Owlo Privacy Policy

This Privacy Policy explains how JLM Enterprises LLC, doing business as Owlo (“Owlo,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal information when you use our websites, applications, AI-powered learning tools, and related services (collectively, the “Services”).

By using the Services, you acknowledge the practices described in this Privacy Policy. If you do not agree, please do not use the Services.

Questions or privacy requests may be sent to support@owloapp.com.

1. Personal Information We Collect

The information we collect depends on how you use the Services.

A. Information You Provide

We may collect:

• Account information, such as your name, email address, password or authentication credentials, and account preferences.
• User content, including documents, notes, images, study materials, questions, prompts, chat messages, flashcards, summaries, and other content you upload, submit, generate, or store through the Services.
• Communications, including information you provide when you contact customer support, submit feedback, participate in surveys, or otherwise communicate with us.
• Transaction information, such as your subscription plan, purchase history, billing status, and limited payment-related details. Payment card information is processed by our payment processor and is not stored by Owlo.

Please do not upload sensitive personal information or personal information about another person unless you are authorized to do so and the information is necessary for your use of the Services.

B. Information Collected Automatically

When you use the Services, we and our service providers may automatically collect:

• Device and technical information, such as IP address, browser type, operating system, device type, language, and app or browser settings.
• Usage information, such as pages or features viewed, actions taken, session dates and times, referring URLs, interactions with generated content, and performance or error data.
• Cookie and similar technology data, where applicable, to operate the Services, remember preferences, understand usage, and improve performance. You may be able to control cookies through your browser settings or any cookie controls we make available.

C. Information From Third Parties

If you sign in through a third-party provider, such as Google, we may receive information authorized by you and the provider, such as your name, email address, profile image, and account identifier. The information we receive depends on the provider and your settings.

We may also receive information from educational institutions, business partners, or other organizations that provide access to Owlo, subject to their agreements with us and applicable law.

2. How We Use Personal Information

We may use personal information to:

• Create, authenticate, maintain, and administer accounts.
• Provide the Services and requested features, including processing uploaded content and prompts to generate summaries, flashcards, quizzes, explanations, and other learning materials.
• Personalize the user experience and remember preferences.
• Process subscriptions and transactions.
• Provide customer support and respond to requests.
• Send administrative or service-related communications, including security, account, billing, and policy notices.
• Monitor, maintain, troubleshoot, secure, and improve the Services.
• Understand product usage and develop new features.
• Detect, investigate, and prevent fraud, abuse, security incidents, and violations of our terms.
• Comply with legal obligations and protect the rights, safety, and property of Owlo, our users, and others.
• Carry out other purposes described at the time information is collected or with your consent.
• Train, test, evaluate, and improve Owlo's artificial intelligence models, systems, and related features, as described in Section 3.

3. AI Processing

Owlo uses artificial intelligence to provide learning features. When you submit prompts or user content, that information may be processed by Owlo and by AI, hosting, infrastructure, or other service providers acting on our behalf.

Our AI providers include OpenAI, Anthropic, and Google. Depending on the feature selected or made available, prompts, uploaded materials, relevant account or usage context, and generated output may be transmitted to and processed by one or more of these providers to generate responses and operate Owlo's AI features.

Unless prohibited by law, an institutional agreement, or a setting or notice presented to you, Owlo may use prompts, uploaded materials, interactions, feedback, and AI-generated output to train, test, evaluate, and improve its models, systems, and Services. Our service providers may process this information on our behalf for these purposes, subject to their agreements with us. We do not authorize service providers to use personal information for their own independent model-training purposes unless we disclose that practice and obtain any consent required by law.

AI-generated output may be stored with your account or retained as needed to provide, secure, evaluate, train, and improve the Services. Do not submit information that you are not authorized to use or that you do not want processed as described in this Privacy Policy. Where required by law, we will provide additional notice or obtain consent before using personal information for model training.

Owlo's AI features are intended to support learning and may produce inaccurate or incomplete results. They are not intended to make decisions that have legal or similarly significant effects on individuals.

4. How We Disclose Personal Information

We do not sell personal information for money. We may disclose personal information in the following circumstances:

• Service providers. We may disclose information to vendors that support hosting, cloud storage, AI processing, authentication, analytics, communications, customer support, security, and payment processing. They may process information only as permitted by their agreements with us and applicable law.
• Account administrators and institutions. If your account is provided or managed by a school, employer, or other organization, that organization and its authorized administrators may be able to access or manage certain account information, content, or activity, depending on the arrangement and account settings.
• Business transfers. We may disclose information in connection with an actual or proposed merger, financing, acquisition, reorganization, bankruptcy, sale of assets, or similar transaction.
• Legal and safety reasons. We may disclose information when we reasonably believe it is necessary to comply with law or legal process; enforce our terms; protect rights, property, or safety; or detect, prevent, or address fraud, abuse, or security issues.
• With your direction or consent. We may disclose information when you ask us to or otherwise authorize the disclosure.

Our primary providers currently include:

• Google services, including Google Analytics for website and product analytics and Google authentication where users choose Google sign-in.
• Amazon Web Services (AWS), for cloud hosting, storage, infrastructure, and related technical services.
• Stripe, for payment and subscription processing.
• OpenAI, Anthropic, and Google, for artificial intelligence model processing and related AI services.

We may add or replace providers as the Services evolve. Additional providers may be identified in our in-product notices, cookie controls, or provider list.

We may use analytics, advertising, retargeting, cookies, pixels, and similar technologies. Depending on applicable law, disclosing identifiers and internet activity to advertising or analytics partners may be considered a “sale,” “sharing,” or use for targeted advertising even when no money is exchanged. We provide applicable opt-out choices through our cookie controls or dedicated privacy choices page and honor legally required browser-based opt-out signals. Owlo does not knowingly use personal information from users under 16 for targeted advertising, retargeting, or cross-context behavioral advertising.

5. Payment Processing

Payments are processed by Stripe or another payment processor identified at checkout. The payment processor collects and processes payment card and billing information under its own privacy policy. Owlo generally receives transaction details such as payment status, subscription type, and limited billing information, but not full payment card numbers.

You can review Stripe's Privacy Policy.

6. Legal Bases for Processing

If you are located in the European Economic Area, United Kingdom, or another jurisdiction that requires a legal basis for processing, we rely on one or more of the following:

• Performance of a contract, when processing is necessary to provide the Services you request.
• Legitimate interests, including operating, securing, improving, and understanding the Services, provided those interests are not overridden by your rights.
• Consent, when we ask for and receive your consent. You may withdraw consent at any time, without affecting processing that occurred before withdrawal.
• Compliance with legal obligations, when processing is necessary to comply with applicable law.

The legal basis may vary depending on the information and the context in which it is processed.

7. Data Retention

We generally retain account information and user content while your account is active. After you delete your account, we aim to delete or de-identify account information and user content from active systems within 30 days, unless retention is required for security, fraud prevention, dispute resolution, legal compliance, or enforcement of our agreements.

Residual copies may remain in encrypted backups for up to 90 additional days before being overwritten through our normal backup cycle. Security and system logs are generally retained for up to 12 months. Transaction, tax, and accounting records may be retained for up to seven years or longer if required by law.

De-identified or aggregated information may be retained where it can no longer reasonably be linked to you. We may also retain information for a longer period when reasonably necessary to establish, exercise, or defend legal claims, respond to lawful requests, or protect the Services and our users.

8. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your login credentials and for promptly notifying us if you suspect unauthorized access to your account.

9. Your Privacy Rights and Choices

Depending on where you live, you may have the right to:

• Request access to or a copy of your personal information.
• Request correction of inaccurate personal information.
• Request deletion of personal information.
• Request restriction of or object to certain processing.
• Request data portability.
• Withdraw consent where processing is based on consent.
• Opt out of certain sales, sharing, targeted advertising, or profiling, where applicable, through our cookie controls or dedicated privacy choices page.
• Appeal our decision regarding a privacy request, where applicable.
• Lodge a complaint with your local data protection authority.

You may also update certain account information through your account settings.

To submit a privacy request, email support@owloapp.com. We may need to verify your identity before completing a request. Authorized agents may submit requests where permitted by law, but we may require proof of authorization and verification of the consumer's identity.

We will not discriminate against you for exercising applicable privacy rights.

10. California Privacy Notice

California residents may have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”).

Depending on how you use the Services, we may collect the following categories of personal information: identifiers; customer records information; commercial information; internet or other electronic network activity; geolocation information derived from an IP address; audio, electronic, visual, or similar information included in user content; professional or educational information; and inferences drawn from usage or preferences.

We collect these categories from you, your device or browser, service providers, sign-in providers, and organizations that provide access to the Services. We use and disclose them for the business and commercial purposes described in Sections 2 and 4.

Owlo does not sell personal information for money. However, some uses of analytics, advertising, retargeting, cookies, or pixels may be considered “selling” or “sharing” under California law. California residents may opt out through our cookie controls or dedicated privacy choices page. We also process Global Privacy Control signals as opt-out requests where required.

Owlo does not knowingly sell or share the personal information of consumers under 16 and does not use their personal information for targeted advertising or retargeting.

California residents may request to know, access, correct, or delete covered personal information and may exercise any applicable right to opt out or limit certain uses of sensitive personal information. These rights are subject to exceptions under applicable law.

California's “Shine the Light” law may permit certain residents to request information about disclosures of personal information for third parties' direct-marketing purposes. Owlo does not disclose personal information to third parties for their own direct-marketing purposes as defined by that law.

11. Other U.S. State Privacy Rights

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and other states with comprehensive privacy laws may have rights relating to access, correction, deletion, portability, targeted advertising, sale, profiling, and appeals, subject to the scope, applicability, and exceptions of those laws.

You may exercise applicable rights by contacting us at support@owloapp.com. If we deny your request, you may appeal by replying to our decision and stating that you wish to appeal.

12. Age Eligibility and Teen Privacy

The Services are intended only for users who are 13 years of age or older. Children under 13 may not create an account or use the Services. Owlo does not knowingly collect personal information from children under 13.

If we learn that we have collected personal information from a child under 13, we will take reasonable steps to delete the information and terminate or restrict the associated account. If you believe a child under 13 has provided personal information to Owlo, contact us at support@owloapp.com.

Users between 13 and 17 should review this Privacy Policy with a parent or legal guardian. Where applicable law requires parental or guardian consent for a user under the age of majority to use the Services or for particular processing activities, the user may use the Services only after the required consent has been obtained.

Owlo does not knowingly sell or share the personal information of users under 16. We also do not knowingly use personal information from users under 16 for targeted advertising, retargeting, or cross-context behavioral advertising.

If Owlo is offered through a school or educational institution, additional terms, notices, or agreements may apply. We use student information provided through a school-authorized account to provide and support the educational service, comply with our agreement, secure and improve the Services as permitted by the agreement and applicable law, and satisfy legal obligations.

13. International Data Transfers

Owlo and its service providers may process and store personal information in the United States and other countries where privacy laws may differ from those in your country. Where required, we use recognized safeguards for international transfers of personal information.

14. Third-Party Services and Links

The Services may contain links to or integrations with third-party websites, platforms, or services. Their privacy practices are governed by their own policies, not this Privacy Policy. We encourage you to review those policies before providing information to third parties.

15. Do Not Track

Some browsers offer a “Do Not Track” setting. Because there is not a universally accepted standard for responding to these signals, the Services may not respond to them. We recognize legally valid browser-based opt-out preference signals, such as Global Privacy Control, where required by applicable law. You may also manage non-essential cookies through our cookie controls or dedicated privacy choices page.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the revised policy and update the “Last Updated” date. If changes are material, we may provide additional notice as required by law, such as by email or through the Services.

17. Contact Us

If you have questions, concerns, or privacy requests, contact us at:

JLM Enterprises LLC, doing business as Owlo
Email: support@owloapp.com
Mailing address: 13771 Denison Street, Suite L, Poway, CA 92064, United States