Overview
The General Data Protection Regulation (GDPR) provides guidelines for collecting and processing personal data of individuals within the European Union (EU). This Data Protection Policy outlines how OneTen Solutions Ltd (C101635), trading as Owly (“we”, “us”, or “our”), either directly or through subsidiaries or licensees, processes any personal data you provide via our electronic platforms such as mobile apps, web (app.getowly.com), or other designated platforms (the “Portal”).
General Information
We collect and process personal data provided by you or third parties, as well as any additional information we may need over time. By using our Portal and its services (the “Services”), you agree to this Data Protection Policy. We may update this Policy periodically, and we will notify you of changes by posting a notice on http://getowly.com/privacy-policy/, sending an email, or other means. Your continued use of the Services after changes are posted signifies your acceptance of the revised Policy.
Data Collection
We collect personal data when you:
- Register an account,
- Use the Services,
- Submit comments or report issues,
- Request information and provide contact details,
- Participate in contests or surveys,
- Register manually.
We may also process your child’s personal data provided by their school or you. You consent to our processing of your child’s data in accordance with this Policy.
Types of Personal Data Collected
“Personal Data” refers to information that identifies an individual, either directly or indirectly. We may collect:
- Your name and contact details,
- Your child’s personal data (name, photo, identification number, emergency contact, and related content).
If we cannot process this information, we may be unable to provide the Services. We also collect:
- Data on your activities through the Portal,
- Transactional history,
- Information collected via cookies.
Some data is automatically collected from your browser, such as IP address, cookie information, web pages requested, browser type, language, access times, and referring website address.
If you provide information about another person, you confirm you have their consent to share their data and receive notices on their behalf.
Use of Personal Data
Beyond providing the Services, we use your data to:
- Maintain and improve the Portal,
- Tailor content to your interests,
- Enforce Terms of Use,
- Conduct research and reporting,
- Operate and maintain the Portal,
- Communicate with you about the Portal,
- Investigate complaints and improve services,
- Respond to user inquiries,
- Conduct market surveys and analytics.
Sharing Personal Data
We may share your data with:
- Third-party service providers assisting in our business operations,
- Third-party data processors,
- Confidentiality-bound individuals fulfilling our obligations.
We do not share your child’s data for marketing purposes but may need to share it with the School to provide Services. Your child’s data may be visible to other users of the Portal (e.g., in photos with other children).
We may disclose data if required by law or to protect our rights. Data may also be transferred in case of a merger or acquisition.
Your Rights
You can request access to, correction, or deletion of your personal data by writing to us. Include proof of identity and address, specify the data you want access to or corrected. If objecting to direct marketing, specify the communication channel. Requests will be addressed within a reasonable timeframe.
Data Retention
We retain personal data as long as necessary for the purposes it was collected, legal requirements, or business purposes. Data such as child and parent details, school fees, health records, attendance, and portfolio will be kept while the school uses our services. When data is no longer needed, it will be deleted or anonymized.
Data Storage and Security
We use Google Cloud, Amazon Web Service, and OVH for data storage and processing. Updated firewalls and technical measures protect our network. Data backups are encrypted and stored for 30 days. Servers are located in Europe. Access to data is restricted to authorised employees with business purposes.
Security Breach Procedure
If a security breach occurs, we will identify and mitigate the issue, notify affected parties, and restore data from backups if needed. Notifications will include information on the breach and any special precautions required.
Contact Information
For access requests, corrections, or inquiries about your data, contact:
Data Protection Officer
info@getowly.com
OneTen Solutions Ltd
Additional Services
- Analytics: Google Analytics, Facebook Pixel
- Contacting Users: Signup and demo request forms
- Payments: Stripe
- Hosting: Google Cloud Services, Amazon Web Service, OVH
- Support: Apple App Store, Google Play Store, Chat
- Push Notifications: Users can opt-out via device settings
- User Identification: UUID for analytics and preferences