Privacy Policy - September 2021

Privacy Policy

Last Updated Sep 1, 2021

This Privacy Policy (“Policy”) describes and governs the information collection, use, and sharing practices of ORO Labs, Inc. (collectively, “ORO Labs,” “we,” “us,” and “our”) with respect to your use of the ORO Labs platform, through both the ORO Labs website and mobile application (together, the “Services”).

This Policy does not apply to information we process as a data processor or service provider on behalf of your customers. For example, we may, on behalf of your employer, request that you provide us with access to photographs or your location. ORO Labs does not control how customers use information ORO Labs processes on their behalf, and you should consult with the applicable customer to understand how they use information they receive from ORO Labs.

Before you use or submit any information through or in connection with the Services, please carefully review this Policy. By using any part of the Services, you acknowledge that ORO Labs will collect, use, and disclose your information as further outlined in this Policy. We will continue to evaluate this Policy as we update and expand the Services and our offerings, and we may make changes to the Policy accordingly. Any changes will be posted here and you should check this page periodically for updates. If we make material changes to this Policy, we will provide you with notice as required by law. Your continued use of the Services will signify acceptance of the terms of the updated policy.

Information we collect

We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as from your browser or device.

Information you provide directly to us

We may collect information from you in a variety of ways, such as when you:

Information that is passively or automatically collected

Our Services may include chat rooms, forums, message boards, news groups and other community tools available to our users. Please remember that any information that is disclosed in these areas becomes public information for both us and other users to use and share. Please be considerate and respectful of others while using the community to share your opinions. We reserve the right, but do not have the obligation, to review and monitor such posting or any other content on our Services, and to remove postings or content that may be viewed as inappropriate or offensive to others.

Device/Usage Information

We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze information such as (a) IP addresses, geolocation information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Services, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

Cookies and Other Electronic Technologies

We may also collect data about your use of the Services through the use of Internet server logs, cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather additional information through other methods.

You can find out more information about how we use cookies and other similar tracking technologies in our Cookie Statement.

Location Information

We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information and features (e.g., to notify you of available shifts at nearby locations). In order to do this, your location information may be shared with our agents and vendors. If you do not want us to provide you with these location-based features, you may disable them through your settings in the Services.

Information Provided By Your Employer and Others

When your employer signs up to use the Services, your employer may provide basic information about you, such as your name and email address, so that we can contact you about signing up to use the Services.

We may also obtain information about you, such as demographic information, from various third parties, such as marketers, partners, and researchers.

How we use your information

We may use the information we collect from and about you for the following purposes:

Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy.

When we disclose user information

ORO Labs may disclose and/or share your information to or with any non-affiliated third parties under the following circumstances:

Analytics and Advertising

Analytics — We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology previously described in the “Cookies ORO LABS INC and other electronic technologies” section to help us analyze how users use the Services, including by noting the third-party website from which you arrive, and provide certain features to you. We may use these service providers to collect on a real-time basis information on how you use and navigate our websites. This may include mouse movements and how you scroll through our website, but we do not collect keystroke data.

Advertising — The Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use. These cookies and other tracking technologies may be placed on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our websites and other sites and (b) report how our marketing content impressions, other uses of marketing services, and interactions with these marketing impressions and marketing services are related to visits to our websites.

Notice Concerning Do Not Track Signal

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

Updating your information and other choices

Updating Information: In order to ensure that the information we maintain is accurate, you may access certain of your information and delete, change, or modify that information in accordance with applicable laws by editing your user profile or by contacting us through this form or at privacy@oroLabs.ai.

Data Retention

We will retain your information for as long as needed to continue offering the Services to you or until you delete or modify your information. However, if you have engaged in any public sharing of information prior to deletion, that information will remain on our services and accessible to the public.

Security

We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

Consent to Transfer

We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

Third Party Links and Services

The Services may contain links to or “frame” third-party websites, applications and other services (e.g., including retailers or merchants where you can make purchases). Please be aware that we are not responsible for the privacy practices of such other sites and services.