Privacy Policy | ORO IMPACT

Online Services Privacy Policy

ORO Impact Inc. (hereinafter “Company,” “we,” “us,” and “our”) recognizes that the privacy of your information is important and we are committed to protecting your personal information. This Online Services Privacy Policy (“Policy”) describes our practices related to information we collect through our online and mobile websites, platforms, services, and applications or through your online interactions with us (collectively, “our Online Services” or “the Online Services”). Any information you provide, including any personal information, will be transferred to and processed by a computer server located within the United States.

By using the Online Services, you consent to our collection, use, disclosure, and storage of information as described in this Policy.

Contents

When This Policy Applies

This Policy applies to Online Services that we own or operate. This Policy does not apply to information collected through other means such as by telephone or in person. In some circumstances we may provide you with additional or supplemental privacy notices to the extent they apply to you because of the interactions you may have with the Online Services or different laws that may apply to you. If you are a resident of California, please refer to the Additional Rights for California Residents section below.

This Policy does not apply to the practices of other companies or other websites or software applications that may be linked from or made available through our Online Services. The inclusion of a link on our Online Services or the ability to utilize a third-party website or software application through our Online Services does not imply that we endorse or otherwise monitor the privacy or security practices of that third-party website or software application or the accuracy of its content, and your use of the third-party website or software application is governed by the third-party's privacy policy.

This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

Information We Collect About You

We collect two types of information through the Online Services: (1) information you provide to us and (2) information that is automatically provided to us or collected through your use of the Online Services (collectively, “Information”).

Information You Provide Us: The information we collect directly from you could include:

Name
Email address
Phone number
Mailing address
Geolocation data
Employment information
User ID
Any other information you choose to provide
Any other information described in this Policy

You may limit the Information you provide or make available to us; however, that may limit your ability to access or use certain functions of the Online Services or to request certain services or information.

Information Collected Automatically: We also may obtain Information that is automatically collected through the Online Services. We automatically receive and record information in our server logs from your browser, including your IP address, search queries, cookie information, mobile device identification, GPS or location data, carrier network location, and the listings and pages you request. We may also record the details of your activity on the Online Services. This information may be used by us to develop new services or improve the Online Services and may be shared with third parties in order to do so.

You may withdraw consent to use precise, real-time, or network location data at any time by turning off the location-based feature on your mobile device or by not using any location-based features. If you withdraw your consent, functionality associated with precise, real-time, or network location will no longer work.

How We Use Your Information

In addition to the uses set forth above, we may use information that you provide to us or that we collect about you, including any personally identifiable information (“PII”):

To present the Online Services to you;
To provide you with content, services, and functionality through our Online Services for other services that we may offer;
To provide you with information or services that you request from us;
To fulfill any other purpose for which you provide Information;
To personalize your experience on our Online Services;
To process an application for a product or service as requested by you;
To communicate with you regarding the Online Services;
To provide you with promotional information regarding the Online Services;
To notify you about changes to the Online Services or any services we offer or provide through the Online Services;
To allow you to participate in interactive features of the Online Services;
To authenticate you on any portion of our Online Services and with vendors acting on our behalf;
To perform analytics and to improve our products, Online Services, and advertising;
To facilitate the provision of software updates and product support;
To administer surveys and promotions;
To provide you with informational or promotional offers, as permitted by law, that we believe may be useful to you, such as information about products or services provided by us or other businesses;
To conduct research and development for the improvement of the Online Services and the development of new services and offerings and in connection with our business;
To comply with applicable laws, regulations, and legal process;
To keep a record of our transactions and communications; and
In any other way we describe when you provide the information, or for any other purpose with your consent.

We may use Information to contact you through any contact information you provide through our Online Services, including any email address, telephone number, cell phone number, or fax number. We may communicate, electronically or via telephone with you about our products and services or services that are or may be available to you in connection with your transactions with us including, but not limited to, Online Services updates, newsletters, and surveys. You acknowledge and accept that such communications may be sent unencrypted and there is some risk of disclosure or interception of the contents of these communications.

We may, when permitted, combine your Information with other information, whether online or offline, maintained or available to us from you or from other sources, such as from our vendors, and we may use and disclose combined data for the purpose described in this Section or for internal business purposes. We may, when permitted, use and disclose de-identified and aggregated data for any purpose, which may include, without limitation, disclosures to third parties for analytics purposes such as evaluating the Online Services and providing additional benefits, programs, and services.

How We Share Your Information

We will only share your Information with third parties as outlined in this Policy and as otherwise permitted by law or as permitted with your consent.

We may share Information if all or part of the Company is sold, merged, dissolved, acquired, or disbanded to any extent in a similar transaction, or in connection with steps that may need to be taken in anticipation of such events.

We may share Information in response to a court order, subpoena, search warrant, or to comply with law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting activities that are illegal, violate our rules, or may be harmful to other visitors.

We may share Information within the Company. We may also share Information with third-party companies with which we have a business relationship or hire to perform services on our behalf. For example, we may hire a third-party company to help us send and manage email and online chat, and we may provide that third-party company with your email address and certain other Information for them to send you a message on our behalf. Similarly, we may hire third-party companies to host or operate some of our Online Services and related computers and software applications.

We will not sell or rent the Information to any third parties for the purposes of third-party advertising to you.

How To Manage Your Information

Our Online Services may permit you to view your profile, if applicable, and access related Information about you and to request changes to such Information. Please remember, however, if we have already disclosed some of this Information to third parties, we may not have access to that disclosed information and may not be able to force the modification of any Information by the third parties to whom we have made those disclosures.

Communication Preference Management: We may offer mobile applications that enable us to communicate with you through push notifications. Where mobile applications are offered, you may be able to manage push notifications in your mobile phone or tablet settings. You may also be able to control preview settings in your email applications. If you need assistance in opting out of a communication, please contact us at: help@oroimpact.com.

Cookies and Tracking: The Company may use various technologies, including cookies, tokens, tags, web logs, web beacons, scripts, and web server logs to gather automatically collected information and may aggregate this information from visitors of our Online Services or to enable certain features of our Online Services. This information may include demographic data, technical information about the technology (e.g., phone, computer) you use to connect to the Online Services, web browser information, your IP address, and browsing behavior such as pages visited and how often they are visited (collectively, "Activity Information"). We may also use third-party analytics companies to provide these services.

We may also allow third parties to use cookies and other technologies to collect Activity Information and to track browsing activity over time and across third-party websites such as web browsers used to read our Online Services, which websites are referring traffic or linking to our Online Services, and to deliver targeted advertisements to you. We do not control these third-party technologies, and their use of such technologies is governed by their own privacy policies. For more information about third-party advertising networks and similar entities that use these technologies, see youradchoices.com/control, and to opt-out of such ad networks' and services' advertising practices, go to optout.aboutads.info and optout.networkadvertising.org. Once you click the links, you may choose to opt out of such advertising from all participating advertising companies or only from advertising provided by specific advertising companies. Please note that, to the extent advertising technology is integrated into the Online Services, you may still receive advertisements even if you opt out of tailored advertising. In that case, you may still receive ads, however the ads will not be tailored. 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.

Activity Information is captured using various technologies and may include cookies. “Cookies” are small text files that may be placed on your computer or mobile device when you visit an Online Service or click on a URL using your web browser. Cookies may include “single-session cookies” which generally record information during only a single visit to a website and then are erased, and “persistent” cookies which are generally stored on a computer or mobile device unless or until they are deleted or are set to expire. You may disable cookies and similar items by adjusting your browser preferences at any time; however, this may limit your ability to take advantage of all the features on our Online Services.

We will comply with web browser “do not track” signals that you may set in your web browser regarding the collection of PII about your online activities over time and across third-party websites or online services, as recognized by many state Attorneys General. You may also opt out of these practices at any time by clicking the “Do Not Sell/Share My Personal Information” link available on our website or within our dedicated Privacy Center.

We gather Activity Information about you to improve the quality of our services, such as the best method and time to contact you. Without limiting the other ways in which we may use Information as described herein, we may otherwise use and disclose your Activity Information unless restricted by this Policy or by law. Some examples of the ways we use your Activity Information include:

Customizing your experiences, including managing and recording your preferences;
Authenticating your account information;
Marketing, product development, and research purposes;
Tracking resources and data accessed on the Online Services;
Developing reports regarding Online Service usage, activity, and statistics;
Assisting users experiencing problems with our services;
Updating and servicing our Online Services;
Enabling certain functions and tools on the Online Services; and
Tracking paths of visitors to the Online Services and within the Online Services.

As described above, we may use tracking technologies that allow us to recognize your device when you return to the Online Services within a period of time, as determined by us, and to support automatic login to your Online Services. We may also use tracking technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We collect this information for both IT debugging purposes, and to provide us with valuable information used when considering possible web and mobile enhancements.

Retention of Data: We will retain your personally identifiable information (PII) and Activity Information for as long as is necessary for the purposes set out in this Policy. We will retain and use your PII to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Protecting Your Information

We maintain administrative, technical, and physical safeguards designed to protect the Information that you provide on our Online Services. These safeguards vary based on the sensitivity of the Information collected, used, and stored. We cannot guarantee the security of our Online Services, nor can we guarantee the security of the Information you transmit to us over the internet, including your use of email. We are not liable for the illegal acts of third parties such as criminal hackers.

It is your responsibility to safeguard the devices you use to access our Online Services (such as laptops, tablets and mobile devices), and to use appropriate security settings on those devices. If those devices are lost, stolen or misplaced, others may be able to access your account and your personal Information using those devices. Where applicable, you should affirmatively log out of the Online Services prior to ending your session or if you will be inactive on the Online Services for more than a few minutes.

You agree that the Company is not responsible for any harm that may result from someone accessing your account or personal Information on any computer or device where you do not, for any reason, take the necessary steps to log out of the Online Services and/or your account prior to ending a session on such device or computer.

We retain Information for as long as necessary for the purpose for which it is collected, subject to a longer period if the Information is relevant to a legal challenge.

Additional Rights for California Residents

California “Shine the Light” Privacy Rights: California law permits California residents to request certain information regarding the disclosure of certain personal information to third parties for their direct marketing purposes.

If we have disclosed any personal information to third parties for direct marketing purposes, we will provide a list of the categories of personal information, along with the names and addresses of these third parties to you at your request. To make such a request, write us at: help@oroimpact.com.

This request may be made once per calendar year. We reserve the right not to respond to requests submitted other than to the specified email address. Please put “California Privacy Rights-Direct Marketing” in the email subject line and in the body of your request. You must provide us with specific information regarding yourself so that we can accurately respond to your request.

California Minors Under 18: If you are a California resident under the age of 18 and are a registered user of our Online Services, you may request that we remove from our Online Services any content you post to our Online Services that can be accessed by any other user (whether registered or not). Please note that any content that is removed from visibility on our Online Services may still remain on our servers and in our systems. To request removal of content under this provision, please write us at: help@oroimpact.com. When you write to us, please provide us with a description of the content and the location of the content on our Online Services, along with any other information that we may require to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Online Services by you.

State Consumer Privacy Notice: This State Consumer Privacy Notice applies to residents of California and sets forth their rights under their respective state's comprehensive privacy laws. This State Consumer Privacy Notice supplements the Policy. It explains what Personal Information (PI) we collect about you, where and from whom we obtain it, why we collect it, and your respective state rights regarding it. If you are a California resident, this notice applies to any PI that we collect about you.

1. Personal Information (PI) We Collect and Disclose for Business Purposes

The PI we collect and/or disclose about a specific California resident will depend on, for example, our relationship or interaction with that individual.

During the past 12 months, for the business purposes described below, we may have collected and/or disclosed the following categories of PI about California residents:

Category of PI

Collected

Third Party to Whom We Disclosed Personal Data for Business Purposes

Personal Identifiers - Personal unique identifiers, such as full name and federal or state issued identification numbers including Social Security number, driver’s license number, and passport number

Personal information – Personal information, including contact details (e.g., telephone number and address), financial information (e.g., account number and balance), payment card details (e.g., credit and debit card numbers), and medical and health insurance information

Yes

Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
Outside companies in connection with routine or required reporting

Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
Outside companies in connection with routine or required reporting

Characteristics of Protected Classes – Characteristics of protected classes or groups under state or federal law, such as sex, disability, citizenship, primary language, immigration status and marital status

None

Purchase Information – Purchase information, such as products and services obtained and transaction histories

None

Biometric information – Biometric information, such as fingerprints and voiceprint

None

Internet or Online Information – Internet or online information (e.g., browsing history) and information regarding interaction with our websites, applications, or advertisements

Yes

Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
Outside companies in connection with routine or required reporting

Geolocation Data – Geolocation data, such as device location

Yes

Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development

Audio and Visual Information – Audio, electronic, visual, thermal, olfactory, or similar information, such as call and video recording

None

Employment Information – Professional or employment-related information, such as work history and prior employer, information from background checks, resumes, and personnel files

Yes

Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development
Outside companies in connection with routine or required reporting

Education Information –
Education information subject to the federal Family Educational Rights and Privacy Act, such as student records and confirmation of graduation

None

Inferences – Inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics

Yes

Outside organizations in connection with providing products and services, completing transactions, supporting our everyday operations, or business management and development

Sensitive Personal Information – Social Security number, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation;
racial or ethnic origin, religious or philosophical beliefs, citizenship, or immigration status; the contents of mail, email, and text messages unless we are the intended recipient of the communication; biometric information processed to uniquely identify an individual; and
health information, sexual orientation

None

2. PI Does Not Include

PI does not include:

De-identified or aggregated consumer information
Publicly available information from government records
PI covered by other privacy laws, including: The Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

3. Categories of Sources of PI

We obtain the categories of PI listed above from:

You or your authorized agent
Service providers
Affiliates
Publicly available information
Organizations with which you are employed or affiliated
Activity on our apps and websites

Collection from these sources may occur online, in person, via paper or other electronic means, and may occur automatically where state law permits such profiling absent an explicit request to opt-out.

4. Why We Collect PI

We collect your PI for one or more of the following business purposes:

To respond to an email or particular request from you
To communicate with you
To personalize services for you
To process an application as requested by you
To administer surveys and promotions
To provide you with information that we believe may be useful to you, such as information about products or services provided by us or other businesses
To perform analytics and to improve our products, websites, and advertising
To comply with applicable laws, regulations, and legal processes
To protect our rights, the rights of affiliates or related third parties, or take appropriate legal action
To keep a record of our transactions and communications
To detect and protect against security incidents
To debug to identify and repair errors
As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law

5. Selling Your PI

We will not sell or rent your PI to any third parties for the purposes of third-party advertising to you. If we seek to use your PI for a materially different purpose than we previously disclosed in this notice, we will notify you and will not use your PI for this new purpose without your explicit consent.

You may configure opt-out preference signals through your web browser utilizing functionality enabled on our website. Use this functionality to opt-out of sharing/selling your PI.

6. How Long We Retain Your PI

We will retain your PI consistent with our internal record-retention policies and for as long as is necessary to provide products and services to you or as required by law.

7. Your Rights

a) You have the right to request that we disclose certain information to you about our collection and use of your PI over the preceding 12 months prior to your request. Once we receive and confirm your verifiable consumer request, we will disclose to you:

What PI we collect about you
Where and from whom we collect PI about you
Our business purpose for collecting PI about you
The types of third parties with whom we share your PI
The specific pieces of PI we collect about you, in a readily-usable format—note that we will not disclose your actual Social Security number, driver's license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers
The types of PI that we disclosed about you for a business purpose, and the categories of third parties to whom we disclosed your PI

b) You have the right to be informed about the PI that we collect about you at the time that or before we collect it. This is that notice.

c) You have the right to request that we delete any PI about you that we have.

d) You have the right to request a correction of any inaccurate information in the PI we collect about you.

e) You have the right to stop us from sharing your PI to display advertisements to you based upon your activities, preferences, and interests.

f) If we use your sensitive PI for purposes other than to render services or offer products to you, you will have the right to request that we limit the processing of your sensitive PI.

g) You will not be discriminated against or penalized for exercising your rights to your PI, and we will honor your rights by not:

Denying you services,
Charging you different prices or rates for services,
Imposing penalties, or
Providing you with a different level or quality of services.

h) Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why and you may appeal this decision (see additional information in Appeals section below).

8. How to Exercise Your Rights

You may exercise your rights by contacting us at: help@oroimpact.com. Please include “CPRA Request” in the subject line of your email. You may be required to submit proof of your identity for your requests to be processed. We will not be able to comply with your request if we are unable to confirm your identity. You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.

9. Timing

Our responses to any of your requests for the information described above will be limited to information that we have collected in the preceding 12 months before our receipt of your verified request. We will acknowledge receipt of your request within 10 days of receipt of your submission. You will receive our response to your request within 45 days of your request, unless we provide you with notice that it will take more than 45 days to respond (in that case, we will not take more than 90 days to respond).

10. Appeals

If the Company denies any of your requests, you may appeal by writing to: help@oroimpact.com. Let us know you are emailing about a CPRA Request Appeal by including “CPRA Request Appeal” in the subject line of your email.

We will respond to your appeal within 45 days of receipt, unless we notify you that we will require an additional 15 days to respond. If you remain concerned about the result of your appeal, you may contact the attorney general in your state of residency.

11. Contact Us

Please contact us at: help@oroimpact.com if you have any questions.

Last Revised: June 4, 2024

Changes to This Policy

We may change this Policy at any time. If we do so, such change will appear on this page. You may always visit this Policy to learn of any updates. Your continued access to or use of the Online Services constitutes your consent to changes to this Policy.

Contact Us

Contact us at: help@oroimpact.com regarding this Policy or related privacy practices. If you believe we or any company associated with us has misused your Information, please contact us immediately.

Effective Date

June 4, 2024