Privacy policy

This privacy policy (“Privacy Policy”) covers the collection, use, and disclosure of information collected by Owners Room AS (“OwnersRoom”, “we”, “us”, or “our”) through our website www.ownersroom.com and its subdomains (“website”), as well as any connected applications that have been developed by OwnersRoom. If you have any questions regarding our protection or processing of your data, please contact us on e-mail: data-privacy@ownersroom.com. If you are looking for our Cookie Policy, you can find it here.

By using the OwnersRoom investor portal, www.ownersroom.com, app.ownersroom.com or any of our products and services (“Services”), you provide your consent to how we obtain and process personal data, including the purposes for which we process data and how we share data internally and with third parties. When you explicitly accept our Terms of Service, you also accept the conditions outlined in this Privacy Policy.

Definitions

In this Privacy Policy, these terms have the following meaning:

“User” refers to any natural person that is registered with us to use our Services.

“Customer” refers to a company that is registered with an OwnersRoom investor portal, either through Paid or Free Services.

“Administrator” refers to any User that holds administrator rights of a Customer’s investor portal.

“Member” refers to any User that has been given access to the investor portal of a Customer.

“Contact” refers to any natural person that has been invited into the investor portal of a Customer by that company’s Administrator but has not yet registered with us to use our Services.

“Visitor” refers to any natural personal or entity that visits our website.

The terms “you” and “your” refers to any of the above definitions, depending on the context.

 

How we collect data

 

Data from our website

We collect non-personally identifying information of the type that is typically made available by web browsers and servers, such as the browser type, language preference, referring site, and the date and time of each visitor request. The purpose in collecting non-personally identifying information is to better understand how our website’s visitors interact with our website.

 

When Visitors choose to interact with our website in a way that requires personally identifying information about our visitors, OwnersRoom will ask for consent to gather personally-identifying information to fulfill the requested service. The amount and type of information that we collect depends on the nature of the interaction. OwnersRooms collects information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with our website.

 

Those who wish to be contacted by OwnersRoom in order to pursue a business transaction may be required to supply additional information. OwnersRoom further collects any other data submitted in a contact form on our website, such as name, phone numbers and email-addresses entered to forms regarding “request early access”, “sign up for our newsletter” or by applying for job openings through our website.

 

Visitors to our websites can always refuse to provide their personally-identifying information, but this may prevent us from being able to provide the full Services we offer.

 

Data from our application and Services

With the explicit consent from our users, we collect, and process information obtained directly from users of our application and Services, for which information OwnersRoom acts as Data Controller.

 

As a registered Administrator, Member or User of our Services, we store and process:

– Your name and contact details such as phone number and registered e-mail address, profile picture, “about me”-text, and any other kind of information you may enter or upload into our service,

– technical identifiers, such as IP-address, geographic location, user id, browser information (type, device, language, etc.),

– site navigation information about your behavior and actions within the Application,

– email handling information when you interact with an email sent to you by one of our Customers or OwnersRoom, such as which emails you open and click, including when and how.

 

As a registered Contact of our Services, we store and process:

– Your registered email, as provided by the Administrator of a Customer.

– email handling information when you interact with an email sent to you by one of our Customers or OwnersRoom, such as which emails you open and click, including when and how.

 

 

How we process your data

 

Data processed on behalf of our Customers

OwnersRoom may process personal data on behalf of our Customers. We are not Data Controllers of this data, and act as Data Processors. We will process such data on behalf of our Customer as as prescribed in the data processor agreement. Our Customer’s privacy policy or other agreement between the Customer and you personally (or other legal entities you represent) will apply to such processing.

 

If your personal data is processed by OwnersRoom on behalf of one of our Customers and you wish to discontinue such processing, please contact the OwnersRoom Customer directly. To exercise any of your rights as a data subject regarding data processed on behalf of our Customer, please contact the OwnersRoom Customer directly.

 

We expect that all personal data our Customers upload is done with the explicit consent of the person whose data it is, and that this is done in accordance with applicable rules and regulations. While we do not take responsibility for any breach of this privacy policy caused by the actions of our Customers, we are always trying to reduce the likelihood of such events.

 

Your data

By agreeing to this Privacy Policy you agree that your data may be shared with any related Customers using OwnersRoom’s Services, including with any Customer where you have been registered as an Administrator, Member, or Contact. We will share information about you with the current Administrators of the investor portals where you are a registered Member or Contact. This includes the data that you have entered on your user’s profile, such as email address, name, profile picture, and any text you may have entered in the “about” field. It further includes data about your actions within that specific investor portal, such as document downloads, page-visits, clicks, and other data about your navigation within a Customer investor portal, as well as email interaction such as deliverability, opens, and clicks when a Customer has sent a news post or invite via email to the registered Members and Contacts of their investor portal.

 

 

How we use the information

The information collected is maintained for the purpose of fulfilling our contractual obligations with our Customers and Users. The data collected through our service and connected applications will be used for the following:

– Providing the service for which you have engaged OwnersRoom.

– Investigating potential violations of our Terms of Service

– Provide information about events and happenings

– Provide information about potential investment opportunities

– Provide information about new services, campaigns and updates

– Customer support

– Collecting statistical data about the use of our Services

 

We may share or in other ways release aggregated, non-personally-identifying information, such as statistics.

 

How we protect your data

We take the protection of your data very seriously. You may at all times contact us on data-privacy@ownersroom.com for inquiries about what personal data we have stored about you, and request that we delete personal data about you for which OwnersRoom is the Data Controller.

 

OwnersRoom discloses personally-identifying information only to those of our employees, contractors and affiliated organizations that (i) need to know that information in order to process it on OwnersRoom’s behalf or to provide Services available at our website, and (ii) that contractually obligated not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using OwnersRoom’s website and Services, you consent to the transfer of such information to them.

 

Other than to its employees, contractors and affiliated organizations, as described above, OwnersRoom discloses personally-identifying information only in response to a court order or other governmental request, or when OwnersRoom believes, in good faith, that disclosure is reasonably necessary to protect the property or rights of OwnersRoom, third parties or the public at large.

 

OwnersRoom will not rent or sell personally-identifying information to anyone. If you send us a request (for example, via a support email), we reserve the right to publish it in order to help clarify or respond to your request or to help provide support to other users.

 

We take all measures that are reasonably necessary to protect against the unauthorized access, use, alteration or destruction of personally-identifying information.

 

Links

OwnersRoom’ website contains links to other sites. Please be aware that OwnersRoom is not responsible for the privacy practices of other such sites. We encourage our users to be aware when they leave our website and to read the privacy statements of each and every website that collects personal information. This Privacy Policy applies solely to information collected by OwnersRoom.

 

3rd Party disclosure

Only aggregated, anonymized data is periodically transmitted to external services to help us improve our website and the OwnersRoom Services. This is true in the following cases:

 

Our website

www.ownersroom.com uses Google Analytics for anonymous tracking. This is a tool which enables us to track the traffic and use of our website, e.g. by knowing which pages have been visited. Only anonymous session data is tracked.

 

We use Mailchimp and SendGrid as a newsletter service providers. Therefore, Mailchimp and SendGrid are possible processors of the information you submit in a form on our website.

 

Our Services

With your consent, we use Mailchimp and SendGrid to send bulk emails to the users of our service, such as updates on new features, campaigns, and account administration.

 

Additionally, we use SendGrid to send email on behalf of our Customers. Customers are required to indicate that they have prior consent to send emails to these Members and Contacts. SendGrid is used to send news posts via email to the Members and Contacts of their investor portal. SendGrid collects data about emails that are delivered, opened, clicked and bounced. SendGrid retains this data for a period of 3 days and uses it to track the reputation of emails being sent from our domain and to avoid sending to email addresses that bounce. OwnersRoom imports this data from SendGrid and retains it for a period of 1 year. This data is presented to Administrators such that they have a record of which Members and Contacts have received which emails. These statistics are particularly important in the case of formal notices or similar notices where reception of the notice is mandatory by law.

 

We share our users e-mail addresses with Auth0 for the purposes of authorization and unique identification on our software service. In addition to email addresses, IP addresses and user-agents may also be stored there, as well as other metadata. Auth0 retains this data for a period of 2 days and uses it to detect brute force attacks against customer accounts and other security abnormalities. OwnersRoom imports this data from Auth0 and stores it for a period of 1 year. We use this data for internal auditing and reporting and for detecting anomalies in login behavior. This data is not exposed to any of our users.

 

Your rights

As an EU/EEC-citizen, you have the right under certain circumstances:

– to be provided with a copy of your personal data held by us

– to request the rectification or erasure of your personal data held by us

– to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example)

– to object to the further processing of your personal data, including the right to object to marketing

– to request that your provided personal data be moved to a third party

 

You can exercise the rights listed above at any time by contacting us at data-privacy@ownersroom.com.

 

Additionally, as a Member, you can at any time request a data takeout or data deletion from your user profile settings. On receiving such a request, OwnersRoom shall within 30 days handle the request on behalf of the User.

 

If you, as a Member or Contact, no longer wish to receive news posts via email from a Customer that has invited you into their investor portal, you can unsubscribe from such emails directly from that email or contact the Customer directly to update or delete your data.

 

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.

 

Retention

OwnersRoom will retain personal data we process on behalf of our Customers as long as needed to provide Services to our Customer. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Information we collect in order to demonstrate our Services is maintained until the purpose of the collection has been fulfilled.

 

Cancellation or termination of account

OwnersRoom can completely remove all our users’ and Customer’s documents, files, and other data upon request, with the exception of data that is processed on behalf of our Customers (see “Data processed on behalf of our Customers”). If your account is terminated for any reason, please contact us with any question about your data on data-privacy@ownersroom.com.

 

Changes to this Policy

We may amend this Privacy Policy from time to time. The latest version will at all times be available through our website. You are advised to consult this Privacy Policy regularly for any changes.

 

We reserve the right, at our sole discretion, to modify or replace this Privacy Policy at any time. If a revision is material, we will try to provide a message on our website to inform when new terms are taken into effect. What constitutes a material change will be determined at our sole discretion. By continuing to use the Services you agree to any potential modifications of this Privacy policy.

 

If OwnersRoom is involved in a merger, acquisition, or sale of all or a large portion (>70%) of its assets, our Customers and Users will be notified via email and/or a prominent notice on our website.