1. INTRODUCTION
Ownly Ltd. (“Ownly”, “we”, “us”) has created this Privacy Policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through our Website and in the course of providing our services to verify home buyer’s information and facilitating a potential home purchase, as further described in our Terms of Use (the “Services”).
The privacy of our users is of great importance to us. By visiting our website located at https://theownly.io/, including subpages, (collectively, the “Website”), or using the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.
2. WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals and information which can be used to identify an individual (“Personal Information”). Personal Information may be collected about users and visitors to the Website, as well as our customers or affiliates and their end users who use the Services.
This Privacy Policy covers the activities of Ownly. This Privacy Policy does not apply to the practices of companies that we do not own or control, including our customers that sell homes who may use the Services on their own websites to collect Personal Information. Third parties, including but not limited to our home seller or other affiliated companies, are responsible for ensuring that they have obtained the necessary authorizations and consents for any Personal Information you make available to us for use in accordance with this Privacy Policy.
3. COLLECTION AND USE OF PERSONAL INFORMATION
3.1 Account Information. In order to use the Services, users may be required to have a valid Ownly account to log in to the Services (“Account”). When you register for the Services or create an Account, Ownly collects certain information from you (collectively, “Account Information”). If you make an Account with Ownly, Ownly collects your name, email address, personal phone number, address, and other information that you may opt in to provide to Ownly, including credit check information or house valuation information. We use this Personal Information to provide you with the Services.
3.2 Services Information. When our users utilize the Services, Ownly collects your home preferences and building selections and other information about your use of the Website. Ownly also collects your IP address while you are using the Website in order to screen for fraudulent activity and optimize your use of our Services.
3.3 Use of Personal Information. Ownly uses the Account Information and Services Information to:
You have the option to unsubscribe from any electronic marketing communications by following the instructions in an email. However, you will still receive transactional and notification emails that are necessary for the Services.
4. COOKIES
When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the user behaviour, such as recording browsing habits of users when searching communities, models and homes on the Website. We refer to this automatically-collected information as “Device Information”.
We collect Device Information using the following technologies:
The Website uses “cookies” to collect information and improve our products and services. A cookie is a small data file that is stored on your device. Cookies cannot be used to see any other data on your computer, nor can they determine your email address or identity.
We may use “persistent cookies” to save your registration ID and login password for future logins to our service. We may use “session cookies” to enable certain features of our service, to better understand how you interact with our service and to monitor aggregate usage and web traffic routing on our service. We also use session cookies to verify your age, keep track of items you have viewed and store such items in your cart while you are browsing.
The Website may also use technologies such as beacons, scripts, and tags. These technologies may be used for analyzing trends, administering the website, tracking users’ movements around the website, and gathering demographic information about our user base as a whole. Various browsers may offer their own management tools for removing these types of tracking technologies. We may also use third-party ad companies to help provide some of our advertising services. These third parties may place cookies on your computer and collect data about your online activities across websites or online services when you are logged into the third-party service, including for targeted advertising.
5. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
Ownly processes and stores its data, including Personal Information, on servers located in Canada and the United States. Ownly also transfers data to our processing services providers who will have access to and process your personal information. By submitting Personal Information or otherwise using the Services or consenting to the sharing of your information from a third party with Ownly, you agree to this transfer, storing or processing of your Personal Information in Canada and United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court order.
6. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
6.1 Home Seller. If you use the Services on one of our Customer’s websites (e.g. a homebuilder, realtor) to price and build a home, your name and contact information may be shared with the applicable home seller to allow the home seller to contact you about your interest in the home purchase. Personal Information collected by the homebuilder or other third party will be governed by such third-party’s privacy policy.
6.2 Service Providers and Business Partners. We may from time to time employ third parties to perform tasks on our behalf and we may need to share Account Information and other Personal Information with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we currently engage includes third party companies and individuals employed by us to facilitate our services, including for the provision of bank data and mortgage pre-approval documentation; the provision of database management, payment processing and customer relationship management tools, including the Sub-Processors.
6.3 Business Transfers. If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
6.4 With Your Consent. If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.
6.5 As Required by Law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.
We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:
The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.
7. RETENTION
We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.
8. INTERNATIONAL USERS
If you are visiting the Website or using the Services from outside of Canada, please note that you are agreeing to the transfer of your information to Canada and the United States and for it to be processed globally by our third-party Sub-Processors. By providing your information you consent to any transfer and processing in accordance with this Policy.
9. ACCESS, CORRECTION AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
10. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website or Services after such changes have been first posted.
11. ADDITIONAL INFORMATION
Questions regarding this Privacy Policy or Ownly’s privacy practices should be directed to our Privacy Officer:
Ray Yip
Privacy Officer
Suite 1210, 150-9th Avenue SW, Calgary, AB, Canada, T2P 3H9
Email: [email protected]
Effective Date: March 13, 2023
