Privacy Policy

Owl Investor Inc. ("us", "we" or "Company") respects the privacy of our users (each, "you" or "User") and are committed to protecting the privacy of Users who access, visit, use or engage with our website or any other online services we provide (collectively: the "Services").

The Company has prepared this Privacy Policy to outline our practices for collecting, using, and disclosing your information when you use the Services.

We encourage you to read this Privacy Policy carefully and use it to make informed decisions. By using the Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to the Privacy Policy.

The Privacy Policy is a part of the Terms of Use and is incorporated therein by reference.

In this Privacy Policy you will read about, among other things:

  • What type of information we collect

  • Cookies and Google Analytics

  • How we use the information

  • With whom we share the information and for what purpose

  • For how long we retain the information

  • How we protect your information

  • How to contact us

What Type of Information We Collect

 

To provide our Services, and facilitate exchanges between users of the Services, we obtain personal information directly from you and obtain information about you indirectly through electronic communications and third parties.

User Supplied Information: Depending on the Services you seek to access we may require that you provide us with some or all of the following types of personal information:

  • Name

  • Phone Number

  • Financial Information

  • Payment Information

  • Address

  • Employment

  • Investment Experience

  • Email

  • SSN (or equivalent)

  • Date of Birth

  • Citizenship

  • Investment Suitability Information

Our membership registration process, surveys, and questionnaires may request that you provide other information that you may, at your option, choose to provide or withhold. Any such information provided will be subject to this policy.

Verification Information: If required to help us verify your identity, you may provide us a copy of your driver’s license, passport, or other government-issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease, or other proof of residence. You may also provide us with other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money laundering, US Treasury department rules or regulations, or other legal requirements. 

Automatically or Passively Collected Information: In addition to the information you directly provide, we automatically or passively collect information when you access or use our services, we may collect your IP address, device identifiers, click path, use of our Website, and other electronic data. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users to understand how our Website is being used, and for security and monitoring purposes. To determine whether your computer is supported by our system, we may collect additional technical information, including your operating system and browser, as well as the presence of any software that our Website may require to operate with your computer, or other third-party software on your computer.

A “cookie” is a small amount of data, often including an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website. You may set your browser so that it does not accept cookies. Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our Services. By using the Website, you consent to this use.

We may also use so-called "pixel tags" – small graphic images (also known as "web beacons" or "single-pixel GIFS") – to tell us what parts of our website have been visited or to measure the effectiveness of searches customers perform on our Site. Pixel tags also enable us to send email messages in a format customer can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our users. You can "opt-out" of receiving these types of communications from us by following the directions provided elsewhere in this policy.

Some web browsers transmit “do-not-track” signals to websites. At this time, our Services are not designed to respond to these signals or similar mechanisms from browsers.

We may send email messages that use a “click-through URL” linked to content on our Website. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply do not click text or graphic links in the email, or notify us at support@owlinvestor.com.

Information Related to Your use of the Services: We collect certain information about you when you visit the Website and interact with any of our Services. We collect information about when you use Services, the pages within the Website you visit, the links you click on, the type, size, and names of files you upload or download, and the search terms you use. If you invite others to use the Website, we retain information about your referral.

We collect information in connection with the transactions you enter into using our Services. Transaction data includes, without limitation, the terms on which you purchase or sell securities and information relating to price, size, volume, class of securities, offers, acceptances, transfer restrictions, and any derivative data related thereto.

Third-Party Information: We collect information about you from third-party sources with which we maintain various commercial relationships. We may utilize a third-party identity verification service provider to help us confirm your identity, prevent fraud, money laundering, and other illegal activity, and to satisfy legal requirements relating to the Services. We may also receive information about you and your activities from third-party service providers, such as Google, LinkedIn, and other advertising, social media, and market research partners who provide us with information about you, and/or your engagement with and interest in our Services. We may also receive information about you from our third-party marketing partners, under referral programs, partnership agreements, and/or under joint marketing arrangements.

How We Use Information We Collect

We may use your information for the following commercial purposes.

  • Administer, operate, facilitate and manage your relationship with Owl Investor and deliver the Services. 

  • Facilitate our business operations, including fulfilling our legal and regulatory requirements such as identity verification, validation, anti-money laundering, and “Know Your Customer” protocols.

  • Determining your eligibility to invest.

  • To enable you to make and receive payments and execute transactions.

  • To satisfy our record keeping and transfer agency obligations under applicable laws, rules, and regulations.

  • To communicate with you about the Services and target our marketing, advertising, and sales efforts to enhance your user experience and increase engagement. These communications may alert you to new Services, offerings, features, content, and promotional events.

  • Provide you with information about our current Services, including onboarding materials, the availability of new investment opportunities, reminders, information about your previous investments.

  • To verify your identity, accounts, and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies. We also use your information to debug, identify, and correct errors;

  • On a de-identified, aggregated basis, for research and development activities, including to analyze how you use the Services to help us understand usage patterns and know if there are problems with the Services or areas ripe for improvement;

  • Contact you or, if applicable, your designated representative(s) by post, telephone, text message, electronic mail, facsimile, etc., in connection with your relationship with Owl Investor, including with information and updates about our Services.

In addition, if we are involved in a merger, acquisition, financing due diligence, reorganization, or other corporate transaction affecting Owl Investor, your information may be shared, transferred, or sold under a duty of confidentiality as part of a transaction as permitted by law or by contract. By using the Services, you consent to receive calls and messages, including auto-dialed and prerecorded message calls, and SMS messages (including text messages) from us, at any telephone numbers that you have provided or may provide in the future (including any cellular telephone numbers). Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You can "opt-out" of receiving these types of communications from us by following the directions provided elsewhere in this policy. If your relationship with Owl Investor ends, we will continue to treat your personal information, to the extent we retain it, as described in this policy.

How We Share Information We Collect

We do not share personal data with third parties for their direct marketing or similar purposes without your consent. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or Services in exchange for your data.

How partners, service providers, and others with whom we share and/or disclose your information is governed by the policies of such parties, and we shall have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in this case, we will only share information that is directly related to the applicable service(s). This may include the incorporation of your personal information into databases maintained to validate information for identity verification, including verification for anti-money laundering and “Know Your Customer” protocols.

The primary situations in which we share your data are as follows:

Service Providers: To operate the Services we share information about you as needed with our service providers, including financial institutions, broker-dealer(s), accountants, auditors, lawyers, payment processors, information technology consultants, advisors, and our affiliates. We only share information to the extent it is required to fulfill our obligations to you, and to regulators, and to operate the Website and the Services.

Potential Business Combination: We may also transfer your personal information to a third party as a result of a business combination, merger, or similar transaction or to governmental authorities when we reasonably believe it is required by law or appropriate to respond to legal process. We will also share your information with third-party companies, organizations, or individuals if we have a good faith belief that access, use, preservation, or disclosure of your information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims or protect against harm to our legal rights or safety. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes to the processing of your Personal Information, give you an opportunity to consent to such changes. Any third party with whom we share your data will be required to provide the same or equal protection of such data as stated in our policy.

Regulators: We may share information about you with the U.S., state, or international regulators or FINRA where we believe doing so is required or appropriate to comply with any laws, regulations, or other legal processes or law enforcement requests, such as court orders or subpoenas.

Third-Party Sites: The Website may contain links to third-party websites and may redirect you to third-party websites. These sites include, among others, service providers who have a relationship with Owl Investor. Third-party websites are not under our control, and we are not responsible for any third-party websites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes, or updates. The inclusion or access to these websites does not imply an endorsement by Owl Investor, or of the provider of such content or services, or any third party website. Please be aware that when you enter a third-party website, any information you provide, including financial information, is subject to the terms of use and privacy policy of that website.

How We Safeguard Your Personal Information

Security Systems and Processes: We have put in place security systems designed to prevent unauthorized access to or disclosure of Personally Identifiable Information, and we take all reasonable steps to secure and safeguard this Information, including:

  • We use industry-standard encryption technology for any information we store;

  • Where applicable, companies that we do business with agree to abide by this policy and apply similar safeguards to Personal Information; and

  • We provide access to our databases containing Personal Information on a need-to-know basis only.

Our security systems are therefore structured to deter and prevent hackers and others from accessing the information you provide to us. Please understand, though, that this information should not be construed as a warranty that our security systems are fail-proof. Due to the nature of Internet communications and evolving technologies, we cannot provide and we also disclaim assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

Other Important Privacy Information

Opting Out of Communications: If you wish to stop receiving marketing or promotional communications or to opt-out of the use of your information for the purposes described in this policy, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can also contact us at support@owlinvestor.com to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy. Please understand that you will not be allowed to opt-out of certain communications required to comply with applicable laws, rules, and regulations, or other legal and related notices concerning your relationship to the Website.

Changing or Deleting Information: All users may review, update, correct or delete the Personal Information furnished by a user by contacting us at support@owlinvestor.com to opt-out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy. Please understand that you will not be allowed to opt-out of certain communications required to comply with applicable laws, rules, and regulations, or other legal and related notices concerning your relationship to the Website.

Changing or Deleting Information: All users may review, update, correct or delete the Personal Information furnished by a user by contacting us at support@owlinvestor.com or, in certain cases, by accessing your member account. If you request, we will take reasonable steps to remove your name and other personal information from our databases. Please understand, however, that:

  • it may be impossible to remove this information completely, due to IRS and regulatory reporting requirements, investments on the platform and the rights thereof, and data backups and records of deletions;

  • if you request deletion of your information, you will be unable to use certain features of the Website and any associated Services; and

  • certain Personal Information may remain in our databases following the deletion of your account according to our data retention policy.

Data Retention: We retain the information we collect for as long as you use the Services, or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements and comply with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required according to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Lost or Stolen Information: You must promptly notify us if you become aware that any information provided by or submitted to the Website is lost, stolen, or used without permission.

Children and Teens: Due to federal law (as reflected in the Children's Online Privacy Protection Act), WE DO NOT ALLOW INDIVIDUALS WHO WE KNOW ARE UNDER 18 TO PARTICIPATE IN OUR WEBSITE OR SERVICES. YOU MUST BE AT LEAST 18 YEARS OLD TO USE OUR WEBSITE AND SERVICES. Please understand that we cannot necessarily tell if a user is providing us with his or her true age. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at support@masterworks.io. We will delete such information from our files within a reasonable time.

Changes to this Policy: Each time you visit our Website or use our Services, the current version of this privacy policy will apply. When you use our Website, you should check the date of the last update to the policy (which appears at the top of the policy) and review any changes since the last version. Our business changes frequently and this policy is subject to change from time to time. Unless stated otherwise, our current policy applies to all information that we have about you. We may require you to affirmatively assent to a revised version of this policy as a condition of continuing to use the Website or our Services.

Further Resources: If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the FTC’s website.

We Operate in the United States: Owl Investor is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.

Contact Us:

If you have any questions about this policy, the practices of this Website, or your dealings with this Website, please contact us by e-mail at support@owlinvestor.com.