Privacy Policy

We care about your privacy

We are committed to treating your privacy with respect, fairness, transparency and integrity, honouring the trust you place in us:

we will be transparent with you through our Privacy Policy and during our interactions with you;
we will only use your personal data to provide you our services, for legitimate business purposes, to fulfil legal obligations, to keep you safe and where you tell us it’s ok;
we will only send you marketing messages if you tell us to do so;
we will keep your personal information secure;
we will respect your rights to control the personal information you share with us.

Our Privacy Policy in Brief

This Privacy Policy covers the OWNERO SA, Luxembourg, 5 Rue Goethe, 1637, its websites, mobile applications and mobile websites.

Personal information we collect and use

We will collect, process and use personal information during our interactions with you. The type of personal information we collect depends on the type of interaction with you. It typically includes:

name/ title;
date of birth;
contact details (including email address and telephone/mobile number);
marketing preferences.

How we use this personal information

We use your personal information to support our business and interactions with you. Such as, to:

provide you our services;
operate our business;
personalise, market and advertise our products, services and offers;
communicate and interact with you;
improve our products, services and websites/mobile applications;
meet legal obligations, prevent crime / fraud and for legal purposes.

We only collect, process, use, share and store your personal information where we are satisfied that we have an appropriate legal basis to do so.

Sharing your personal information with others and globally

The OWNERO SA is a global business, which means your personal information may be transferred and stored in the United Arab Emirates and other countries which may be outside your country of residence. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and fully managed to protect your privacy rights and interests.

How we protect and store your personal information

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to protect the personal information that you share with us and safeguard the privacy of such information. For example, the measures we take include:

placing confidentiality requirements on our staff members and service providers;
destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected;
following security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it;
using secure communication channels such as SSL ("secure sockets layer") or TLS (“transport layer security”) for transmitting data that is sent to us. SSL and TLS are industry standard encryption protocols used to protect online transaction channels.

Cookies

A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our websites and the internet, and helps us provide better website services to you and tailor certain content.

Legal rights available to help manage your privacy

If you are subject to laws that provide you with such rights, depending on certain exceptions and the processing activity we are undertaking, you may have certain rights in relation to your personal information, such as the right to:

access personal information;
restrict the processing of your personal information;
object to the processing (including direct marketing) of personal information;
transfer your personal information;
obtain a copy of personal information safeguards used for transfers outside your jurisdiction;
lodge a complaint with your local supervisory authority.

You can exercise your by contacting us by email Info@ownero.com.

How to contact us

If you have any questions about our Privacy Policy, you can contact our Data Privacy Officer at Info@ownero.com.

Updates to this Privacy Policy

We may amend this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business. If we decide to change our Privacy Policy, we will place any updates on this webpage and the privacy sections of any relevant platforms.

Updates

We may amend this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business. If we decide to change our Privacy Policy we will place any updates on this webpage and the privacy sections of any relevant Platforms. Please regularly check this webpage and the privacy sections of any relevant Platforms for the latest version of our Privacy Policy. If at any point we decide to make fundamental changes to our Privacy Policy, we will seek to inform you by notice on our website or on the relevant section of any other Platform or email.

Third Party Websites

You might find external links to third party websites on our Platforms. Our Privacy Notice does not apply to your use of a third party site. We are not responsible for the privacy practices of websites that are not operated by an entity in the OWNERO SA and encourage you to read the privacy statements of any such third party site.

We use your personal information to:

fulfil our agreement with you;
personalise the service and offers you receive;
personalise the look and feel of our Platforms and communications with you, so as to align with preferences you may have told us about or which we have inferred from your use of our Platforms, market research, your interactions with us on social media and previous transactions (details on How we use your personal information for marketing purposes, profiling and analytics are below);
improve the products and services we offer or help us to create new ones;
conduct customer satisfaction surveys so that we can obtain a better understanding of how we can continue to improve the products and services we offer or help us to create new ones. During these surveys we may collect personal information from you relating to your thoughts/comments about your experience with us;
market our products and services to you (details on How we use your personal information for marketing purposes, profiling and analytics are below);
work with social media providers to provide you with advertisements within those platforms (details on How we use your personal information for marketing purposes, profiling and analytics are below);
manage our business such as for systems testing, IT maintenance or development training, benchmarking and performance measurement;
use in connection with your online as you may authorise or consent to additionally from time to time.

Personal information we collect and use when you use our Platforms

Our Platforms use cookies. A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our Platforms and the internet, and helps us provide better Platform services to you and tailor certain content. Cookies may collect personal information about you. For more information on how we use personal information when you use our Platforms and how to manage cookie settings see When and how we undertake analytics and profiling and Cookies below. We also monitor your journey on our Platforms via tools on our Platforms in order to ensure your customer experience meets expectations and to identify errors or issues.

Some of our Platforms make available for purchase products and services.

Overview

These sections explain the legal basis for collecting and using your personal information, how we use personal information for marketing, analytics and profiling, how we protect your personal information, the legal rights that are available to you and how to contact us.

Legal basis for using your personal information

we only collect, process, use, share and store your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:
we need to use your personal information to perform a contract or take steps to enter into a contract with you;
we need to use your personal information for our legitimate interest as a commercial organisation. For example, we may record calls to our customer service centre so that we can review how we handle calls and make any necessary improvements or we may share your personal information with other OWNERO SA companies to improve our products and services. In all such cases, we will look after your information at all times in a way that is proportionate, that respects your privacy rights and is in accordance with our Privacy Policy, and you have a right to object to processing as explained in Legal rights available to help manage your privacy;
we need to use your personal information to comply with a relevant legal or regulatory obligation that we have or we are legally permitted to disclose your personal information to law enforcement or regulatory and other governmental agencies to aid in investigations;
we have your consent to using your personal information for a particular activity. For example, where you consent to us sharing with you special offers about the OWNERO SA which we think may be of interest;
we need to use your personal information to protect your vital interests.
we set out more information about the legal bases for which we process personal information in the table which you can access below. There may be one or more legal bases relevant to an activity listed in this table. The table may be amended and updated from time to time.

Sharing your personal information with others

We share your personal information in the manner and for the purposes described below:

with other entities within the OWNERO SA where such disclosure is necessary to provide you with our products and services or to manage our business, including loyalty schemes. We may also share your personal information within the OWNERO SA to personalise the service and offers you receive (for example, preferences and tailoring the way we provide our products or services to you based on your preferences and profile); to develop a single view of our customers’ transactions, interactions, preferences and behaviours across the OWNERO SA; to improve the products and services we offer or help us to create new ones and for marketing, profiling and analytics as detailed in Personal information we collect and use for marketing purposes, profiling and analytics below; and for the purposes described in this Privacy Policy;
with third parties who help us manage our business and deliver our products and services, including loyalty schemes. These third parties have agreed to confidentiality obligations and use any personal information we share with them or which they collect on our behalf solely for the purposes of providing the contracted service to us. These third parties include service providers who help manage our IT and back office systems, manage communications and tailor marketing and advertising; manage our data warehouses; provide services to administer our Platforms; provide internet services; host our facilities; and conduct research that assists us with understanding consumer interests;
with third parties whose products or services you are purchasing through our Platforms or otherwise so that they can complete your purchase, meet their legal obligations in connection with your purchase. These third parties may have their own privacy policies that also apply to you; and may use your personal information to meet their own business purposes and legal requirements;
we may share in aggregate, statistical form, non‑personal information regarding the visitors to our Platforms, traffic patterns and Platform usage with our other entities within the OWNERO SA or third party advertisers and social media and digital platforms to provide advertising;
we work with third party advertising and social media platforms to provide more personalised advertising promoting our products and services in accordance with your preferences as detailed in Personal information we collect and use for marketing purposes, profiling and analytics below;
if, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.

How we use personal information to keep you up to date with our products and services

We use personal information to let you know about OWNERO SA products and services that we think may be of interest to you. This may be based on your preferences, derived from Cookies, inferred from your interactions with us including on our social media accounts or market research. We may also let you know about our corporate services which we believe may be relevant to you in a professional capacity.

We also work with social media and other digital platforms to provide you with advertisements within those platforms. We provide them with your name and contact details (such as your email address or phone numbers). If these social media and digital platforms match profile information provided by us with your profile information held by them then they will serve you our advertisements. The social media platforms will not identify you or share other personal information in your social media account to us.

We will only send you direct marketing, whether about OWNERO SA, carefully selected third parties or partners, products or services, in accordance with your marketing preferences. We may contact you by email, SMS/text, social media, or through other communication channels that we think you may find helpful. If at any time you would like us to stop sending you marketing material, contact us Info@ownero.com.

How you can manage your marketing preferences

To protect your privacy and to ensure you have control over how we manage marketing with you (and provided that you have indicated that you would like to receive it):

we will take steps to limit direct marketing to a reasonable and proportionate level;
only send you communications which we believe may be of interest or relevance to you and at all times in line with your permissions, which, as appropriate, may include:
telling you about developments in the products and services available through our Platforms and those of our carefully selected partners (provided that we will communicate these to you in conjunction with our own marketing);
allowing other companies within the OWNERO SA to send you information about developments in their products and services; and
allowing third parties to send you marketing or updates relating to their products or services.
you have the ability to change your cookie settings to block certain types of cookie;
you can click the "unsubscribe" link that you will find at the bottom of our emails which you receive from us, or you can unsubscribe by contacting us or changing your account settings which will remove you from Emirates' marketing lists;
you can opt out of mobile device messages or notifications from applications by going into “settings” on your device and turn off notifications for the relevant application;
if you do not want to be served with our advertisements within social media or other digital platforms, you can manage your preferences within these platforms.

Be aware that if you unsubscribe completely from our marketing communications we may be unable to notify you of tailored offers to meet your needs.

When and how we undertake analytics and profiling

Analytics

We aggregate personal information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse Platform use, to improve our content and products and services, to customize our Platforms’ content, layout, products and services, and to support our business operations and we may appoint third parties to do this on our behalf, as set out above in Sharing personal information with others.

We gather certain usage information like the number and frequency of visitors to our Platforms. This information includes which webpage you just came from, which webpage you next go to, what browser you are using, your device ID and your IP address. This collective data helps us to determine how much our customers use parts of our Platforms, and do research on our users’ demographics, interests, and behaviour to better understand and serve you. One of the ways we do this is by installing and using Cookies on your browser or device. You can find out more about cookies and our Cookie Policy in the section entitled Cookies below.

If you use buttons on our Platforms linked to social media or similar sites (for example, "Like" and/or "Share" buttons), content from our Platforms may be sent back to those sites and, depending on your privacy settings, may be privately or publicly visible (for example, to friends, followers or generally to anyone who has access to your profile page).

Profiling

We use personal information such as your date of birth, gender, country of residence, transactions (for example, payments made with us, mileage and flights taken), information derived from Cookies and your preferences for profiling. Some of the legitimate purposes we profile personal information include:

to obtain a better understanding of what you would like to see from us and how we can continue to improve our services for you;
to personalise the service and offers you receive from us and recognise your loyalty and reward you as part of our loyalty schemes, including with invitations to special events;
to provide you with tailored content online and optimise your experience of our Platforms;
to provide you with tailored advertisements on other websites you visit and social media and digital platforms;
to share marketing material we believe may be of interest to you, including from other companies within the OWNERO SA and our third party partners;
to help us operate our services more efficiently;
to authenticate log‑ins on our Platforms and detect, prevent fraud and send you email or SMS/text with one time passwords.

Where required under applicable privacy laws:

we will take steps to ensure that prior to profiling your personal information for a legitimate interest that our legitimate interest is not overridden by your own interests or fundamental rights and freedoms;

Transferring personal information globally

The OWNERO SA is a global business, which means your personal information may be transferred and stored in the United Arab Emirates and other countries which may be outside your country of residence. Some of these countries are subject to different standards of data protection than your country of residence.

We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law, and we only transfer personal information to another country where:

we are satisfied that adequate levels of protection are in place to protect your information;
the transfers are fully managed to protect your privacy rights and interests and are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.

To this end:

we ensure transfers within the OWNERO SA will be covered by an agreement entered into by members of the OWNERO SA (an intra group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within the OWNERO SA;
where we transfer your personal information outside the OWNERO SA or to third parties (who help us to provide our products and services), we obtain contractual commitments from them to protect your personal information;
where we receive requests for information from law enforcement or regulators, we carefully review and validate these requests before any personal information is disclosed.

In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions.

You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

How we protect and store your personal information

Protection of your personal information

placing confidentiality requirements on our staff members and service providers;
destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected;
following security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it;
using secure communication channels such as SSL ("secure sockets layer") or TLS (“transport layer security”) for transmitting data that is sent to us. SSL and TLS are industry standard encryption protocols used to protect online transaction channels.

As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

Storage of your personal information

We keep your personal information for as long as is reasonably necessary for the purposes for which it was collected. We will ensure that it is disposed of in a secure manner.

In some circumstances we may store your personal information for longer periods of time, for example, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

If you require further information about how we retain particular information please contact us.

Cookies

A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our Platforms and the internet, and helps us provide better Platform services to you and tailor certain content.

Cookies may collect personal information about you. Cookies help us remember information about your visit to our Platforms, like your country, language and other settings and searches. Cookies enable us to understand who has seen which webpages and how frequently, and to determine which are the most popular areas of our Platforms. They can also help us to operate our website more efficiently, and make your next visit easier and customise your view of the Platforms to reflect your preferences and activities. They also help us tailor our marketing and advertisements to you on our Platforms, other websites you visit, social media platforms and your other devices.

For more information on how we use cookies please read our Cookie Policy, where you can also find information so you can delete cookies or block certain types of cookie. You should note that this may have an impact on our ability to provide the Platform services to you.

Legal rights available to help manage your privacy

If you are subject to laws that provide you with such rights, depending on certain exceptions, and in some cases dependent upon the processing activity we are undertaking, you may have certain rights in relation to your personal information:

to access personal information;
to rectify / erase (‘right to be forgotten’) personal information;
to restrict the processing of your personal information;
to object to the processing (including direct marketing) of personal information;
to transfer your personal information;
to obtain a copy of personal information safeguards used for transfers outside your jurisdiction;
to lodge a complaint with your local supervisory authority.

If you wish to access any of the rights set out above, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive.

Right to access personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: the source of your personal information; the purposes, legal basis and methods of processing; the data controller’s identity; and the entities or categories of entities to whom your personal information may be transferred.

Right to rectify or erase personal information

You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.

You can also request that we erase your personal information in limited circumstances where:

it is no longer needed for the purposes for which it was collected; you have withdrawn your consent (where the data processing was based on consent);
following a successful right to object (see right to object);
it has been processed unlawfully;
the personal information must be erased for compliance with a legal obligation under European Union or Member State law to which the relevant OWNERO SA entity is subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

for compliance with a legal obligation;
for the establishment, exercise or defence of legal claims.

Right to object to the processing (including direct marketing) of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

You can request that we stop contacting you for marketing purposes.

You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

Right to transfer your personal information

You can ask us to provide your personal information to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

the processing is based on your consent or on the performance of a contract with you; and
the processing is carried out by automated means.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

We may redact data transfer agreements to protect commercial terms.

Right to restrict the processing of your personal information

You can ask us to restrict your personal information, but only where:

its accuracy is contested, to allow us to verify its accuracy;
the processing is unlawful, but you do not want it erased;
it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims;
you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal information following a request for restriction, where:

we have your consent;
to establish, exercise or defend legal claims;
to protect the rights of another natural or legal person.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority (i.e. your place of habitual residence, place of work of place of alleged infringement) if you have concerns about how we are processing your personal information.

We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

How to exercise your rights

You can exercise your rights by emailing us at Info@ownero.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

How to contact us

The primary point of contact for all issues arising from this Privacy Policy is our Data Privacy Officer, who can be contacted at Info@ownero.com.

If you have any questions, concerns or complaints regarding our compliance with this Privacy Policy, we encourage you to first contact our Data Privacy Officer. We will investigate and attempt to resolve complaints and disputes as quickly as possible and in any event, within the timescales provided by applicable data protection laws.