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Notice of Privacy Shield Certification

Oro Inc. complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, including personal information Oro Inc. receives from individuals who visit Oro websites or interact with Oro Inc., as well as personal information stored and processed by customer’s instances hosted in OroCloud.

Oro Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Types of Personal Information Oro Inc. Collects and Uses

The categories of personal information Oro Inc. receives in the United States, the purposes to collect and use of the personal information are listed in the Oro Inc. Privacy Policies available at https://oroinc.com/privacy-policy.

Oro will only process personal information in the ways that are compatible with the purposes listed in the Privacy Policies. Oro Inc. will notify users about any changes to the Privacy Policies, including the changes to private data processing and purposes, providing an opportunity to opt-out.

The purposes and categories of personal information collected and processed in customer’s instances hosted in Oro cloud can vary depending on customer implementation and is described in the corresponding privacy policy of the customer site. Oro Inc. can access this personal information on behalf of the customer in order to fulfill customer’s support request and provide the contracted level of service.

General Use of the Site

We do not currently require you to provide Personal Information in order to have access to general information available on the Site other than in order to post comments on the User Communication Platforms. ORO reserves the right to change such matter from time to time, as set forth herein.

What Personal Information We Collect and How We Collect It

We receive and/or collect Personal Information from you in the following ways:

  1. Account. In order to provide you with certain services that we may offer through the Site, we may request that you register an account (“Account”). For example, such an Account may be required in order to post a comment onto the User Communication Platforms. As part of the Account registration process, you will be asked to provide us certain mandatory Personal Information such as your user name, first name, phone number, email address, company name, a password that you will use in connection with your Account, and other designated information. You may also choose to provide your fax number, date of birth, job title, website, country, a company contact person, and other information. We do not intend to make any of your Account information publicly available on the Site other than if you comment on the User Communication Platform, then we may display a partially obscured version of your user name on the Site as part of the User Communication Platform.
  2. ‘Contact Us’ or ‘Update’ request Information. If you send us a “contact us” request or “request to receive updates” we will receive and store a copy of your name, email address, telephone, and country, as well as any other Personal Information that you choose to disclose.
  3. Log Files. The Site may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the site, track user’s movement around the Site, and gather demographic information.
  4. Cookies and Other Tracking Technologies. Some of our Site pages may utilize “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example, to collect information about Site activity. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a Site user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. If you block or delete “cookies” you may find the usefulness of our Site or parts of it to be impaired

Use of Personal Information

If you submit Personal Information to us through the Site, Account User Submissions or any other way, then such Personal Information may be used in the following ways:

  1. We will use your Personal Information to provide (and improve) the Site and our related services to you, to contact you in connection with the Site and its related services (including for the purpose of notifying you about our offers, products and/or services) and to identify and authenticate your access to the parts of the Site and the related services that you are authorized to access, such as the User Communication Platforms.
  2. We may use your Personal Information to contact you in response to a “contact us” request or an “update” request.
  3. We may provide Personal Information to our subsidiaries and affiliated companies for the purpose of processing or storing such information on our behalf. Such information may be transferred to other countries around the world. We require that these parties agree to process such information in compliance with our Privacy Policy.
  4. We may share your Personal Information with our third party service providers (such as a hosting provider, service provider or a payment processor), but only to assist us with our business operations and to provide the Site and its related services. Such information may be transferred to other countries around the world. We use commercially reasonable efforts to only engage or interact with third party service providers that post a Privacy Policy governing their processing of Personal Information.
  5. We may disclose your Personal Information or any information you submit, if we have a good faith belief that disclosure of such information is reasonably necessary, to: (i) comply with any applicable law, regulation, legal process or governmental request, (ii) enforce our Terms including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, and/or (iv) protect against harm to the rights, property or safety of ORO, its users, yourself or the public.

Use of Anonymous Information

We may use Anonymous Information or disclose it to third party service providers in order to provide and improve our Site and to enhance your experience with it. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners, for purposes including, but not limited to, targeted advertisements. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Site.

Opt-out

We may use your email address to send promotions, updates, a newsletter or news regarding our Site, service and products. You may choose not to receive future emails from us by pressing an unsubscribe link added at the bottom of each email that you receive from us or by sending a single email with the subject “BLOCK” to show email. Please note that the email must come from the email account you wish to block. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Site or the Account. If you wish to delete or deactivate your Account you can contact us at show email and include adequate details of your request. Your email must contain the following topic: “DEACTIVATION OF ACCOUNT”

Changes to Your Personal Information

To the extent that you do provide us with Personal Information, please ensure that it remains accurate. If your Personal Information changes, or you wish to remove or modify certain Personal Information that we are storing, you may either correct or update it by logging-in to your Account and making the change(s), or by contacting us at show email. Your email should include adequate details of your request and also contain the following email topic: “PERSONAL INFORMATION UPDATE REQUEST”. We will provide initial responses to such requests within a reasonable period of time.

Choice

At all times, you may choose whether or not to provide Personal Information to ORO. The notices that we provide on the Site in circumstances where we collect Personal Information should help you make this choice. If you choose not to provide the Personal Information we request, you can still use the Site, but you may be unable to access certain options, offers, and services that involve our interaction with you.

Data Transfers to Third Parties

In order to perform business tasks Oro Inc. may transfer private information to the following sub-processors:

Entity name Location
Google LLC United States
Sendgrid Inc. United States
Atlassian Inc. United States

Additional sub-processors may be used by the owner of a particular customer’s instance and listed in the Privacy Policy of the corresponding customer site.

If Oro has received end user’s personal information in the United States and subsequently transferred that information to a third-party acting as an agent, and such third-party agent processes user’s personal information in a manner inconsistent with the Privacy Shield Principles, Oro Inc. may be responsible under the Privacy Shield Principles if Oro Inc is responsible for the event giving rise to the damage.

Disclosures for National Security or Law Enforcement

Under certain circumstances, Oro Inc. may be required to disclose end user’s personal information in response to lawful requests by public authorities, including, to meet national security or law enforcement requirements.

Access Rights

A user may have the right to access personal information that Oro Inc. stores and request to correct, amend, delete it if it is inaccurate or processed in violation of Privacy Shield. These access rights may not apply in some cases, including the ones, where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of a third party. In order to request access to, correction, amendment, or deletion of personal information, a user can submit a written request to the privacy@oroinc.com. Oro Inc. may ask for additional confirmation of the user’s identity. Because Oro Inc. personnel has a limited ability to access data of Oro customers, users need to provide customer name or website URL that stores and processes their private data. Oro Inc will transfer this request to the specific customer and assist as needed in the fulfillment process.

A user may choose to change personal information or deactivate an account by contacting Oro Inc. via email show email.

Questions or Complaints

In compliance with the Privacy Shield Principles, Oro Inc. commits to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Oro Inc. at:

show email

Oro Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Oro Inc. commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner. EU and Swiss individuals can contact EU DPA or the Swiss Federal Data Protection and Information Commissioner, as applicable. The contact details of the EU DPAs can be found here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

EU and Swiss individuals may also have the option to select binding arbitration for the resolution of complaint under certain circumstances. To find out more about the Privacy Shield’s binding arbitration scheme please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Changes to this Notice

Oro Inc. reserves the right to amend this Notice from time to time consistent with Privacy Shield requirements.

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