Effective as of 30 August 2024
Thank you for accessing or using this website and any associated webpages and/or social media pages (our "Website") and/or all services, applications
and/or products accessible via the Website or our application programming interfaces (APIs), or otherwise made
available to you by us (the "OwllAI") (our Website and OwllAI are collectively known as our
"Services").
For the purposes of data protection and privacy laws, TIYA PTE LTD and RAMBUTANAI PTE. LTD. ("we" or "us") are
joint controllers in the processing of your personal information. We are committed to protecting your privacy
through our data practices described in this Privacy Policy.
This Privacy Policy describes:
• The ways we collect personal information about you and why we do so;
• How we or our Authorised Partners use your personal information;
• The choices you have about your personal information; and
• How we protect your personal information.
For the purposes of this Privacy Policy, the terms “personal information” and “personal data” are used
synonymously. This Privacy Policy does not apply to our data collection activities offline or otherwise
outside of the Services (unless otherwise stated below or at the time of collection).
Residents of certain U.S. states have privacy rights detailed in our Privacy Notice to US Residents. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice to US Residents, the latter will control.
We reserve the right to change and may periodically update this Privacy Policy prospectively effective upon
the posting of the revised Privacy Policy on our Website. Where required, we endeavour to notify you of
material changes to this Privacy Policy by posting a notice on our Website. Your continued use of our Services
following the posting of changes to the Privacy Policy or any notification to you shall mean you accept those
changes. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or
unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and
enforceable.
The designated joint controller representative is RAMBUTANAI Pte Ltd which is entitled to act on behalf of Tiya Pte Ltd and is responsible for processing and responding to data requests made by you or any government
authority.
If you have questions about how we collect, use, process or protect your personal information, or if you have
any requests in respect of your personal information, you may contact us:
Name of data controller:
RAMBUTANAI PTE. LTD.
Address:
60 ANSON ROAD #09-01/02 MAPLETREE ANSON SINGAPORE (079914)
Attn:
Data Protection Officer
Email:
feedback@owll.ai
We will respond to your requests in accordance with applicable laws and may take additional steps to verify
your identity before fulfilling your request. These steps may include verifying your account details. You may
also designate an authorized agent to act on your behalf but we reserve the right to verify the agent's
identity and authority, and may deny any requests in appropriate circumstances.
We endeavour to respond to all requests in a timely manner. For more complex requests, we may charge a fee
for processing your request. We will inform you of such fees before proceeding with your request. If you have
any unresolved concerns about your privacy rights or personal data protection that we could not address
adequately, you may contact your local privacy and personal data protection authority for further
assistance.
2. Collection of Personal Information
(I) Information you provide when you create or update your account
|
Category |
Description |
|
User Data |
You do not need to provide any personal identifiers (such as name or phone number) to start using
OwllAI.
When you use OwllAI, we will collect information such as your country and device langugage
settings in order to enable you to use the features. We collect some of this data from your device. For
more information about how we collect and use this data, see ‘Your general (non-precise) location’ in
the Usage Data category.
When you send us feedback or request, we may collect your name and email address etc as well as the
contents of those feedback or requests. |
(II) Information We Get When You Use Our Services
When you use our Services, we may automatically collect information about you and how you use our Services.
We only use pseudonymized or anonymised data that have gone through a privacy-enhancement process to protect
and improve the functionalities of the Services.
|
Category |
Description |
|
User Content |
• All information, text, audio file, audio content, voice recordings or any other materials whatsoever,
whether input, uploaded, transmitted, recorded or used by you in conjunction with OwllAI
(collectively “Submitted Content”) are collected by us.
• The Output generated using your Submitted Content are also collected by us.
• We process your Submitted Content and Output for purposes of enabling you to use the Services,
monitoring for and preventing abusive or harmful use of our Services or for analytics purposes.
• Your Submitted Content are deleted immediately after the corresponding Output is generated. |
|
Optional data you may choose to share with us |
|
|
Category |
Description |
|
Survey and User Research Data
|
When you respond to a survey or take part in user research, we collect and use the personal data you
provide. |
(III) Information We Collect from Third Parties
|
Categories of Third Parties |
Description |
Data Categories |
|
Law Enforcement Agencies |
We may receive information from law enforcement about potential violations of our Terms of Use.
|
User Data
User Content |
3. How Do We Use Your Information
DO NOT SELL.
We do not sell your personal information. We also do not transfer, disclose or share your personal
information with third parties, except where the information is necessarily transferred, disclosed and shared
with our authorised third-party partners who must use and process your information solely to provide you with
the Services on our behalf.
We use your personal information for the following purposes only when it is necessary to do so for valid
reasons (such as with your consent, to comply the law, to provide you with the Services, to protect your
rights and interest or to fulfil our legitimate business interests) and in accordance with applicable
laws:
|
Purpose |
Legal basis |
|
To allow you to use the Services and generally manage your account. |
They are necessary to provide you the Services. |
|
To deliver and facilitate the delivery and use of the Services |
They are necessary to provide you the Services. |
|
To better understand how OwllAI users use and interact with the Services. |
We have legitimate interests to develop and improve our products and features for our users. |
|
To comply with our legal obligations, respond to legal requests, respond to requests from law
enforcement authorities (such as police, prisons, courts) as well as exercise, establish or defend our
legal rights. |
Compliance with legal obligations |
|
To take appropriate action in respect of intellectual property infringement claims or reports of
inappropriate content or activity. |
Legitimate interest to protect our legal rights |
|
To diagnose, troubleshoot and fix issues with the service |
They are necessary to provide you the Services. |
|
When OwllAI users respond to a survey or take part in user research, we collect and use the
personal information as described in the survey or user research. |
You provide consent for processing personal information. |
|
To evaluate and develop new features or technologies. |
Legitimate interest to improve our products, improve user experience and develop new products for our
users. |
4. Who Else Can Use Your Information
We may share your information with other entities in the following situations:
A) Our Related Entities: We might share your personal information with our related entities in the same corporate group to
assist us in technical processing operations (such as data hosting, analytics or maintenance), finance, legal,
HR or accounting assistance, enhancing security against spam, abuse, fraud, infringement or other wrongdoings,
and improve the Services; for corporate audit, analysis, strategic planning, research and development,
corporate transactions (for example merger and acquisition, sale of company assets, financing etc); or
compliance with applicable law. Each entity within the group may only use your personal information in
accordance with this Privacy Policy.
B) Our Authorised Partners: We may work with third party vendors to provide the Services ("Authorised Partners" or "Vendors"). We
seek to update our list of Authorised Partners below as soon as practicable. These Authorised Partners process
your information only at and according to our instructions. They perform tasks such as hosting, user support,
analytics and fraud detection and prevention. For more information, please read the privacy policies of our
Vendors.
|
Vendor |
Purpose |
|
NA |
|
C) Government Agencies:
In order to combat fraud and illegal activity, we may process and disclose information to other organizations
or provide information to government agencies in response to any lawful request. If required by any government
authority or courts for any purposes such as the enforcement of any laws or to prevent their contravention, we
may release your personal information as is legally required or permitted.
5. Cross Border Data Transfers
In order to provide you with the full range of Services efficiently, we are working with authorised third
party partners as well as related entities within the same corporate group around the world. Accordingly, your
personal information may be accessed by our authorised personnel around the world and/or your personal
information may be lawfully transferred at our instructions for limited access, use or processing by our
authorised personnel around the world. Because the data protection and privacy laws in other countries may be
different from those of your home country, we will take steps to ensure that adequate safeguards are in place
to protect your personal information as explained in this Privacy Policy. Adequate safeguards that we may use
include relying on approved standard contractual clauses and implementing other lawful safeguards.
In order for you to use the Services, we may need to access your device's microphone. You have the option to
grant or deny microphone access at any time through your device settings. If you choose not to grant access,
certain features of the application may not be available to you.
B) Access the personal information we hold about you
Upon your written request and successful verification of your identity, we will provide you with a copy of
your personal information in an electronic format.
C) Personal information rights
You may, at any time, withdraw your consent for us to collect, use, disclose or transfer your personal
information to third parties. You also have the right to rectify or delete your personal information, or limit
the porcessing of your personal information. Upon receipt of your written request, we require reasonable time
(depending on the complexity of the request and its impact on our relationship with you) for your request to
be processed and for us to notify you of the consequences regarding the same. In general, we shall seek to
process your request within thirty (30) calendar days of receiving it. Depending on the nature and scope of
your request, you may not be able to access some or all features of our Services, and we may have to terminate
the User Agreement we have with you. We will notify you before completing the processing of your request.
Should you decide to cancel your request, please inform us immediately.
Please note that
a. If you choose not to provide us with all the personal information as required to (i) use the Services, (ii)
process your personal information requests or (iii) assist you on other feedback, queries or requests, we may
(x) be unable to, or refuse to, process your personal information for any of the purposes stated herein, (y)
be unable to (or continue to) perform our contractual obligations owed to you (if any), and/or (z) have to
terminate the User Agreement, without any liability on our part.
b. You may withdraw your consent to using or disclosing your personal information at any time by
contacting us, but withdrawing does not affect the lawfulness of the processing before the withdrawal
nor our rights to collect such information where (i) such use or disclosure is required by law, (ii) the
personal data in question was collected from publicly available sources or (iii) such use or disclosure is
necessary in an emergency where the life or health of a person is at risk.
c. You may, by providing us with a notice in writing, limit the processing of your personal information
(including to request us to cease or not begin processing your personal information for purposes of direct
marketing). If you limit the processing of your personal information, we may not be in a position to continue
to administer any arrangement or contractual relationship in place, which in turn may result in: (i) us being
unable to (or continue to) process your personal information for any of the purposes stipulated in this
Privacy Policy; (ii) unable to (or continue to) perform our contractual obligations owed to you (if any);
and/or (iii) the termination of any arrangements/agreements/contracts you have with us, without any liability
on our part.
d. Even if you ask us to delete all or some of your personal information, we may still retain some of your data
to the extent necessary to serve our legitimate business interests, such as to comply with our legal
obligations, resolve disputes, and enforce our agreements. Where required under applicable laws or if you
reside in Japan, we will explain to you in greater detail about why we cannot delete your personal data when
we receive such requests.
Under applicable laws, you may have the right to obtain a transferable version of your personal information
to transfer to another provider.
To exercise your personal information rights, please contact us according to Section 1 "Contact Us" above.
You will not be subject to discriminatory treatment for exercising your rights.
7. How Do We Protect Your Personal Information
In order to help ensure a secure environment for the Services and safe experience for our users, we are
continuously developing and implementing reasonable administrative, technical and physical security measures
to protect your personal information from unauthorized use or access and against loss, misuse or
alteration.
While we try our best, we cannot warrant the security of any information transmitted to us through or in
connection with the Services, that we store on our or our authorised partners' systems.
Any improper collection or misuse of personal information is a violation of this Privacy Policy and our Terms of Use and should be reported to feedback@owll.ai
B) Pseudonymisation, anonymisation and aggregation techniques
These privacy-enhancing techniques involve modifying or removing certain identifying information from your
personal data and information to make it more difficult to link the data or information to you. We only use
information that has gone through this privacy-enhancement process if we are using them to improve
functionalities of the Services.
C) Personal information retention
Generally, we will store your personal information only for the time period necessary:
a. to fulfil the purposes for which such personal information was collected;
b. for as long as needed to provide you the Services; or
c. as required or permitted by applicable laws (such as tax, accounting, or other legal requirements).
Once we determine that the retention of your personal information is no longer necessary for the above
purposes, or that retention is no longer necessary for any legal or business purpose, we will cease to retain
your personal information, or anonymise the personal information so that it can no longer be used to identify
any particular individual.
8. Protecting Children's Privacy
We believe in protecting children's privacy online. OwllAI is not meant for use by minors. If you are
under the legal age of your country, please do not use our OwllAI in any manner.
We do not knowingly collect personal information and data from children and the OwllAI is not directed
at children. Any person who provides their personal information to us through our Services explicitly
represents that they are of legal age. If we become aware that a minor has provided us with their personal
information, we will, where technically feasible and commercially practical, disable that user's access to our
Services and promptly delete their information or remove their information to the extent required by law, save
when we are under a legal obligation to keep certain information.
Residents of certain U.S. states have privacy rights detailed in our Privacy Notice to US Residents. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice to US Residents, the latter will control.