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Privacy Policy

Last updated: June 17, 2024

At SendOwl, we respect your privacy. This Privacy Policy explains how we collect, use, and share the personal information that we gather on the subdomains and websites on sendowl.com (the “Sites”) or through your use of our products and services. We encourage you to read this Privacy Policy before submitting any personal data to us through our Sites. By continuing to use our Sites, you agree to the terms of this Privacy Policy.

Concept Den Ltd. doing business as SendOwl will be the data controller of your personal data if you are a merchant using SendOwl to deliver products (“Merchant”) or a promoter of a Merchant’s product (“Affiliate”). Conversely, SendOwl will be the data processor if you are a customer to a SendOwl Merchant (“End Customer”). This Privacy Policy does not apply to the way we process Merchants’ End Customer information in our role as a service provider to our Merchants. Our Data Processing Addendum, which describes how we process and safeguard Merchants’ End Customer information as a service provider to our Merchants, is available upon request by emailing [email protected].

If you are an End Customer to one of our Merchants, please contact your Merchant directly for information regarding how your Merchant uses and shares your personal information gathered from our services.

Please click the following links to learn more about our Privacy Policy:

Information We Collect

Information We Automatically Collect. For all visitors to our site, we collect aggregated information on pages viewed including IP address, timestamps, logins. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means. You can control cookies in your browser to enable or disable them. Learn more in our Cookie Policy.

Information You or Your Merchant Gives Us. For our Merchants, we collect registration information including name, email address, telephone number; billing information including address; and information required to sell goods.

For End Customers who buy a digital product from a Merchant that is delivered by SendOwl, we collect information relating to any transactions recorded by us or returned by the payment gateway including name, email address, billing and shipping address.

We use payment processors for payment, analytics, and other business services. Payment processors collect identifying information about the devices that connect to its services. Payment processors use this information to operate and improve the services they provide to us, including for fraud detection. You can learn more about Stripe, our main payment processor, and read its privacy policy at www.stripe.com/privacy.

Information We Collect From Third Parties. If you access our Sites through third parties (e.g., Facebook or Google), or if you share content from our Sites to a third party social media service, the third party service will send us certain information about you if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.

How We Use Information

The data recorded is used for the following purposes:

  • to respond to your enquiry, ask a question, contact you about your request or other reasons related to offering and improving our services;
  • provide checkout capabilities on our site;
  • to enable us to communicate with you and sellers;
  • send you our monthly newsletter if you have signed up;
  • To analyze Sites usage and improve the services offered;
  • For market research, project planning, troubleshooting problems;
  • To share your website visitor activity, through website cookies, with third-party marketing partners to market our services on our Sites and other websites that you may visit;
  • for buyers who buy something that is delivered by SendOwl we collect data so we can provide them with access to their purchase;
  • to protect against, identify and help prevent fraud, unauthorized activity, claims and other liabilities; and
  • to fulfil our legal and financial obligations.

How We Share Information

We use third party vendors and hosting partners to provide the necessary equipment required to run the service and may share data with them accordingly in order to provide the services you have requested. Specifically: Cloudflare, Amazon Web Service, Rackspace, MailGun, Google Analytics, FreeAgent, HelpScout, Stripe and MailChimp. We have contracts in place with our third-party vendors that require them to use personal data only as necessary to perform services on our behalf and to implement appropriate security measures as required by law.

We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal information in order to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

How Do We Respond to ‘Do Not Track’ Signals?

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

Cookies

A cookie is a text file that websites send to a visitor’s computer to uniquely identify the visitor’s browser or to store information or settings in the browser. Cookies may use your IP address, timestamps, logins. Information collected from cookies is used by us to evaluate the effectiveness of our website, analyse trends, and administer our website. This allows us to determine such things as which parts of our website are most visited and difficulties our visitors may experience in accessing our website. To learn more, please see our Cookie Policy.

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve this site. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

You may wish to restrict the use of cookies. Please be aware that some of the features of our website may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

Personalized Advertising. We may also use targeted advertising cookies, such as Google Ads, to deliver tailored advertising on our Sites and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your

Your Privacy Rights

If you would like to unsubscribe from receiving our newsletter, you can click on the “unsubscribe” link included in our email or contact us as indicated below.

Exercising Your Privacy Rights. We have listed the privacy rights for several jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws.

EEA or UK Individuals’ Rights

If you are from the European Economic Area or United Kingdom, you have the right, under certain circumstances, to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to the processing of your personal data for reasons relating to your particular situation.
  • Request restriction of processing your personal data.
  • Request to export the personal data that we process based on our contract with you or your consent and transfer it to another company (if technically feasible).
  • Withdraw any consent you have previously provided to us.

If you wish to exercise any of the rights set out above, please contact us using the details in the Contact Us section.

If you are not happy with our response, you can contact the ICO in the UK, or other data protection regulator in your country. Important note: if you are a customer who has been delivered a product via SendOwl you will need to contact the Merchant regarding your data rights. SendOwl acts as a data processor and it is the Merchant who must complete your data subject requests as your purchase contract is with them, not us.

Additional Disclosures for Certain U.S. State Residents

Certain state laws require that we detail the categories of personal information that we disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products.

We disclose the following categories of personal information for our business purposes:

  • Identifiers;
  • Personal information under California Civil Code section 1798.80;
  • Commercial information;
  • Internet activity information; and
  • Inferences drawn from any of the above information categories.

Several jurisdictions grant state residents certain rights, including the right to access specific types of personal information, the right to correct inaccurate personal information, the right to learn how we process personal information, the right to know whether and how we disclose or sell personal information, the right to opt out of any sale of personal information, the right to request deletion of personal information in certain circumstances, the right to limit our use of your sensitive personal information, and the right not to be denied goods or services for exercising these rights.

To make such a request, please contact us using the contact details listed in the Contact Us section below.

Do Not Sell or Share My Personal Information. Residents of certain U.S. states have the right to opt out of the sale of the consumer’s personal information.

We do not sell your email address, shopping cart data, or other marketing information to third parties. However, under some U.S state laws, some sharing of personal information necessary to provide you with personalized ads may be considered a “sale,” even if no money is exchanged, such as our use of cookies and similar technologies. You may learn more about how to opt out of such personalized ads through our Cookie Policy.

Limit the Use of My Sensitive Personal Information. We do not use or disclose sensitive personal information for any purpose other than providing our goods and services to you, or as otherwise permitted under applicable law.

Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the third parties’ direct marketing purposes.

Automated Processing & Profiling. Residents of certain U.S. states have the right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Verification Process for Exercising Rights. To protect your privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you submit additional information. If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information at the bottom of this privacy policy and provide us with a copy of the consumer's written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Appeal Process. If we do not decide to act in response to your request to exercise a right, we will provide a timely response detailing the reasons for not taking the action and, depending on your jurisdiction, any rights that you may have to appeal our decision. This may include, where required by law, instructions on how to contact your local Attorney General or Department of Justice for further review.

After confirming that the SendOwl website recognizes and respects Global Privacy Control's opt-out signals, add the following to the "How Do We Respond to 'Do Not Track' Signals?" section:

California and certain other U.S. state residents may opt out of tracking technologies by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us.

Legal Bases for Processing

Billing information is recorded as it is necessary to comply with our contractual obligations when providing our service to Merchants and our Merchants’ End Customers.

We process information about our visitors for the legitimate business interests of developing our site to ensure a better experience for our visitors. We also obtain registration information based on the legitimate interest of business administration. When processing your personal data for our legitimate interests, we take appropriate measures to ensure that the interests we pursue are balanced with your interests, rights and freedoms.

With your consent, we may use your personal data to send you marketing materials, except as otherwise permitted by applicable law. You may also provide consent where we do not rely on another legal basis. Consent may be withdrawn at any time.

We may process data in compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your personal data to record your requests to exercise your rights and to verify your identity for such requests.

In some limited cases, we may also have a legal obligation to collect personal information from you, in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in How We Share Information.

Retention and Withdrawal

We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

Data Transfer

We may transfer your personal data to recipients in countries other than the country in which the personal data originally was collected. Those countries may not offer the same level of protection to your personal data. When we transfer your personal data to recipients outside of the European Economic Area (“EEA”), we will comply with applicable legal requirements by providing adequate protection for the transfer of personal data, including by (i) entering into the European Commission’s EU Standard Contractual Clauses with the data recipients, (ii) verifying that the recipient has implemented Binding Corporate Rules, or (iii) any other appropriate safeguards as required by applicable law for any personal information transferred internationally.

To obtain a copy of our Data Protection Addendum with Standard Contractual Clauses incorporated, please email [email protected].

Children’s Privacy

The Sites are not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us using the contact details provided in the Contact Us section below. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information.

Change of Control

Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your personal information.

Data Security

We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be reasonable procedures to protect the confidentiality, security, and integrity of personal information obtained through the Sites, we cannot ensure or warrant the security of any information you transmit to us.

Updates

This policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting personal data to our site. The date the policy was last updated is indicated at the top of this page.

Contact Us

You can contact us at [email protected] if you have any questions regarding this privacy policy.