The privacy policy below describes our privacy practices for all websites, platforms and services related to it.

1. Definitions
   

   If you see an undefined term in this Privacy Policy (such as “Listing” or “GOODOWL Platform”), it has the same definition as in our Terms of Service (“Terms”).

2. Information collector
   

   When this policy mentions “GOODOWL,” “we,” “us,” or “our,” it refers to the GOODOWL company that is responsible for your information under this Privacy Policy (the “Information collector”).

3. Applicability to Payments
   

   This Privacy Policy also applies to the Payment Services provided to you by GOODOWL pursuant to the Payments Terms of Service. When using the Payment Services, you will be also providing your information, including personal information, to one or more GOODOWL entities, which will also be the Information collector (the "Payments Information collector") of your information related to the Payment Services.

1. Information You Give to Us.
1.1 Information that is necessary for the use of the GOODOWL Platform.

We ask for and collect the following personal information about you when you use the GOODOWL Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

Account Information. When you sign up for an GOODOWL Account, we require certain information such as your first name, last name, email address, and date of birth.

Profile and Listing Information. To use certain features of the GOODOWL Platform (such as booking or creating a Listing), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.

Identity Verification Information. To help create and maintain a trusted environment, we collect identity verification information.

Payment Information. To use certain features of the GOODOWL Platform, we may require you to provide certain financial information (like your bank account or credit card information, or Paypal information) in order to facilitate the processing of payments.

Communications with GOODOWL and other Members. When you communicate with GOODOWL or use the GOODOWL Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.

1.2 Information you choose to give us.

You may choose to provide us with additional personal information in order to obtain a better user experience when using GOODOWL Platform. This additional information will be processed based on our legitimate interest or when applicable, your consent.

Additional Profile Information. You may choose to provide additional information as part of your GOODOWL profile (such as gender, language(s), city, and a personal description). Some of this information as indicated in your Account settings is part of your public profile page, and will be publicly visible to others.

Contact Information. You may choose to list your employees’ information manually to access certain features of the GOODOWL Platform, like inviting them to use GOODOWL.

Other Information. You may otherwise choose to provide us information when you fill in a form, update or add information to your GOODOWL Account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team, share your experience with us, or use other features of the GOODOWL Platform.

1.3 Information that is necessary for the use of the Payment Services.

The Payments Information collector needs to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services.

Payment Information. When you use the Payment Services, the Payments Information collector requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.

Identity Verification and Other Information. If you are a Professional, the Payments Information collector may require identity verification information (such as images of your government issued ID, passport, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payment Services to you, and to comply with applicable law.

1.4 Information We Automatically Collect from Your Use of the GOODOWL Platform and Payment Services.

When you use the GOODOWL Platform and the Payment Services, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the GOODOWL Platform and Payment Services.

Geo-location Information. When you use certain features of the GOODOWL Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. GOODOWL may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.

Usage Information. We collect information about your interactions with the GOODOWL Platform such as the pages or content you view, your searches, and other actions on the GOODOWL Platform.

Log Data and Device Information. We automatically collect log data and device information when you access and use the GOODOWL Platform, even if you have not created an GOODOWL Account or logged in. That information includes, among other things: details about how you’ve used the GOODOWL Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the GOODOWL Platform.

Cookies and Similar Technologies. We use cookies and other similar technologies when you use our platform, use our mobile app, or engage with our online ads or email communications.

Payment Transaction Information. GOODOWL Payments collects information related to your payment transactions through the GOODOWL Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and GOODOWL Payments and to allow the provision of the Payment Services.

1.5 Information We Collect from Third Parties.

GOODOWL and GOODOWL Payments may collect information, including personal information, that others provide about you when they use the GOODOWL Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the GOODOWL Platform and the Payment Services. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

Third Party Services. If you link, connect, or login to your GOODOWL Account with a third party service (e.g. Google, Facebook, WeChat), the third party service may send us information such as your registration, friends list, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.

Your Reviews. If someone has posted a review for you, it will be published on your GOODOWL public profile page.

Background Information. To the extent permitted by applicable laws, GOODOWL and GOODOWL Payments may obtain reports from public records of criminal convictions or sex offender registrations, the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.

Referrals. If you are invited to GOODOWL, the person who invited you may submit personal information about you such as your email address or other contact information.

Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the GOODOWL Platform through partnerships, or about your experiences and interactions from our partner ad networks.

We may use, store, and process personal information to (1) provide, understand, improve, and develop the GOODOWL Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with GOODOWL Policies) and (3) provide, personalize, measure, and improve our advertising and marketing.

1 Develop the GOODOWL Platform. We may use the personal information to provide, improve, and develop the GOODOWL Platform such as to:

enable you to access and use the GOODOWL Platform,

enable you to communicate with other Members,

operate, protect, improve, and optimize the GOODOWL Platform and experience, such as by performing analytics and conducting research,

provide customer service,

send you service or support messages, updates, security alerts, and account notifications,

if you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection

to operate, protect, improve, and optimize the GOODOWL Platform and experience

enable your use of our enterprise products.

We process this personal information for these purposes given our legitimate interest in improving the GOODOWL Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.

2 Maintain a Trusted Environment. We may use the personal information to create and maintain a trusted and safer environment such as to:

detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,

conduct security investigations and risk assessments,

verify or authenticate information or identifications provided by you

conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required,

comply with our legal obligations,

Resolve any disputes with any of our Members and enforce our agreements with third parties,

Resolve any disputes with any of our Members and enforce our agreements with third parties,

in connection with the activities above, we may conduct profiling based on your interactions with the GOODOWL Platform,your profile information and other content you submit to the GOODOWL Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the GOODOWL Platform if such processes detect activity that we think poses a safety or other risk to the GOODOWL Platform, our community, or third parties. If you challenge the decisioning based on the automated process, please contact us as provided in the Contact Us section below.

We process this personal information for these purposes given our legitimate interest in protecting the GOODOWL Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. We may use the personal information to provide, personalize, measure, and improve our advertising and marketing such as to:

send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences,

conduct profiling on your characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think may be of interest to you,

invite you to events and relevant opportunities

4 How the Payments Information collector uses the Personal Information Collected. We may use the personal information as a part of Payment services such as to:

Enable you to access and use the Payment Services.

Detect and prevent fraud, abuse, security incidents, and other harmful activity.

Conduct security investigations and risk assessments.

Conduct checks against databases and other information sources.

Comply with legal obligations (such as anti-money laundering regulations).

Enforce the Payment Terms and other payment policies.

With your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

The Payments Information collector processes this personal information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

GOODOWL and GOODOWL Payments may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against GOODOWL, (iii) to respond to valid requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of GOODOWL, its employees, its Members, or members of the public. For example, Professional tax information may be shared with tax authorities or other governmental agencies.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the GOODOWL Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage. Service Providers.GOODOWL and GOODOWL Payments uses a variety of third-party service providers to help us provide services related to the GOODOWL Platform and the Payment Services. Service providers may be located around the world.These providers have limited access to your personal information to perform tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions .GOODOWL and the GOODOWL Payments will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you. Corporate Affiliates. To enable or support us in providing the GOODOWL Platform and the Payment Services, we may share your information, including personal information, within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control.The data sharing is necessary for the performance of the contract between you and us, in order to support and integrate, promote, and to improve the GOODOWL Platform and our affiliates’ services. Information Provided to Firms. If you have linked your professional Account to a FIRM account, added your work email address or any other information, that FIRM will have access to your name, contact details, permissions and roles, and other information as required to enable use by you and the FIRM of the platform. Business Transfers. If GOODOWL undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy. Aggregated Data.We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

1. Analyzing your Communications.
   We may review, scan, or analyze your communications on the GOODOWL Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.
   
   These activities are carried out based on GOODOWL's legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

You may exercise any of the rights described in this section before your applicable GOODOWL Information collector and Payments Information collector by communicating with us through the Contact us section. Please note that we may ask you to verify your identity and request before taking further action on your request.

1. Rectification of Inaccurate or Incomplete Information.
   You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your GOODOWL Account).

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your GOODOWL Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your GOODOWL Account, please contact us following the instructions in the Contact Us section.

GOODOWL reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the GOODOWL Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the GOODOWL Platform will be subject to the revised Privacy Policy.