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PRIVACY POLICY

Updated as of: April 15, 2024

Owners Platform, Inc. and its affiliates (collectively"Owners”, “Company”, " "we," "our,"or "us") value privacy. In this Privacy Policy ("Policy"),we describe the information we collect, how we use it, and when and with whom we share it when you visit our sites, mobile applications, and other online services (collectively, “Websites” or "Platform") to take advantage of the services provided therein (our “Services”). Except as otherwise explicitly provided herein, this Policy applies only to information collected on or through the Platform, and it does not apply to information collected or obtained by or through any other means (including, without limitation, information collected offline, in person, over the telephone and/or by mail, or from third-parties outside the Platform). By accessing or using the Platform, you agree to this Policy. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE THE PLATFORM. This Policy may be supplemented by additional privacy statements, terms or notices provided to you.

PERSONAL DATA. Personal Data” is any information that is personal in nature and that may be used to identify, relate to, describe, or is capable of being associated with, or could reasonably be linked, directly or indirectly to an individual orbusiness. You may provide Personal Data to us when you send us an e-mail message or a request for information, when you fill out a questionnaire or customer satisfaction survey, etc.  We collect Personal Data to provide the Websites to the best of our ability. It is our intent to inform you before we collect Personal Data, such as your name and/or address on the internet. The term Personal Data shall also include information as described by any applicable privacy laws, including the CCPA, the GDPR or UK Privacy law. We don’t share your Personal Data with anyone except to comply with the law, develop our products, or protect our rights. We don’t store Personal Data on our servers unless required for the on-going operation and delivery of our Services to you. We store Personal Data only for as long as we have areason to keep it.

DATA COLLECTION: Our collection of Personal Data includes but is notlimited to the following: 

●  Usage Data: We may collect data aboutyour use of our Services such as the values of your searches, previous purchases, etc. to improve your experience and our Services.

●  Automatically Collected Data: We collect some data automatically when you interact with us, visit our Websites, or use our Services. We may receive and store information such as an IP address, device ID, and your activities on our website. We may store this information, or it may be stored in databases owned and maintained by affiliates, agents, orservice providers. We may use this data or combine it with other data to track the number of users and referral sources for customers and purchase of our products.

●  Data from other Services: You may give us permission to collect your information through other services. For example,you may interact with us through our blog or one of our social media accounts such as Facebook or LinkedIn. When you do this, you may share certain information available through those accounts.

●  Cookies: Cookies are pieces of data that websites and services set on your browser or device to improve your user experience on future visits and speed upfunctionality. We use cookies and similar technologies to track your computer’s settings such as the account you have logged in with and notification settings. We may expand the use of cookies and saved data as we add new features to our Websites or our Services. We use technologies such as web beacons and single-pixel GIFS to track and log data for marketing purposes like open rates.

●  Analytics: We also may use third-party analytic tools like Google Analytics that employ cookies to collect information about your use of our Services. You can disable cookies at any time by changing your browser or device settings. Further information about how to disable cookies check your Internet browser provider’s website via your help screen.

●  Advertisements: We may advertise our Services on other websites and social media sites. After clicking on one of these advertisements you become a user of our Services. Various advertising platforms such as Facebook may collect information for optimizing advertising campaigns outside of our website. If you do not want to receive personalized ads from third parties, you should exercise opt-out rights directly with those third-parties. You can also opt-out through the NetworkAdvertising Initiative (NAI) and Digital Advertising Alliance (DAA). Since there is no established industry compliance standard for “Do Not Track” (“DNT”) we do not respond to DNT signals in our Services and operate as explained in this Privacy Policy.

●  Payment and Subscription Data: We do not directly collect, retain, or use your payment information. We use the third-party payment processor, Stripe. They may collect Personal Data, so you should check their respective privacy policy. 

DATA RETENTION. We take all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of Personal Data. We collect Personal Data only insofar as is necessary or appropriate to fulfill the purpose of a user’s interaction with us. We do not disclose Personal Data other than as described below. And you can always refuse to supply Personal Data, with the caveat that it may prevent them from engaging in certain website-related activities. We collect Personal Data for a number of reasons, including:

●  to meet our contractual obligations to you or respond to your requests inanticipation of entering a contract for purchasing our Services;

●  providing you with a safe and enjoyable user experience; customer service; marketing,such as email announcing new features of our Services; protecting you, our users, and our personnel and property;

●  analyzing and improving our Services by collecting data about how you use our Services sowe may improve design and features; manage and respond to legal issues;

●  if required to use or disclose Personal Data to comply with legal, regulatory or government requirements; and other reasons as deemed necessary.

We may handle your data based on your implied or express consent to do so. Where legally permitted or required we handle Personal Data based on your implied or express consent. When we dispose of Personal Data we may delete, anonymize, or use other appropriate methods. Based on reasonable business practices and system and data security purposes, Personal Data may continue to exist in system back-up files for additional time. 

DISCLOSURE OF YOUR PERSONAL DATA. We do not sell your Personal Data because we consider it a vital part of your relationship with us. There may arise circumstances when we may share your data with third parties, such as in a business transfer. If we sell or buy a business or assets or corporation, merger, reorganization, bankruptcy, dissolution or similar business event, the related transfer of assets may include your Personal Data.We may disclose Personal Data:

●  Consent: If you provide us with consent to transfer your data.

●   Related Companies: We may share your Personal Data with our related companies, affiliates, consistent with this Privacy Policy.

●  Developers: If we utilize contracted developers for our Website or Services, they may have access to user data as part of their services. We would require any developers to limit use of Personal Data only to what necessary to provide their services to us.

●  Related Third Parties: In the event we hire agents, consultants or other companies or individuals to perform services for us. For example, use of a third-party payment processor for purchases.

●  Legal Compliance: We may disclose your Personal Data if required by law or we believe in good faith we are required to for compliance with a legal obligation, to protect our rights, property, and intellectual property, defend against legal liability, or protect Subscriber’s’ or other’s personal safety.

●  Aggregated Data: We may share non-personally identifiable data (“Aggregated Data”) with third-parties for our business purposes.

We will not rent or sell Personal Data to anyone. Other than to our employees, contractors and affiliated organizations, as described above, we disclose Personal Data, only when required to do so by law,or when we believe in good faith that disclosure is reasonably necessary toprotect the property or rights of the Company, third parties or the public at large.

UNSOLICITED INFORMATION. You may voluntarily provide us with “Unsolicited Information” such as new product ideas or communicate with uswithout our request. By sending any Unsolicited Information you agree that itis non-confidential, and we may share, use, reproduce, disclose, and distributeit without limitation or attribution to you. You acknowledge that you bear soleresponsibility and release us from all liability related to any Personal Datayou willingly provided in any open or public forums to us, other Users or thepublic.

CHILDREN. Our Services are not designed for minors under the age of 18. Only persons 18 years of age or older may use the Platform. If we discover that an individual under 18 has provided us with personal information, we will close the account and delete that individual’s personal information to the extent required by the Children's Online Privacy Protection Act. We may, where permitted by law, retain certain information internally for purposes described in this Policy. If you are a resident of the European Economic Area (“EEA”) which requires consent to processing Personal Data, we will not knowingly process Personal Data for Users under the age ofconsent established by EEA data protection law. If we discover that we processed any Personal Data covered by these laws, we will cease such processing and take prompt reasonable measures to remove it from our records.

LINKS. Our Privacy Policy only applies to our Website and Services. Our Website, blog posts, newsletters, social media posts and emails may contain links to third-party web sites that we do not operate or control. This Privacy Policy does NOT apply to any third-party website. Ourlink to any third-party websites does not imply endorsement or appropriatenessfor use of those sites. Use of any third-party site is solely at your own risk.We recommend you review any third-party sites’ privacy policy prior to use.

SECURITY. We employ physical, procedural, and technological security measures to help protect your personal information fromunauthorized access or disclosure. Owners may use encryption, passwords, andphysical security measures to help protect your personal information against unauthorized access and disclosure. No security measures, however, are 100% failsafe. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or communications will not be collected, disclosed and/or used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, amongother things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. Owners is not responsible for the unauthorized use of your information nor forany lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

YOUR DATA RIGHTS. We treat all users equally regardless of location. You may unsubscribe from emails by clicking the “unsubscribe” link.You may opt out from cookie-related processing as explained in the Cookies explanation under Data We Collect. Depending on your jurisdiction, you may havelegal rights to obtain confirmation of whether we hold your Personal Data, access your Personal Data (including in portable form), and to correct, update, amend or delete your Personal Data. You also may have the right to object to our use or disclosure, request restrictions on processing, or withdraw yourconsent for us to use your Personal Data. These rights do not apply retroactively and may not affect our ability to continue processing data as allowed under those laws.

ACCESSING, CORRECTING OR REMOVING YOUR PERSONAL DATA. To submit a request to access, correct, update, amend or delete your Personal Data, please email us at hi@owners.com and include an explanation of which dataright you are exercising. On receipt of your request, we verify your identity for your protection prior to initiating any action. Once verified, we begin processing your request and respond within thirty (30) days. You also have the right to request us to stop using or limit our use of your Personal Data if you believe we do not have a lawful basis to use it or you believe it is inaccurate. If you are in the EEA, you have the right to opt-out of all Personal Data processing for direct marketing. To do so, please select “unsubscribe” in any marketing email. We may send periodic emails to you. You may opt out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days forus to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us. We may monitor and record our telephone conversations with you for training and quality assurance purposes. You will be provided with a notice at the beginning of any call that is being recorded.

PRIVACY POLICY CHANGES. We may update or modify this Privacy Policy at any time without notice. We post any changes or modifications on thispage. You should review this Privacy Policy before submitting any Personal Data and periodically as you use this website or our Services. Your continued use ofthis website and our Services after any update or modification shall indicateyour knowing consent to the terms of this Privacy Policy in effect on the dateof your use.

DO NOT SELL OR SHARE MYPERSONAL DATA. Owners doesn’t sell your personal information directly to non-Owners users. We may also work with marketing partners who collect personal information directly from you on the Platform through the useof cookies or other tracking technologies. This helps us and our marketingpartners improve your marketing experience and share the most relevant ads with you. If you’re a California resident, you have the right to opt out of both forms of sharing referenced in our Supplemental Privacy Policy, attached here as Exhibit A.  Opting out means you’ll only hear from pros you contact first and we will not share your personal information marketing partners who are not a “service provider”. Please note, however, thatit could be harder for us to find the right pro for you if you opt out. To optout of tailored browser advertising and for more information on how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative's Consumer Opt-Out Link and/or the Digital Advertising Alliance's Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visitthe Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Platform, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may nolonger be effective. Additional information is available on NAI's and DAA's websites, accessible by the above links.

ADDITIONAL INFORMATION FOR UK AND EUROPEAN UNION USERS

Personal Information. References to “Personal Data” in thisPrivacy Policy are equivalent to “personal data” as defined by the European Union General Data Protection Regulation 2016/79 (“GDPR”), and any laws or regulations that amend, supplement, supersede, repeal or replace the GDPR or that are intended to ensure the continued application of the GDPR in the United Kingdom once it ceases to be amember state of the European Union (including the Data Protection Act 2018(collectively, “UK Privacy Law”). We are the processor of your Personal Data for GDPR and UK Privacy Law purposes.

Legal Bases for Processing. We only use your Personal Data as permitted by law. We are required to inform you of the legal bases of ourprocessing of your Personal Data, which are based on one or more of thefollowing:

●  Consent: The consent you provide to us when you share or submit your Personal Data withor to us;

●  Legitimate interest: Our “legitimate interest,” as defined by GDPR and UK Privacy Law, orthe legitimate interest of a third party, including you. For example, we may use your data for fraud and security monitoring to ensure our networks and websites are secure, administer and conduct our business with you, and respondto your requests, inquiries, and complaints.

●  Contract: Our contract performance, directly or indirectly, between us and you.

●  Legal Obligation: Our compliance with a legal obligation that we are or may be subject to.

If you have questions about the legal bases of how weprocess your Personal Data, contact us at hi@owners.com. 

New Use. We may use your Personal Data for reasonsnot described in this Privacy Policy where permitted by law, and the reason iscompatible with the purpose for which we collected it. If we need to use yourPersonal Data for an unrelated purpose, we will notify you and explain theapplicable legal basis.

Your rights. GDPR and UK Privacy Law gives you certain rights regarding your Personal Data. You may ask us to take the following actions concerning your Personal Data that we hold:

●  Opt-out. Stop sending you direct marketing communications. You may continue to receiveservice-related and other non-marketing emails.

●  Access.Provide you with information about our processing of your Personal Data and give you access to your Personal Data.

●  Correct.Update or correct in accuracies in your Personal Data.

●  Delete.Delete your Personal Data.

●  Transfer.Transfer a machine-readable copy of your Personal Data to you or a third party of your choice.

●  Restrict.Restrict the processing of your Personal Data.

●  Object.Object to our reliance on our applicable legal bases (see list of legal bases above) for processing your Personal Data.

You can submit these requests by email to hi@owners.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we reject your request, we will tell you why subject to legal restrictions. If you would like to submit a complaint about our use of your Personal Data or our response to your requests regarding your Personal Data, you may contact as described above or submit a complaint to thedata protection regulator in your jurisdiction. 

Cross-Border Data Transfer. Whenever we transfer your Personal Data out of the European Economic Area (EEA) to countries not deemed by the European Commission to provide an adequate level of Personal Data protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for Personal Data, whererequired by EU data protection legislation:

●  The consent you provide to us when you share or submit your Personal Data with or to us and when you visit our Services;

●  Contracts approved by the European Commission; or

●  Other valid and applicable safeguards under GDPR and UK Privacy Law.

Please get in touch with us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.

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Exhibit A

U.S.Supplemental Privacy Policy

This United States Supplemental Privacy Notice (“Supplemental Notice”) applies only to information collected about consumers in the following states: (1) California, (2) Colorado, (3) Connecticut, (4) Nevada, (5) Utah,and (6) Virginia. This Supplemental Notice describes our practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests. This Supplemental Notice isin addition to, and incorporated into, our Privacy Policy.

Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, we have indicated that such language applies only to those consumers.

To the extent terms used in this Supplemental Notice are defined terms under the applicable US State Privacy Law, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein. As ther eare some variations between such definitions in each of the state statutes, the definitions applicable to you are those provided in the statute for the state in which you are a consumer. For example, if you are a Virginia consumer, terms used in this Supplemental Notice that are defined terms in the VCDPA shall have the meanings afforded to them in the VCDPA as this Supplemental Notice applies to you.

1.       Supplemental Notice for California Residents. This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information we have collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider)in the preceding twelve 12 months.

1.1.   Disclosure for California Consumers: Unless specifically stated, we have not sold or shared Personal Information about California consumers to third parties for their own use in the past twelve months. Relatedly, we do not have actual knowledge that we sell or share Personal Information of California consumers under 16 years of age. However, we may share your personal information with our affiliates and trusted partners in arrangements that may meet the broad definition of “sale” or “share” under California law. In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions. That said, we may share information with third-party advertising partners or analytics providers for the purpose of promoting our Services as described above, including for cross-context be havioral advertising. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your personal information shared with such advertising partners or analytics providers by emailing us here: hi@owners.com. For purposes of California law, a “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

1.2.   Additional Privacy Rights forCalifornia Residents:

·   Right to Access. If you are a California consumer, you have the right to ask us to send you the following information up to two times in a twelve-month period: (i) categories of personal data we have collected about you; (ii) categories of sources from which we collected the personal data; (iii) our business or commercial purpose for collecting personal data; (iv) categories of third parties with whom we share personal data; (v) categories of personal data we disclose about you for business purposes; (vi) categories of personal data we sell or exchange for consideration about you; and (vii) the specific pieces of personal information we have collected about you.

·   Right to Delete.If you are a California consumer, you have the right to ask us to delete thepersonal data about you we have collected. We may deny the request if the information is necessary to: (i) complete a transaction, including providing arequested or reasonably anticipated good or service, or fulfill a contract between the consumer and Owners; (ii) detect and protect against security incidents, malicious, deceptive, fraudulent, or illegal activity, or take against those responsible for such activity; (iii) debug to identify and repair errors impairing intended functionality; (iv) comply with the California Electronic Communications Privacy Act; (v) engage in research in the public interest adhering to applicable ethics and privacy laws where the consumer has provided informed consent; (vi) enable solely internal uses reasonably aligned with the consumer’s expectations based on the consumer’s relationship with Owners;(vii) comply with a legal obligation; or (viii) otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided the information.

·   Right to portability.A consumer has the right to request personal information about the consumer bedisclosed in a common file format.

·   Right to Opt-out of the sale of Personal Information. If a business sells personal information to third parties, California consumers have the right, at any time,to opt out of the sale or disclosure of their personal information to third parties. Owners does not sell personal information to third parties, except in conjunction with a corporate sale, merger, dissolution, or acquisition.

·   Right to designate an authorized agent.You have the right to designate an authorized agent to make a request under theCCPA on your behalf. To designate an authorized agent, please contact us.

·   Right to non-discrimination.The CCPA grants California consumers the right not to be discriminated againstfor exercising your privacy rights. If you exercise your privacy rights, we will not discriminate against you, for example, by denying you access to ourshop or charging you different rates or prices for the same Services, unless that difference is reasonably related to the value provided by your data.

1.3.   California Privacy Rights Act.In addition to the rights provided by the CCPA, California residents areprovided with the following rights through the California Privacy Rights Act:(i) the right to request that incorrect or outdated personal information be corrected but not deleted; (ii) the right to restrict a business’s ability to process sensitive data about the consumer; and (iii) prohibition against a business making decisions about a consumer based solely on an automated process without human input.

1.4.   California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

1.5.   Disclosure About Direct Marketing forCalifornia Residents. California Civil Code § 1798.83permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. We do not distribute yourPersonal Information to other entities for their own direct marketing purposes.

2.      Supplemental Notice for Colorado Residents. The Colorado Privacy Act provides Colorado residents with the following rights: (i)the right to opt out of the processing of personal data concerning the consumer; (ii) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer's personal data; (iii) the right to correct inaccurate personal data collected from the consumer; (iv) the right to delete personal data concerning the consumer; (v) the right to restrict a business’s ability to process personal information about the consumer, specifically to opt-out ofprocessing for profiling/targeted advertising purposes; (vi) a prohibition against a business making certain decisions about a consumer based solely on an automated process without human input; and (vii) the right to data portability. When exercising the right to access personal data, a consumer has the right to obtain the personal data in a portable, and to the extent technically feasible,readily usable format that allows the consumer to transmit the data to another entity without hinderance. A consumer may exercise this right no more than twotimes per calendar year. 

3.      Supplemental Notice for Connecticut Residents. The Connecticut Data Privacy Act providesConnecticut residents with the following rights: (i) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer's personal data; (ii) the right to request that in corrector outdated personal information be corrected but not deleted; (iii) the right to delete personal data concerning the consumer; (iv) the right to restrict a business’s ability to process sensitive data about the consumer- specifically to opt-out of processing for profiling/ targeted advertising purposes; (v) the right to request personal information about the consumer be disclosed in a common file format; (vi) the right to opt out of the sale of personal information about the consumer to third parties; and (vii) prohibition against a business making certain decisions about a consumer based solely on an automated process without human input.

4.      Supplemental Notice for Nevada Residents. We generally do not disclose or share personal information for profit. If you area resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. To exercise this right, if applicable, you or your authorized representative may submit a request to hi@owners.com. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

5.      Supplemental Notice for Utah Residents.The Utah Consumer Privacy Act provides Utah residents with the following rights: (i) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer's personal data; (ii) the right to delete personal data concerning the consumer; (iii) the right to restrict a business’s ability to process sensitive data about the consumer- specificallyto opt-out of processing for profiling/ targeted advertising purposes; (iv) the right to request personal information about the consumer be disclosed in a common file format; and (v) the right to request to opt out of the sale of personal information about the consumer to third parties.

6.      Supplemental Notice for Virginia Residents. The Consumer Data Protection Act provides Virginia residents with the following rights: (i) the right to confirm whether or not a controller is processing the consumer's personal data and to access such personal data; (ii) the right to delete personal data provided by or obtained about the consumer; (iii) the right to obtain a copy of the consumer's personal data that the consumer previously provided to the business ina portable and, to the extent technically feasible, readily usable format; iv)the right to opt out of the processing of the personal data for purposes of (i)targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer; and (vi) the right to restrict a business’s ability to process personal information about the consumer, specifically to opt-out ofprocessing for profiling/targeted advertising purposes.

Disclosure for Colorado, Virginia, Utah, and Connecticut Consumers: Unless specifically stated, we do not sell or share Personal Information to Third Parties for their own use. However, we may share or process one or more of the above categories of personal information with our affiliates and trusted partners in arrangements for purposes of targeted advertising, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPA, VCDPA, UCPA, and CTDPA. In these arrangements, use of the information weshare is limited by policies, contracts or similar restrictions.

Changes to this Supplemental Notice: We reserve theright to amend this Supplemental Notice at our discretion and at any time. Whenwe make material changes to this Supplemental Notice, we will notify you byposting an updated Supplemental Notice on our website and listing the effective date of such updates.

Contact Us: For moreinformation about our privacy practices, if you have questions, or if you wouldlike to make a complaint, please contact us by e‑mail at hi@owners.com.

Owners app use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.