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Online Services Privacy Policy

Effective date: December 16, 2024

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
  • Information We Collect About You
  • How We Use Your Information
  • How We Share Your Information
  • How to Manage Your Information
  • Protecting Your Information
  • Additional Rights for California Residents
  • State Consumer Privacy Notice (CA)
  • Changes to This Policy
  • Contact Us

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:
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  • 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

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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”):

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  • 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.

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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.

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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.
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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.

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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.

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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.  

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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").  

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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.

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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.

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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.

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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:

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  • 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.

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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.

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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.

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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.

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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.

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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.

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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.  

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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.

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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.

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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.

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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:

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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 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
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
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 No None
Purchase Information – Purchase information, such as products and services obtained and transaction histories No None
Biometric Information – Biometric information, such as fingerprints and voiceprint No 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 No 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 No 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 No None

2. PI Does Not Include

PI does not include:

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  • 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:

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  • 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:

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  • To respond to an email or particular request from you
  • To communicate with 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.

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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

  1. 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
  2. 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.
  3. You have the right to request that we delete any PI about you that we have.
  4. You have the right to request a correction of any inaccurate information in the PI we collect about you.
  5. You have the right to stop us from sharing your PI to display advertisements to you based upon your activities, preferences, and interests.
  6. 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.
  7. 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.
  8. 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.

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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.

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Last Revised: December 16, 2024

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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

December 16, 2024

ORO logo

info@oroimpact.com

818-676-9646

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