unless otherwise stated in this Privacy Policy, cookies remain stored as long as necessary to fulfill the respective processing purposes. You can object to the storage of cookies by browser preferences and delete them manually in your browser settings. Please note, however, that some cookies may be technically required for the use of our website or individual functions.
d) Duration of the data storage
Unless a specific duration of data storage is specified in this Privacy Policy, we will only process your data as long as this is necessary for the respective purposes or as long as there are retention obligations under applicable laws. After the respective processing purpose ceases to apply and retention obligations end, your data will be routinely deleted.
For example, we will use Personal Information that is necessary to provide you with the Owl services as long as you use such services.
e) Your rights under the GDPR and UK GDPR
Under the conditions of the GDPR / UK GDPR, you can request information about and access to your Personal Information and have the right to receive Personal Information in a standard and machine-readable format. In addition, under the conditions of the GDPR / UK GDPR, you can also request the deletion, correction or restriction of the processing of your Personal Information.
If you have given your consent to the processing of your Personal Information (legal basis is Art. 6 (1) lit. a GDPR / UK GDPR), you can withdraw your consent at any time with effect for the future.
You can also object to the processing of Personal Information processed on the basis of our legitimate interests (legal basis is Art. 6 (1) lit. f GDPR / UK GDPR) at any time under the conditions of the GDPR / UK GDPR.
f) Contact; complaint to supervisory authority
Please address your questions or concerns regarding the processing of your Personal Information to:
Owl Labs Inc. 33 1/2 Union Sq, Somerville, MA, 02143 privacy@owllabs.com
Contact information for the EU:
Owl Labs Inc. Sir John Rogerson's Quay Dublin 2 DO2 X576 Ireland privacy-EU@owllabs.com
Contact information for the UK:
Owl Labs Inc. 1st Floor, Cobham MSA, M25 Junction 9/10 Downside Cobham, Surrey, KT11 3DB United Kingdom privacy-UK@owllabs.com
In case of questions and in case of possible concerns about the data processing, you can also contact your competent supervisory authority.