Privacy Policy
This Privacy Policy was last updated on October 16, 2023.Thank you for visiting White Owl Consulting Group. We at White Owl Consulting Group ("White Owl Consulting Group", "we", "us") respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights regarding your personal data.
This Privacy Policy applies when you use White Owl Consulting Group websites or related services (the "Services").
By using the Services, you agree to the terms of this Privacy Policy. You shouldn't use the Services if you don't agree with this Privacy Policy or any other agreement that governs your use of the Services.
Table of Contents
1. What Information We Collect
2. How We Get Information About You
6. Your Rights Around the Use of Your Data
7. Updates & Contact Information
1. What Information We Collect
We collect certain data from you directly, like information you enter yourself, data about your consumption of content, and data from third-party platforms you connect with White Owl Consulting Group. We also collect some data automatically, like information about your device and what parts of our Services you interact with or spend time using.
1.1 Data You Provide to Us
We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.
When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:
Type of Data | Description |
Account Data | In order to use certain features (like accessing content), you need to create a user account, which requires us to collect and store your email address, password, and account settings. You will also be prompted to submit additional information including your name. Upon account creation, we assign you a unique identifying number. |
Chatbot Document Data | When you use the chatbot (the "BM Chatbot" ), you can upload documents that are used as part of the BM Chatbot document search capabilities. This data is retained for as long as you use the Services. |
Payment Data | If you make purchases or have subscriptions to Services, we collect certain data about your purchase (such as your name, billing address, and ZIP code) as necessary to process your order and which may optionally be saved to process future orders. You must provide certain payment and billing data directly to our payment service providers, including your name, credit card information, billing address, and ZIP code. We may also receive limited information, like the fact that you have a new card and the last four digits of that card, from payment service providers to facilitate payments. For security, White Owl Consulting Group does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data. |
Data About Your Accounts on Other Services | If you access or use our Services through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party. |
Sweepstakes, Promotions, and Surveys | We may invite you to complete a survey or participate in a promotion (like a contest, sweepstakes, or challenge), either through the Services or a third-party platform. If you participate, we will collect and store the data you provide as part of participating, such as your name, email address, postal address, date of birth, or phone number. That data is subject to this Privacy Policy unless otherwise stated in the official rules of the promotion or in another privacy policy. The data collected will be used to administer the promotion or survey, including for notifying winners and distributing rewards. To receive a reward, you may be required to allow us to post some of your information publicly (like on a winner’s page). Where we use a third-party platform to administer a survey or promotion, the third party’s privacy policy will apply. |
Communications and Support | If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, messages, location, White Owl Consulting Group user ID, refund transaction IDs, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy. |
The data listed above is stored by us and associated with your account.
1.2 Data We Collect through Automated Means
When you access the Services (including browsing content), we collect certain data by automated means, including:
Type of Data | Description |
System Data | Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types |
Usage Data | Usage statistics about your interactions with the Services, including content accessed, time spent on pages or the Service, pages visited, features used, your search queries, click data, date and time, referrer, and other data regarding your use of the Services. |
Approximate Geographic Data | An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on your IP address. |
2. How We Get Information About You
We use tools like cookies, web beacons, and similar tracking technologies to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.
2.1 Cookies and Data Collection Tools
We use cookies, which are small text files stored by your browser, to collect, store, and share data about your activities across websites, including on White Owl Consulting Group. They allow us to remember things about your visits to White Owl Consulting Group, like your preferred language, and to make the site easier to use. To learn more about cookies, visit https://cookiepedia.co.uk/all-about-cookies. We may also use clear pixels in emails to track deliverability and open rates.
White Owl Consulting Group and service providers acting on our behalf (like Google, Google Analytics, third-party vendors, and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools“) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.
2.2 Why We Use Data Collection Tools
White Owl Consulting Group uses the following types of Data Collection Tools for the purposes described:
- Strictly Necessary: These Data Collection Tools enable you to access the site, provide basic functionality (like logging in or accessing content), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are required for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.
- Functional: These Data Collection Tools remember data about your browser and your preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the Services (like your preferred language or volume level for video playback).
- Performance: These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from. These tools can help us test different versions of White Owl Consulting Group to see which features or content users prefer and determine which email messages are opened.
- Advertising: These Data Collection Tools are used to deliver relevant ads (on the site and/or other sites across the internet) based on things we know about you like your Usage and System Data (as detailed in Section 1), and things that the ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and content that you share publicly on the Services.
- Social Media: These Data Collection Tools enable social media functionality. These cookies may track a user or device across other sites and build a profile of user interests for targeted advertising purposes.
You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional. To learn more about managing Data Collection Tools, refer to Section 6.1 (Your Choices About the Use of Your Data) below.
3. Data Uses
We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity. We retain your data for as long as it is needed to serve the purposes for which it was collected.
We use the data we collect through your use of the Services to:
- Provide and administer the Services, including displaying customized content (Account Data; Chatbot Document Data; System Data; Usage Data; Approximate Geographic Data);
- Process payments to other third parties (Payment Data);
- Process your requests and orders for content, products, specific services, information, or features (Account Data; Chatbot Document Data; Payment Data; System Data; Communications and Support);
- Communicate with you about your account by (Account Data; Chatbot Document Data; Sweepstakes, Promotions, and Surveys; System Data; Communications and Support);
- Responding to your questions and concerns;
- Sending you administrative messages and information; notifications about changes to our Service; and updates to our agreements;
- Sending you information, such as by email or text messages, about rewards programs, new services, new features, promotions, newsletters, and other available content (which you can opt out of at any time);
- Manage your account and account preferences and personalize your experience (Account Data; Chatbot Document Data; Payment Data; System Data, Usage Data, Cookie Data);
- Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse (Account Data; Payment Data; Communications and Support; System Data; Approximate Geographic Location);
- Solicit feedback from users (Account Data; Communications and Support);
- Solicit testimonials from users (Account Data; Communications and Support);
- Market products, services, surveys, and promotions (Account Data; Chatbot Document Data; Sweepstakes, Promotions, and Surveys; Usage Data; Cookie Data);
- Market Subscription Plans to prospective customers (Account Data; Chatbot Document Data; Cookie Data);
- Learn more about you by linking your data with additional data through third-party data providers and/or analyzing the data with the help of analytics service providers (Account Data; Data About Your Accounts on Other Services; Usage Data; Cookie Data);
- Identify unique users across devices (Account Data; System Data; Cookie Data);
- Tailor advertisements across devices (Cookie Data);
- Improve our Services and develop new products, services, and features (all data categories);
- Analyze trends and traffic, track purchases, and track usage data (Account Data; Chatbot Document Data; Communications and Support; System Data; Usage Data; Approximate Geographic Data; Cookie Data);
- Advertise the Services on third-party websites and applications (Account Data; Cookie Data);
- As required or permitted by law (all data categories); or
- As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services (all data categories).
4. Who Receives Your Data
We share certain data about you with companies performing services for us, White Owl Consulting Group affiliates, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.
We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:
- With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service. (All data categories)
- With Business Partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to White Owl Consulting Group. Depending on your location, we may share your data with these trusted partners. (Account Data; Learning Data; Communications and Support; System Data)
- With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics, we share certain contact information or de-identified data. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner. (Account Data; System Data; Usage Data; Cookie Data)
- To Power Social Media Features: The social media features in the Services may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy. (System Data; Usage Data; Cookie Data)
- To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey. (Account Data; Sweepstakes, Promotions, and Surveys)
- For Advertising: If we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1), to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and to undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks’ behavioral advertising, see Section 6.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads. (System Data)
- For Security and Legal Compliance: We may disclose your data (all data categories) to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
- Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
- Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of White Owl Consulting Group, our users, employees, members of the public, or our Services;
- We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy; or
- Required or permitted by law.
- During a Change in Control: If White Owl Consulting Group undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence). (All data categories)
- After Aggregation/De-identification: We may disclose or use aggregated or de-identified data for any purpose.
- With Your Permission: With your consent, we may share data to third parties outside the scope of this Privacy Policy. (All data categories)
5. Security
We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it's important to protect your password and to contact us if you suspect any unauthorized access to your account.
White Owl Consulting Group takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data.
Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and White Owl Consulting Group, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and email ralph.brooks@whiteowlconsultinggroup.com with any concerns.
6. Your Rights Around the Use of Your Data
You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain third parties. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data. Parents who believe we've unintentionally collected personal data about their underage child should contact us for help deleting that information.
6.1 Your Choices About the Use of Your Data
You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.
- If you no longer want to hear from us, you can opt out by sending us an email at ralph.brooks@whiteowlconsultinggroup.com. Regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
- The browser or device you use may allow you to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control whether location or other data is collected and shared.
- To get additional information on how you can opt out of Google’s use of device identifiers, see the Google Support Page that discusses how to control the use of these identifiers through device settings.
- To get information and control cookies used for tailored advertising from participating companies, see the consumer opt-out pages for the Network Advertising Initiative and Digital Advertising Alliance, or if you're located in the European Economic Area, visit the Your Online Choices site. If you’re located in Japan, visit the Digital Advertising Consortium. To opt out of Google's display advertising or customize Google Display Network ads, visit the Google Ads Settings page. To opt out of Google Marketing Platform's use of cookies, visit the Google Marketing Platform opt-out page.
If you have any questions regarding this section, contact us at ralph.brooks@whiteowlconsultinggroup.com
6.2 Accessing, Changing, and Deleting Your Personal Data
You can access and update your personal data that White Owl Consulting Group collects by doing the following:
- To change data you provide directly, just log into your account and make your changes.
- To delete your account:
6.3 Our Privacy Policy Concerning Minors
The Services that are provided are only for people who are 18 years of age or older.
7. Updates & Contact Information
7.1 Modifications to This Privacy Policy
Occasionally, we may change this Privacy Policy. When we make a major change to this policy, we'll notify you via email. Changes will take effect from the date they are posted. Contact us via email with any questions.
As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.
7.2 Capitalized Terms
Any capitalized terms not defined in this policy are defined as specified in White Owl Consulting Group's Terms of Use.
8. Additional Advertising and Remarketing Information
We utilize third-party vendors, including Google, to show ads on sites across the internet.
In addition, we use Google AdWords Remarketing to advertise White Owl Consulting Group across the Internet. AdWords remarketing will display relevant ads tailored to you based on what parts of the White Owl Consulting Group website you have viewed by placing a cookie on your machine. THIS COOKIE DOES NOT IN ANYWAY IDENTIFY YOU OR GIVE ACCESS TO YOUR COMPUTER The cookie is used to say "This person visited this page, so show them ads relating to that page." Google AdWords Remarketing allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you.
If you do not wish to participate in our Google AdWords Remarketing or if you wish to opt-out of the Google Marketing Platform's use of cookies, you can opt out by visiting the Google Marketing Platform opt-out page .
9. Questions
If you have any questions or concerns regarding this Privacy Policy, email us at ralph.brooks@whiteowlconsultinggroup.com .