OWOW APP
Privacy Policy
This Policy was last updated on April 17, 2024
OWOW Technologies Inc. (“OWOW” or "We") respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes:
The types of information we may collect or that you may provide when you purchase, download install, register with, access, or use the OWOW App (the "App").
Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This Policy applies only to information we may collect in this App, and in email, text, and other electronic communications sent through or in connection with this App.
This Policy DOES NOT apply to information that:
We may collect offline or on any other OWOW apps or websites, including websites you may access through this App.
You provide to or is collected by any third party.
Such other websites and apps, and other third party sites may have their own privacy policies, which we encourage you to read before providing information on or through them.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this Policy. This Policy may change from time to time. Your continued use of this App after we revise this Policy means you accept those changes, so please check the Policy periodically for updates.
Privacy of Children
The App is not intended for children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@owow.ai.
In certain jurisdictions the intended age for use of this App may be higher than 13 due to local regulatory requirements or residents of certain jurisdictions may have additional rights.
Information We Collect and How We Collect It
We collect information from and about users of our App:
Directly from you when you provide it to us.
Automatically when you use the App.
Information You Provide to Us Directly
When you download, register with, or use this App, we may ask you provide information:
By which you may be personally identified, such as name, email address, telephone number, photographs, selfie photographs, pictures, images, or any other identifier by which you may be contacted online or offline ("Personal Information").
That is about you but individually does not identify you.
This information includes:
Information that you may provide by filling in forms in the App. This includes information provided at the time of registering to use the App, and subscribing to our service, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App.
Records and copies of your correspondence (including email addresses and phone numbers) if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through the App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App.
Your search queries on the App.
Your photographs, selfie photographs, pictures, and images that you select from a mobile device, when using the App, to upload/edit/modify those photographs. You have to grant the App permission to access and use those photographs from the mobile device. Only the specific photographs you select to upload/edit/modify are collected and used by the App, so even if you grant the App access to your camera or mobile device album, those photographs are not collected or used by the App (we safeguard each photograph that you select using an encryption key stored locally on your mobile device which means the mobile device from which the photograph was submitted, using the App, is the only device that can view the photograph).
Your photographs that are generated when using the App's AI face swapping features to create another photograph.
Information We Collect Through Automatic Data Collection Technologies
When you download, access, and use the App, it may use technology to automatically collect:
Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.
Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, the photographs you select to edit via the App, personal contacts, and address book information. While the App does not require or request any metadata attached to the photographs you select for editing, metadata (including, for example, geotags) may be associated with your photographs by default. We take steps to delete any metadata that may be associated with a photograph you provide when you use the App. However, your photographs may remain cached for a limited period, after your last edit, so that you can return to it and make additional changes if you so choose.
Location Information. This App collects real-time information about the location of your device but only to provide you with an appropriate experience (such as preferred language) and to ensure we are abiding by applicable laws specific to the jurisdiction in which the App is accessed and used.
If you do not want us to collect this information do not download the App or delete it from your device.
The technologies we use for automatic information collection may include:
Cookies (or mobile cookies). A cookie is a small file placed on your mobile device. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting, you may be unable to access certain parts of our App.
Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit OWOW, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal Information, to:
Provide you with the App and its contents, and any other information, products, or services that you request from us.
Fulfill any other purpose for which you provide it.
Give you notices about your account or subscription, including expiration and renewal notices, if applicable.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our App according to your individual interests.
Speed up your searches.
Recognize you when you use the App.
As previously stated in this Policy, we use location information we collect to provide you with an appropriate experience (such as preferred language) and to ensure we are abiding by applicable laws specific to the jurisdiction in which the App is accessed and used.
We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at: info@owow.ai.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
In addition, we may disclose Personal Information that we collect, or you provide:
To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. For the avoidance of doubt, your uploaded selfie photograph and any photograph generated with the AI face swapping App features (your “App Generated Content”) is stored in our third party cloud file storage system and the location of those files is stored in a database that is linked to your account. Any photograph you generate using the AI face swapping App features, is sent to our third party AI face-swapping provider and technology partner, Pics.ai, to help us generate the App Generated Content you purchase by completing the photograph transformation. Once the face-swap transformation is complete, Pics.ai deletes and does not store your selfie photograph or the resulting App Generated Content.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of OWOW's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by OWOW about our App users is among the assets transferred.
To third parties to market their products or services to you if you have consented to or have not opted out of these disclosures. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce our rights arising from any contracts entered into between you and us, including the App End User License Agreement, and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of OWOW, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
How Your Information is Retained
Personal Information
If your Personal Information is collected by us, we will retain and use your Personal Information for the period necessary to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law up to a maximum of 60 months.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
Uploaded Content: Any content you upload using the App, such as photographs, your selfie photographs, pictures and images (collectively “Uploaded Content”) and the information associated with such content, may be stored on your mobile device and our servers to optimize your experience with each subsequent use of the App. If your Uploaded Content is stored on our servers, such content is stored for up to twelve (12) months. This period allows you to revisit your Uploaded Content to make further modifications during that time without the need to repeat the onboarding process for each subsequent purchase. If your account is inactive for a period that exceeds such storage time, you will be notified and given a reasonable opportunity to collect all of your Uploaded Content.
App Generated Content: For photographs and other content that you generate using the App’s AI face swapping features ("App Generated Content"), such App Generated Content may be stored on your mobile device and our servers to optimize your experience by minimizing wait times for generating subsequent App Generated Content. If your App Generated Content is stored on our servers, such content is stored for up to twelve (12) months. This period allows you to purchase new App Generated Content without the need to repeat the onboarding process for each subsequent purchase. If your account is inactive for a period that exceeds such storage time, you will be notified and given a reasonable opportunity to collect all of your App Generated Content.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the Personal Information you may provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
Tracking Technologies. You can set your browser to refuse all or some browser cookies (the App only uses first party cookies to collect analytics data, remember language settings, and perform other useful functions that provide a good user experience). If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the App may become inaccessible or not function properly.
Promotion by OWOW. If you do not want us to use your email address to promote our own or third parties' products or services, you can also always opt-out by sending us an email stating your request to info@owow.ai.
Targeted Advertising by OWOW. If you do not want us to use information that we collect or that you provide to us to upsell new products or features and/or deliver advertisements according to our advertisers' target-audience preferences, you can always opt-out by sending us an email, stating your request to info@owow.ai.
Disclosure of Your Information for Third-Party Advertising and Marketing. We will not share your Personal Information with unaffiliated or non-agent third parties for advertising and marketing purposes.
Accessing and Correcting Your Personal Information
You can review and change your Personal Information by logging into the App and visiting your account profile page or by sending us an email at info@owow.ai to request access to, correct, or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Your Data Protection Rights
Cross-Border Data Transfers
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own.
If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”) and your data is transferred outside of the EEA or UK, we ensure at least one of the following safeguards is implemented:
We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us at info@owow.ai if you want further information on the specific mechanism used by us when transferring your personal data.
Data Protection Rights Under the GDPR
If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”), you have certain data protection rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed of what Personal Information, we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
(i) You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
(ii) You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.
(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.
(iv) You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this Policy.
(v) You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.
(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims.
(vii) You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.
(viii) You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. For more information, please contact your local data protection authority in the EEA. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.
California Privacy Rights
Consumers residing in California are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act of 2020 (collectively referred to as the “CPRA”). If you are a California resident, this section applies to you, and you have the right to:
know the categories of Personal Information collected about you in the prior 12 months and its sources and business purpose;
know whether your Personal Information is sold or disclosed, and to whom, in prior 12 months;
opt out of the sale or sharing of your Personal Information;
access and then delete your Personal Information (subject to exceptions);
equal service and price (non-discrimination) if you exercise your privacy rights;
limit the use of your sensitive Personal Information; and
correct your Personal Information.
Under the CPRA, “Personal Information” is defined to include information that identifies, relates to, describes, or is capable of being associated with a particular consumer or household. This includes (among other types of personal information) IP addresses, geolocation data, biometric information, and “unique identifiers” such as device and cookie IDs, Internet activity information like browsing history, commercial information such as products or services purchased or consuming histories or tendencies, and characteristics concerning an individual’s race, color, sex (including pregnancy, childbirth, and related medical conditions), age (40 or older), religion, genetic information, sexual orientation, political affiliation, national origin, disability or citizenship status. Inferences drawn from personal information “to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes” are also considered personal information.
Additionally, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
To exercise your rights under the California data protection laws, simply contact us as detailed below. We will not discriminate against you if you exercise your rights under such laws.
How to Exercise Your Data Protection Rights
Any requests to exercise your rights can be directed to:
Email Address:
info@owow.ai
Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.
You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
Data Security
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards. The information you share in public areas may be viewed by any user of the App.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through our App. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Data Breach
In the event we become aware that the security of the App has been compromised or users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the App, and/or send you an email.
Changes to Our Privacy Policy
We may update this Policy from time to time. If we make material changes to how we treat our users' Personal Information, we will notify you by email to the email address specified in your account.
The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this Policy to check for any changes.
Contact Information
If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:
info@owow.ai
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable privacy and data protection laws.