This policy applies to the affiliated companies that are part of Own Solutions AC Ltd. (including Own Solutions d.o.o).

The reference to Own Solutions (including “we”, “us” or “our”) includes those companies and all relevant group affiliates.

References to “you” in this notice are to the individual who is accessing or applying to use the Services (as defined below) either on your own account or on behalf of a business.

At Own Solutions, we take the protection of personal data seriously. We understand that your privacy is important to you, and we are committed to collecting, using, and protecting your personal data in accordance with the EU General Data Protection Regulation (GDPR). This Privacy Policy explains how we collect, use, and protect your personal data. It also explains your rights under the GDPR, and how you can exercise those rights. If you have any questions or concerns about this policy, please do not hesitate to contact us.

This introduction states Own Solutions commitment to privacy and compliance with the GDPR. It also explains the purpose of the policy and how it covers the personal data collection and usage, as well as the rights of the individuals and how they can exercise them. It also encourages the users to contact the company if they have any questions regarding the policy.

In the following policy, we provide information about the collection of personal data when using:

• Own Solutions’ website services and features provided when you access Own Solutions website, portals or pages (such as, but not limited to https://own.solutions including any country versions and sub-domains) (hereinafter “website”) and/or
• Own Solutions’ products and services (including, but not limited to ESP – eService Platform), and/or
• any ways or means of communication between you and Own Solutions such as, but not limited to, email, telephone, web chat, website/portal.

Together these are all referred to in this notice as “Services”.

Please note that Own Solutions provides services to both individual consumers and businesses (such as Own Solutions ESP users, CloudPOS users, POS terminal user) and this Privacy Policy applies to both and should be read and interpreted accordingly.

1. Identity of the controller for processing personal data

Own Solutions AC Ltd, Marina House, Marina Village, Malahide, Co. Dublin K36 N702, Ireland is the controller for the personal data we process, unless stated otherwise.

2. Contact

You can address your data protection concerns to: Own Solutions AC Ltd, Marina House, Marina Village, Malahide, Co. Dublin K36 N702, Ireland at email address GDPR@own.solutions

3. Personal Data

We collect and process personal and non-personal information relating to you.

Personal data is any information that relates to an identified or identifiable individual, also known as a data subject, and it is information that can be used to uniquely identify a single person, either directly or indirectly. This includes information such as (but not limited to) a person’s name, address, email address, or IP address, as well as any other information that can be used to identify a person. Under GDPR, organizations like Own Solutions are responsible for ensuring that personal data is collected, processed, and stored in a manner that is compliant with data protection regulations.

We may also collect and process non-personal information or may anonymize personal information in order to make it non-personal. Non-personal information is information that does not enable a specific individual to be identified, either directly or indirectly.

4. Collection of data during informational use of Own Solutions website

When you use the website for informational purposes only, that is, when you do not register or otherwise provide us with information, we do not collect any personal data, except for the data that your browser sends to enable you to visit the Website.

These are:

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (concrete page)
• Access status/HTTP status code
• Amount of data transmitted in each case
• Website from which the request comes
• Browser
• Operating system and its interface
• Language and version of the browser software

5. Collection of personal data during use of Own Solutions services (including Own Solutions websites: newsletter, downloads, contact form, marketing campaigns and promotions, etc.)

When you use Own Solutions websites to be in contact with our team, submit a form, register for our newsletter or download content, such as a whitepaper, personal data can be collected and stored in our Customer Management Systems, such as but not limited to HubSpot and Bamboo, in order to follow up with your request. We will use the data for the sole purpose of processing your request and only with your explicit consent.

We also may collect and process:

• your IP address when using Own Solutions services
• your name, last name, company email address and company phone number in the context of Own Solutions sales and/or business discussions.

6. Collection of personal data during use of eService Platform (or ESP)

eService Platform (or ESP) is a back-office transactional platform that provides Digital Products for sale in retail stores. The ESP manages the digital product catalog, pricing and ranging of digital products, activation with the supplier, generation of vouchers, and overall sales reporting and settlement, containing a portfolio of Digital Products. To provide this service and also for legal and regulatory purposes, Own Solutions may need to collect specific personal data as follows:

For identification purposes during account creation:

• First Name, Middle Name, Last Name
• Email address
• Mobile Phone Number

We may use your First Name, Middle Name, Last Name, telephone number and email address for marketing purposes.   

For verification purposes, for users that operating CloudPOS and/or terminals and/or retail stores we may collect personal data as follows:

• First Name, Middle Name, Last Name
• Email address
• Mobile Phone Number
• Full Address
• Gender

We will use the above information for regulatory purposes, store management, access and security purposes.

We will always seek to notify you and obtain your consent if it is our intention to make use of this information for any other purposes than the above indicated.

7. Collection of personal data during recruitment process

When you apply for a position at Own Solutions, we collect the following information: your First Name, Last Name, Email address, details from your resume (including education, professional training, work experience, skills, and specific knowledge), Phone Number, Address, and the URLs of any social media profiles (such as LinkedIn, Facebook, GitHub, or any other relevant links).

This information is gathered and processed based on our legitimate interest in identifying, selecting, and hiring qualified candidates to meet our business needs. Our goal is to find the most suitable candidate for the advertised role and to build a pool of potential candidates for future openings, thereby enhancing the interest of skilled professionals in working with us.

For the candidate who accepts our job offer, we will process the data as necessary to take the required steps before finalizing an employment contract. This ensures we can establish an employment relationship and complete the contractual process.

Providing personal data is optional. However, if you wish to apply for the advertised position, you must fill out the application form, enabling us to collect your personal data throughout the application and selection process. Without this data, you will be unable to apply for the position.

8. Processing purposes and legal basis

Data processing is carried out in particular to analyze the internet traffic on our services, to maintain and monitor the performance of our services, to improve the functionality of our services and for advertising purposes. We may also use your personal information to contact you, to provide you with a service or to keep you up to date about our services and promotions, as per your request.

The lawful basis we rely on for processing of your data depends upon the relevant data gathered and processing purpose.

Purpose	Lawful basis
Collection of data during informational use of Own Solutions website	Consent
Collection of personal data during use of Own Solution’ services (including Own Solutions websites: newsletter, downloads, contact form, marketing campaigns and promotions, etc.)	Consent
Collection of personal data during use of Own Solutions eService Platform (or ESP) including CloudPOS and/or any other integral part of ESP	As necessary to process transactions, manage and control access to ESP and/or any other integral part of ESP including but not limited to any device connected to ESP (POS device, terminal device…)
Collection of personal data during recruitment process	Consent

If you have given us your consent to process your personal data for specific purposes (for example, marketing promotions, informational purposes about new releases, improvements, service availability, maintenance windows), we will process your personal data within the scope of and based on this consent, unless we have another legal basis and do not require such a basis. A given consent can be revoked at any time, but this has no effect on data processing that has already taken place.

9. Data categories and data origin

We process the data that is generated when you use our services and websites or the data that is provided by you (for example, when you register for a specific service).

10. Recipient (data disclosure)

In the course of our business activities and purposes, we also disclose personal data to third parties where permitted, and necessary for your proper use of the services and/or required by law. This concerns in particular the following data recipients:

• Own Solutions’ affiliated companies (including Own Solutions AC Ltd and Own Solutions d.o.o.);
• Service providers of Own Solutions affiliated companies, including the companies mentioned in this Privacy Policy and contractors (e.g., IT providers, digital marketing agencies), marketing tools such as HubSpot, and HR tools such as Bamboo.

Under no circumstances do we sell any data to third parties or share it for the purposes of direct marketing.

11. International transfers

Some of the above recipients are in the EEA area but they can also be abroad. In particular, you must expect your data to be transferred to all countries in which the Own Solutions Group is represented by group companies, branches or other offices and to other countries in Europe and the USA where the service providers we use are located or operate. These countries may have data protection standards that are different to (and, in some cases, lower than) those of the territory in which you reside and therefore courts, law enforcement and other authorities in these countries have the right to access your information in certain situations.

If we transfer data to a country without adequate legal data protection, we will ensure an adequate level of protection as required by law by means of appropriate contracts. We partner with data processors who are third parties who provide elements of services for us. We have contracts and agreements in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct.

We will not share your information with any third parties for the purposes of direct marketing by such third parties. If we are required to disclose your information by a judicial, governmental or regulatory authority, acting within its legal authority, we will comply and share only the Information we are obligated to provide.

12. Use of Cookies

We typically use “cookies” and similar tracking technologies on our websites to identify your browser, device and tracks the activity on our websites and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our service. Throughout this policy, when referring to “cookies”, we implicitly also refer to similar tracking technologies such as “web beacons”. The technologies we use may include:

• Cookies are small text files that are stored on your hard disk in accordance with the browser you are using and through which certain information is transmitted to the party that sets the cookie (in this case us or third parties). They are used to make the Internet offer as a whole more user-friendly and effective and to analyze the surfing behavior of the website visitors. We use cookies to identify you for subsequent visits if you have an account with us. Otherwise, you would have to log in again for each visit.
• Web Beacons. Certain sections of our websites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

More about Cookie Policy can be found here.

13. Marketing promotions on the website

We may occasionally run promotions. Your data (First Name, Last Name and Email Address) will be processed and stored by a data processor on our behalf or by ourselves for the purpose of the promotion. The personal data will be deleted if they are no longer needed for the purpose for which they were collected, which is to evaluate the success of the promotion.

14. Newsletter

We are happy to inform you about current topics concerning Own Solutions and our products via our newsletter. Your data will only be used and stored by us for the purpose of sending the newsletter.

You can unsubscribe from the newsletter at any time and thus object to the further use of your data. You can unsubscribe from the mailing list at the end of a newsletter.

To send our newsletters, we use the application such as “HubSpot”, a service of HubSpot, Inc., Cambridge, MA 02141, United State. Further information of their data protection and compliance can be found by clicking the following links: HubSpot Private Policy and GDPR Compliance.

 

15. Contact Form

If you fill out a contact form or send us an e-mail or other electronic message, your details will only be stored for the purpose of processing the enquiry, possible related further questions and will only be used within the scope of the enquiry.

If you fill out a carrier contact form or send us an e-mail or other electronic message, we will collect and process the information you provide to address your inquiry, evaluate your qualifications, and potentially initiate further communication regarding career opportunities. This information may include your name, contact details, resume, and any other relevant data you choose to share. The data will be used solely for the purpose of assessing your suitability for employment and responding to your request.

To collect your personal data, we use the application such as Bamboo, a service of Bamboo HR LLC., Further information of their data protection and compliance can be found by clicking the following links: Bamboo Private Policy and Data processing Agreement.

16. Duration of data storage

Unless otherwise stated, we store usage data or other personal data for as long as we deem it necessary or appropriate to comply with applicable laws, or for as long as we deem it necessary for the purposes for which it is processed. We delete your personal data as soon as they are no longer needed. We are required under applicable law to retain your personal data for 5 years after the last transaction for you has been carried out.

17. Data security

We have technical and organizational security procedures in place to maintain the security of your personal data and to protect your session data and personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access. These are adapted to the current state of the art. However, you should always be aware that there are inherent security risks in transmitting information via the Internet and other electronic means, and that we cannot guarantee the security of any information transmitted in this way.

18. Rights of the data subject

You are entitled to the following rights, depending upon our reason for processing your information:

• Right of access – you have the right to ask us for copies of your personal information.
• Right to rectification – you have the right to ask us to rectify information you think is inaccurate or incomplete.
• Deletion – you have the right to ask us to erase your personal information, provided we are not bound to retain such information following applicable laws.
• Right to object to processing
• Restriction of processing – you have the right to ask us to restrict the processing of your information.
• Data transferability – you have the right to ask that we transfer the information you gave us from one organization to another, or give it to you.

Furthermore, you have the right to object at any time to the processing based on your consent or our legitimate interests. 

You also have the right to pursue your claims through the courts or to lodge a complaint with the competent data protection authority. According to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or of an alleged infringement of the GDPR. For a list of supervisory authorities, click here

Please note, however, that we reserve the right to assert the restrictions provided for by law, for example if we are obliged to store or process certain data, if we have an overriding interest in doing so (insofar as we are entitled to invoke this) or if we need them for the assertion of claims.

The exercise of such rights usually requires that you clearly prove your identity, where your identity is otherwise not clear or cannot be verified (e.g., by means of a copy of your identity card). To assert your rights, you can contact us at: GDPR@own.solutions

19. Amendment of the Privacy Policy

We may change this Privacy Policy at any time without notice. If we have stored your email address as part of any previous contact, we will provide you with a notification of such changes by sending you a notice to your contact details. The current version published on our website applies. If the Privacy Policy is part of an agreement with you, we will notify you by e-mail or other appropriate means if we update it.