Updated: December 2021

GENERAL

OwnID Inc. (“we”, “us”, “our”, “Company” or “OwnID”), is committed to protecting the privacy of our services' endusers, business partners and our website's visitors, all as further detailed below. We take several precautions and have implemented certain mechanisms to ensure the protection of Personal Data (as defined below), as well as to comply with applicable privacy and data protection laws.

This Privacy Policy (“Privacy Policy”) is an integral part of our Terms of Use and governs the collection, processing, usage and transfer of data by us from: (i)individuals who access and use our website: https://www.ownid.com (respectively,“Visitor(s)” and “Website”); (ii) end-users who use our OwnID password-less widget embedded within our business partners’ websites, apps, or other digital assets (“Partner's Digital Assets”) (respectively, “End-User”and “Widget”); and (iii) our business partners who has been registered to our services through our Website, including any individual on their behalf (“Partner”). All of the above shall be referred to as “you” or “User(s)”.

This Privacy Policy explains how you can exercise your rights related to yourPersonal Data, in accordance with the laws and regulations applicable to you (which may include for example the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”). In the event you are a California resident and the CCPA applies to you – please make sure to review our CCPA Privacy Notice to learn more about our privacy practices with respect to the CCPA. If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, please send us an email to: support@ownid.com.

THE HIGHLIGHTS

·  As an essential part of our business, we offer our Partners to facilitate the registration and login process on their Digital Assets, by enabling End-Users to proceed with registration or log-in, quickly without providing any credentials, by using the OwnID Widget embedded in the applicable Digital Assets. In this framework, we do not process Personal Data related to End-Users. We solely use End-User’s device verifications method (e.g., Face ID) for authentication purposes. This information is not stored or processed by us. The entire verification and authentication process happens within End-User’s device. For the purpose of this Privacy Policy, the Widget and any associated services provided to our Partners shall be collectively referred to as the “Services”.

·  Children under the age of 16 (or equivalent minimum age for providing consent) are not permitted to use the Services without parental or legal guardian consent. In any event, we do not knowingly collect children's Personal Data.

·  You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.

·  You may not share Personal Data about other people with us who you are not authorized to share or use.

·  You may be entitled to request to review, amend, erase restrict and opt-out from the processing of your Personal Data, in accordance with applicable law. For more information regarding your rights please refer to our Privacy Rights Policy.

·  We share Personal Data with third parties in connection with the provision of the Services, or other limited circumstances as specified here in.

WHAT IS PERSONAL DATA?

"Personal Data" is any information which identifies or can be reasonably used to identify a natural person. Such data includes for example:first and last name, phone number, email address, unique online identifiers, billing information, credit card details, etc.

As opposed to Personal Data, "Non-Personal Data", or anonymized data, is information which does not identify a specific natural person and cannot reasonably be used for such identification. This type of information includes for example aggregate or statistical data or otherwise, technical information transmitted from your device such as type of browser and operating system, language preference, referring and exit pages and URLs, time and datestamp, amount of time spent on particular page.

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HOW WE COLLECT INFORMATION

Depending on the nature of your interaction with us, we may collect information from you in one or both of the following ways:

· Automatically – we may use cookies (as further elaborated below) or other similar tracking technologies to gather some information automatically when you interact with our website and Service.

· Provided by you voluntarily –we will collect information if and when you choose to provide us with the information, such as through the Service, when you contact us or sign up for our newsletter.

YOUR RIGHTS RELATED TO YOUR PERSONAL DATA  

Depending on your jurisdiction, data protection and privacy laws provide you with the ability to exercise certain rights regarding your Personal Data that we process.The principal rights includes the right to access your Personal Data; the right to ensure your Personal Data is accurate, complete and up to date; the right to have your Personal Data amended or otherwise deleted; the right to object to the processing of your Personal Data; the right to send or “port” your Personal Data; the right to file a complaint with a supervisory authority in your jurisdiction; and the right to withdraw consent, subject to legal or contractual restrictions and reasonable notice;

Please review our Privacy Rights Policy for more information regarding the rights you may have under the relevant data protection and privacy laws in your jurisdiction.

If you wish to exercise any or all of the above rights, please fill out the Data Subject Request Form (“DSR”) available here, and send it to us at: support@ownid.com.

If we are unable to provide you with the information that you asked for, we will endeavour to explain the reasoning for this and inform you of your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law.

WITH WHICH THIRD PARTIES DO WE SHARE PERSONAL DATA?

We do not share any Personal Data collected from you with third parties except in the following events:

- Compelled Disclosures - We may share Personal Data with third parties where required to comply with a legal requirement, for the administration of justice, to protect the vital interests of data subject or the vital interests of others, to protect the security or integrity of our databases and services, and to take precautions against legal liability.

- Enforcement of our Rights- To enforce this Privacy Policy and the terms of our agreements (including theTerms of Use), including the investigation of potential violations thereof.

- Change of Control- In the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale, etc.), we may share Personal Data with our affiliated companies or acquiring company, which will assume the rights and obligations as described in this Privacy Policy.

- Security Detections - To detect, prevent, or otherwise address fraud, security or technical issues.

- Affiliated Companies - With our parent company, any subsidiaries, joint ventures, or other companies under common control with the Company solely if and when applicable or necessary for the purposes described in this Privacy Policy, orin the event of any of the corporate transactions listed herein;

- Service Providers - To collect, hold or manage your Personal Data through our authorized third-party service providers and to perform certain requested services on our behalf, as reasonable for our business purposes, all of whom we contractually ensure comply with applicable data protection laws. Some examples of service providers that we may use include (without limitation): payment processors, server and storage providers and marketing partners.

- Explicit Consent - If you provide us with your explicit approval to share your information prior to the disclosure.

COOKIES & TRACKING TECHNOLOGIES

We may use cookies and other similar tracking technologies or method sof web and mobile analysis to gather, store, and track certain information related to your access of, activity and interaction with our Website.  

A “cookie” is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Service quicker, easier and smoother. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). You can find out more information about cookies at www.allaboutcookies.org.

The third-party cookies used on our Website are as follows: