Last updated January 11, 2024

Introduction - Scope

Welcome to the website ownassistant.ai (hereinafter “Website”) of the company under the name “Own.Solutions” and with the distinctive title Own.Solutions AC Ltd, based in Marina Village, Malahide, Co. Dublin K36 N702, Ireland (hereinafter Own.Solutions, “Company”, “us”, or “we”), owner contact email: support@own.solutions.

This Policy governs the management practices of personal data and information of natural persons (collectively, “Data Subjects” or “Subjects”) who either visit our Website individually on their own initiative or are customers who use the virtual service assistant application using artificial intelligence technology as a service (“SaaS application”), hereinafter collectively “Service”.

This Policy explains how we collect, process and protect Data Subjects’ information as part of the Service provided, in compliance with the applicable national and European regulatory framework for the protection of privacy and personal data, and in particular, Regulation (EU) 2016/679, also known as GDPR (‘GDPR’ or ‘Regulation’), Law 4624/2019 and Law 3471/2006, which incorporated the European Directive 2002/58/EC (e-Privacy Directive), as applicable, including the relevant decisions of national and European courts, as well as the relevant Guidelines and decisions of the competent supervisory authorities and the European Data Protection Board, hereinafter collectively referred to as “Applicable Legislation”. Any reference to your use of the Service in this Policy includes your visits and other interactions with the Website and the Service, regardless of whether you are a user of the Own.Assistant SaaS application.

By accessing and using the Service, you declare your acceptance of the terms of this Policy. If you do not agree or are not familiar with any aspect of this Policy or the Terms and Conditions of Use of Services, you should immediately discontinue access to or use of our Service.

Our relationship with you

On this point our relationship with you is defined. If you have provided to us some personal information, for instance by subscribing to our newsletter, then you are a “User” and Own.Solutions is Controller for processing your account information, such as your name and email address. If you are using the SaaS app, then you are a “Customer” and Own.Solutions is Processor performing the processing on your behalf. The ” Customer’s End User” is someone who provides personal information to our Customers. We do not have a direct relationship with them. Note that these categories do not rule out each other — you may belong to all three!

In order to fully understand your rights and Own.Solution’s obligations under this Policy, it is important to determine your relationship with Own.Solutions.

“User” or “simple User” means the natural person who provides to us personal data through the Website, for instance by subscribing to our newsletter or creating an account. In this case, Own.Solutions shall be Controller of your personal data in compliance with Article 4 GDPR

"Customer" means a natural or legal person who chooses to use the SaaS application for the mutual benefit of himself/itself and his/its own customers. In this case, Own.Solutions shall act as Processor on behalf of the Customer in compliance with Article 4 GDPR.

“Customer’s End User” means any natural person who interacts on our Customers website/webpage and provides to them his personal information. Own.Solutions is not directly related to the Costumer’s End Users. We do not control the purposes or the means by which this personal information is collected and we have no direct relationship with the Customer’s End Users. For more details on the processing of your personal information as a Customer’s End User, see our respective Customers’ Privacy Policies.

Henceforth, we may refer to Customers and Users collectively as “you”.

What data we collect

Own.Assistant collects various categories of personal information that you voluntarily provide to us during your interaction with the Website and the SaaS application, either as a simple User, as a Customer or as a Customer’s End User. The personal information we collect depends on the context of your interactions with us and the Website, the choices you make and your use of the Service. Anonymous or anonymised information does not fall into the category of personal data. In summary, we collect the following data and information that you voluntarily disclose to us:

Registration data: full name, email address and social media account information (e.g. if you sign in through your Google (Gmail) account.

Financial Data: We collect only the data that is absolutely necessary to confirm your payment via Stripe.

Billing information: Postal billing address and VAT number (Tax ID or SSN for U.S. taxpayers).

Electronic identifiers: operating system, browser name and version and/or IP addresses.

Customers’ End-User Interaction Data with the Service: questions and answers, as well as any voluntarily provided information in the free text area of the virtual assistant - application, authentication data, security questions, any public social media posts, user ID, click flow data and other data collected through cookies and similar technologies. Please read Own.Assistant’s Cookie Policy for more information.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Own.Assistant. Unless specified otherwise, all Data requested by Own.Assistant is mandatory and failure to provide this Data may make it impossible for Own.Assistant to provide its services. In cases where Own.Assistant specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools — by Own.Assistant or by the owners of third-party services used by Own.Assistant serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy. Users are responsible for any third-party Personal Data obtained, published or shared through Own.Assistant.

Mode and place of processing the Data

Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Own.Assistant (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Cookie Policy

Own.Assistant uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent. Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Additional information about Data collection and processing

Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Own.Assistant or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Own.Assistant may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance
For operation and maintenance purposes, Own.Assistant and any third-party services may collect files that record interaction with Own.Assistant (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Own.Assistant and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Minors data

We never collect personal data directly and deliberately about a natural person under the age of majority and unable to provide valid consent according to local requirements. If you notice that a minor has disclosed personal information to us without the consent of their parents and guardians, please let us know and we will act accordingly.

The age threshold of minors’ legal capacity ranges from 13 to 16 years old and varies from country to country. The Company does not intend to directly collect and process child data under the legal age of consent, as defined by the jurisdiction of the country in which the Data Subject is located. If you notice that minors’ data is disclosed through the Service without the consent and without the knowledge of their parents and guardians, please inform us immediately in order to close the account and take the appropriate protection measures.

Who has access to your data

Access to your data has Company’s authorized personnel and its partners, providing appropriate contractual guarantees. In certain cases, and to the extent necessary, we use third-party services, such as in payments, file storage and analytics. All these services comply with policies such as ours.

The Company carries out most of the data processing activities required to provide the Service on its own resources and personnel. However, where appropriate and according to the needs that arise, we work with third party service providers for the proper function and support of the Service, including our suppliers in the following areas:

  • Stripe ‘s secure online payment processing services.
  • Google cloud storage services.
  • Customer support tools.
  • Product development tools.
  • IT and security service providers.
  • Google and Facebook marketing or analytics tools.

Each service provider shall be controlled and bound by contractual obligations equivalent to or more stringent than this Policy.

International transfers

It is not our intention to transfer data to non-EU/EEA third countries per se. However, due to the location or multinational nature of certain technology service providers , your data may be transferred to non-EU/EEA third countries. In such case, our established policy is to use the European Commission’s Standard Contractual Clauses and other approved data transfer mechanisms to better protect your personal data in non-EU/EEA jurisdictions.

The Company uses approved data transfer mechanisms to transfer your personal data to and from the United States and other jurisdictions outside the EU/EEA. Primarily, we rely on Standard Contractual Clauses approved by the European Commission as a legal mechanism, where necessary, for any non-EU/EEA data transfers, to the extent that such transfers are made.

We recognise that the Court of Justice of the European Union ruled in July 2020 (Schrems II) that certification under the EU-US Privacy Shield can no longer serve as an exclusive basis for guaranteeing an adequate and equal level of protection of personal data and equal to the EU level. In this context, where necessary, the Company shall make every effort to the extent possible to ensure further guarantees as to the level of protection of personal data by non-EU/EEA providers and in particular in the United States, by adopting the respective Standard Contractual Clauses approved by the European Commission.

For more information on the European Commission’s Standard Contractual Clauses, please address to https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en For more information about the U.S. Privacy Shield program, please visit https://www.privacyshield.gov/. In case of conflict between the terms of the non-EU/EEA Providers Policy and this Policy, this Policy shall prevail.

Time to keep your data

We store and keep your data for as long as the contract between us stands or for as long as is necessary to fulfill the purpose for which your data was collected or for as long as the law requires on a case-by-case basis.

Subjects’ personal data is stored only for the period of time required to fulfill the purposes for which the data was originally collected. Furthermore, the Company retains your data as long as necessary to comply with requirements of the law, including any legal, accounting or other obligations in order to resolve any disputes arising from its activities. Although retention requirements may be different in each case, we apply some standard retention periods for part of your personal data, as described below:

  • Contact information collected for marketing purposes, such as name and email address, is kept on an ongoing basis until you request to opt-out or withdraw any prior consent.
  • Browser interaction data, such as data from cookies and related tracking technologies, is retained for the periods provided for in the Company’s applicable Cookie Policy or until the withdrawal of any prior consent.
  • Data provided during the use or in the framework of the Service shall be kept for a period of five (5) years from the date of the last interaction of the Subject or the termination of the contract between us accordingly, unless otherwise specified by law.

Security

The security of your personal data is a priority for us and therefore we ensure that all the appropriate contractual, technical and organisational measures are implemented.

We are committed to protecting the physical and digital security of subjects’ personal data by implementing appropriate contractual, technical, and organisational measures. Indicatively, such measures are the following:

  • Internal Policies and Procedures for the protection of personal data
  • Confidentiality and privacy clauses in contracts with our service providers and business partners
  • Event management and disaster recovery plan
  • Data recovery plan
  • Keeping backups
  • Authorized access to files and databases (Authentication and identification)
  • Classified access depending on the role of each user
  • Maintenance and regular upgrade of hardware and software and their security control
  • Periodic system and infrastructure security screening
  • Keeping backup copies
  • Encryption and pseudonymisation (if applicable)
  • Raising awareness and training of personnel on privacy and information security issues

Your rights

The Company ensures the exercise of your rights as stipulated in the Articles 15-22 GDPR, such as the right of access and the right to be informed, the right to erasure, etc., upon request at support@own.solutions.

Our Company is committed to the protection and respect of your rights as defined by Articles 15-22 of the GDPR and in particular:

  • Your right to be informed about the processing of your personal information (right of access) and to request more information about the processing that is being performed
  • Your right to rectification of inaccurate personal data
  • The right to erasure of the personal information you have provided unless this is not permitted for legitimate reasons
  • Your right to restriction of processing
  • Your right to data portability, if possible.
  • Your right to object to further processing of your data
  • Your right to withdraw any prior consent.

In such cases, the Company will evaluate and respond accordingly to your request within one (1) month of the receipt of your request and your identification. In case your request is complex or there is a large number of requests, our Company will inform you within the above period of one month of a time period extension of up to two (2) additional months, in compliance with the GDPR. Moreover, our Company may refuse to grant your request in whole or in part, only when this is possible in compliance with the GDPR or national law.

Furthermore, in the event of the exercise of one or more of the above mentioned rights to rectification, erasure and restriction of your data, your requests may also be shared with any third party to whom your data may have been transferred in pursuit of the above mentioned processing purposes.

For the exercise of these rights, you can send us an online request at support email. If the reply you receive from us does not satisfy you or if your personal data is deemed to still be infringed, then you have the right to contact the national Data Protection Authority (www.dpa.gr submission of a complaint) or to any other competent supervisory authority concerning you (you can find more information here).

Restrictions on your rights

Your rights to your personal information are not unlimited and may be rejected in accordance with the stated circumstances.

In certain circumstances, the Company may refuse to respond to certain rights or requests in connection with your personal data, when:

  • Refusal of access is required or permitted by law,
  • The provision of access would have a negative impact on the rights and freedom of third natural persons, or
  • Where the request is manifestly unfounded or excessive.

Changes to this Policy

We update the Privacy Policy when necessary to better inform you or when we need to comply with new legislation.

From time to time and according to our needs, we may update this Policy to better inform you. The updated version of this Policy will be posted on the Website indicating the effective date of the latest version, which is the date of its posting on the Website and of your free access to it. If we make significant changes to this Policy, we may notify you either by posting a specific notice of these changes on the Website or by sending you a notice directly by e-mail to the address you have provided to us. In any case, we encourage you to frequently review this Policy for your reliable and timely information on how we process and protect your personal data.

Definitions and legal references

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through Own.Assistant (or third-party services employed in Own.Assistant), which can include: the IP addresses or domain names of the computers utilized by the Users who use Own.Assistant, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User
The individual using Own.Assistant who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Own.Assistant. The Data Controller, unless otherwise specified, is the Owner of Own.Assistant.

Own.Assistant (or this Application)
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by Own.Assistant as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Legal information
This privacy policy relates solely to Own.Assistant, if not stated otherwise within this document.

Contact us

For more information about the protection of your personal data and the Privacy Policy of our Company, as well as the exercise of your rights, you can contact us at the following information:

Own.Solutions AC Ltd

Marina Village, Malahide, Co. Dublin K36 N702, Ireland

Email: support@own.solutions