Privacy

The Effective Date of this Privacy Policy is January 1st, 2019.

Who we are

Your personal information is collected by AURA Devices Inc., registered at 1013 Centre Road, Suite 403-B, Wilmington, DE 19805, USA ("we"/"us"/"our"). We respect your privacy and value the trust you place in us when you share your personal information with us. This Privacy Policy sets out how we collect and use your personal information.

If you have questions in relation to this Privacy Policy, our details are set out in the “How to Contact Us” section at the end of this notice.

Data collection and usage

We will collect, store and use your personal information to:

The table below explains what information we collect and how and why we use it.

What information we collect How we use your data Why we use your information

1. We collect your personal information in a number of ways:

  • when you set up a user account;
  • when you buy our products; and
  • when you subscribe to email updates, newsletters or other subscriptions and features made available on our website or app from time to time.

Specifically, we collect personal information you give us such as your name, address, phone number, date of birth, gender, e-mail address, password, account settings and preferences.

We use this information to:

  • create an account for you to use our website and app;
  • provide our products;
  • manage and administer our systems;
  • help us ensure that our customers are genuine and to prevent fraud;
  • send you marketing communications including push service notifications;
  • share this information with third parties if you have provided your consent to this.

We use this information because:

  • this is necessary to enter into or perform our contract with you;
  • this is necessary to comply with legal or regulatory requirements;
  • we have a legitimate business interest to:
  • tell you about the various products and services we can offer;
  • understand how you use our app and website;
  • understand the type of products our customers buy and how they use them;
  • understand and respond to customer feedback;
  • research and analyse the services our customers want; or
  • improve our products and services.

In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.

2. Information about the way you use our products and services:

  • the content that you have viewed;
  • the things that you've purchased;
  • when and where you have accessed content and/or made the purchases (including where information can be identified from your IP address);
  • what you paid and how;
  • whether you've opened electronic communications from us;
  • whether you've clicked on links in electronic communications from us;
  • your marketing preferences;
  • our app makes use of GPS tracking (with your consent);
  • our app may (with your consent) access the photos and videos that you store on your device; and
  • our app may use push notifications to send you notifications.

We use this information to:

  • identify products and services that may be of interest to you (e.g. offering recommended relevant products to you);
  • monitor the way our website and app are used;
  • to provide you with location-based functions;
  • to allow you to upload your photos and videos for use in the app;
  • to send you notifications regarding the app;
  • personalise our service to you to:
  • provide you with, make available, and show you more of the things which interest you, based on your activity and feedback;
  • do statistical analysis and research;
  • improve our services and efficiency of service delivery;
  • develop new products and services based on what we learn from your activity and the activity of other customers.

We use this information because:

  • this is necessary to enter into or perform our contract with you;
  • we have a legitimate business interest to:
  • tell you about the various products and services we can offer;
  • understand how you use our products, app and website;
  • understand the type of products our customers buy and how they use them;
  • understand and respond to customer feedback;
  • research and analyse the products our customers want;
  • improve our services;
  • ensure that we are better able to personalise our offers to you.
  • In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.

3. Information that you give us to make an online purchase, including:

  • your contact details including your name, address and email address;
  • your bank account details;
  • the details you provide to open an online account with us;
  • the product(s) purchased.

We use this information, including to:

  • process your order;
  • take payment from or give you a refund;
  • on-board you as a customer;
  • provide our products and services;
  • manage and administer our services;
  • help us ensure that our customers are genuine and to prevent fraud; and
  • send personalised offers or shopping ideas which are based on your shopping habits.

We use this information because:

  • this is necessary to enter into or perform our contract with you;
  • this is necessary to comply with legal or regulatory requirements;
  • we have a legitimate business interest to:
  • tell you about the various products and services we can offer;
  • understand how you use our products, app and website;
  • understand the type of products our customers buy and how they use them;
  • understand and respond to customer feedback;
  • improve our services and better understand how our customers use them; or
  • ensure that we are better able to personalise our offers to you.
  • In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.

4. Information when you communicate with us whether in person, through our website or app, via email, over the phone, through social media or via any other medium, and/or use our app via your social media account including:

  • your contact details (this may include your social media account if that's the way you communicate with us or use our app via your social media account);
  • the details of your communications with us (including when you sent it, when we received it and where you sent it from (such as our website, app, via email, through social media)); and
  • the details of our messages to you.

We use this information, including to:

  • answer any of your issues or concerns;
  • provide you access to use our app
  • monitor customer communications for quality and training purposes;
  • develop new services which is based on the information your provide;
  • improve our services based on the information and feedback you provide; and
  • personalise our service to you to take account of the information and feedback you have provided.

We use this information because:

  • this is necessary to enter into or perform our contract with you;
  • this is necessary to comply with legal or regulatory requirements;
  • we have a legitimate business interest to:
  • understand customer feedback and respond to customer communications in a consistent manner;
  • ensure that we are better able to personalise our offers to you;
  • research and analyse the products and services our customers want;
  • provide security over our business and who we trade with;
  • prevent and detect fraud; or
  • verify customer details.

In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.

5. Information that we collect through your use of the website and app:

  • technical information, including IP address, login information, browser type and version (e.g., Internet Explorer, Firefox, Safari, etc.), time zone setting, browser plug-in types and versions, operating system you are using (e.g., Vista, Windows XP, Mac OS, etc.), platform, device type, hardware model, MAC address, unique device identifiers and mobile network information;
  • information about your visit, including the full URL clickstream to, through and from our website (including date and time);
  • information about your network, such as information about devices, nodes, configurations, connection speeds, and network and application performance; and
  • pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

We use this information to:

  • provide our products and services;
  • provide and adapt our services to take account of the technical capabilities of our users and to ensure content is presented in the most effective manner;
  • analyse site traffic and understand customer needs and trends;
  • improve our products and services;
  • identify products and services that may be of interest to you (e.g. by offering recommended relevant products to you);
  • develop new products and services;
  • identify issues with the website;
  • do statistical analysis and research;
  • monitor the way our website is used; and
  • combine this information with other types of information mentioned above to allow us to make our services more personal and tailored to each customer's preferences and habits.

We use this information because:

  • this is necessary to enter into or perform our contract with you;
  • this is necessary to comply with legal or regulatory requirements;
  • we have a legitimate business interest to:
  • understand how our customers use our products, app and website;
  • tell you about the various products and services we can offer;
  • ensure network and information security;
  • conduct fraud prevention and detection; or
  • assess the number of visitors, posts, page views, reviews and followers in order to optimise future marketing campaigns.

In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.

6. Information that we collect incidentally from other sources or public sources, including information presented on our social media or wider social media platforms including Facebook, Twitter and Instagram.

We use this information, including to:

  • maintain market awareness; and
  • build and maintain social media brnding.

We use this information because:

  • this is necessary to enter into or perform our contract with you;
  • this is necessary to comply with legal or regulatory requirements;
  • we have a legitimate business interest to:
  • maintaining a public profile within the media;
  • maintaining the accuracy of data we hold; and
  • conducting research to improve our products and services.

In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.

7. Special categories of information that you give when using our services, including specifying your health and biometrics data which may imply your medical condition.

We use this information to provide our products and services.

Some personal information is treated as falling into a special category. This includes information about health, disability, race, ethnicity,, political opinions, biometrics or religion and used to be known as sensitive personal data.
We will use your health data only where:

  • this is necessary to enter into or perform our contract with you; or
  • we have your explicit consent for the relevant purpose.

How long do we keep your information

We will retain personal data of individuals covered by this Privacy Policy for as long as required to perform the purposes for which the data was collected, depending on the legal basis on which that data was obtained and/or whether additional legal/regulatory obligations require us to retain the personal data. In general terms, this will mean that personal data will be kept for the duration of our relationship with the individual and as long as it is necessary for individuals to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under applicable law.

In certain circumstances, personal data may need to be retained for longer, for example, where we are in ongoing correspondence or there is a continuing claim or investigation.

Information we share

There are certain circumstances where we transfer your personal data to other parties.

Your personal data may also be shared with third parties if it is made anonymous and aggregated. In such circumstances the information will cease to be personal data.

Where your information will be held

The information that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA), including the USA, which does not have equivalent data protection laws to those applicable to Europe. It may also be processed by staff operating outside the EEA who work for us, for one of our affiliated companies, or for the organisations that host our website and app.

We will only transfer data to jurisdictions outside the scope of the European General Data Protection Regulation (GDPR) where the appropriate safeguards set out in the GDPR are in place. For example, transfer of this information may be governed by a contract including Standard Contractual Clauses approved by the European Commission in accordance with Article 46(2)(c) of the GDPR.

Please contact us using the details set out below if you want further information on the countries to which we may transfer personal data and the specific mechanism used by us when transferring your personal data outside the EEA.

Your rights

You have certain rights in relation to your information. Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please submit your request by emailing us using the contact details set out below and provide sufficient information to allow us to understand the scope of the request. Your rights are as follows:

  1. Consent: if our processing is based on consent, you can withdraw your consent at any time by emailing us using the contact details set out below.
  2. Access: you can ask us if we are processing your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and certain other information about it.
  3. Correction: you can request that any incomplete or inaccurate personal data we hold about you is corrected.
  4. Erasure: you can ask us to delete or remove personal data in certain circumstances. In certain cases we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
  5. Restriction: you can ask us to suspend the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it.
  6. Transfer: you can request the transfer of your personal data to another third party in limited circumstances.
  7. Objection: where we are processing your personal data based on legitimate interests (or those of a third party) you may challenge this. However we may be entitled to continue processing personal data based on our compelling legitimate interests or where this is relevant to legal claims. You can also has object if we are processing your personal data for direct marketing purposes.
  8. Automated decisions: you can contest any automated decision made about you where this has a legal or similarly significant effect and ask for it to be reconsidered.
  9. Supervisory Authority: you can lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where you work or where an alleged infringement of Data Protection Legislation has taken place. For example, in the UK you can make a complaint to the Information Commissioner's Office (Tel: 0303 123 1113 or at www.ico.org.uk).

Direct marketing

We may use the information you give us on our website or app for direct marketing purposes to provide updates, newsletters, events or other communications that we think may interest you. We will only do this with your consent (where required by law).

You can opt-out of receiving direct marketing from us at any time. You can do this by clicking on the "unsubscribe" link included at the end of any marketing email we send to you, or by emailing us using the contact details set out below. California Civil Code permits California residents to request that we do not share your personal information with third parties for their direct marketing purposes. If you are a California resident, you may contact us to request information regarding how we share personal information with third parties for their direct marketing purposes and/or to request that such information not be shared with third parties for such purposes.

Cookies

Our website and app use cookies to distinguish you from other users and to keep track of your visits. They help us to provide you with the very best experience when you browse our website or use our app and to make improvements to both. They also help us and our advertising networks to make advertising relevant to you and your interests.

Third parties that are unaffiliated with us may also collect information about you, including tracking your browser history, when you use our website or app. We do not have control over the collection practices of these third parties.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For detailed information on the cookies which we and our service providers use and the reasons why we use them, please refer to our Cookie policy.

Security

We are committed to keeping your personal information safe. We have got physical, technical and administrative measures in place to prevent unauthorised access or use of your information.

Links to third party websites

Our website, app, newsletters, email updates and other communications may, from time to time, contain links to and from third party websites. The personal data that you provide through these websites is not subject to this Privacy Policy and the treatment of your personal data by such websites is not our responsibility. Please read their privacy policies to find out how they collect and process your personal information



Children

While our website is designed for a general audience, we will not knowingly collect any data from children under the age of 13 or sell products to children. If you are under the age of 18, you are not permitted to register an account with, use or submit your data to the website.

If we discover that we have collected any personal information from a child under the age of 18, we will suspend the associated account and remove that information from our database as soon as possible.

If you believe we might have any personal information from or about a person under the age of 18, please email us using the details set out below.

Changes to this Privacy policy

From time to time, we may change and/or update this Privacy policy. If this Privacy Policy changes in any way, we will post an updated version on our website, and we will update the Effective Date included at the top of the Privacy Policy. If we change anything important about this Privacy Policy (the personal data we collect, how we use it or why) we will highlight those changes at the top of the Privacy policy and provide a prominent link to it for a reasonable length of time before the change.

We recommend you regularly review our website to ensure that you are always aware of our data practices and any changes. Any changes to this Privacy policy will go into effect on posting to this website.

How to contact us

If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy and wish to make a complaint, please contact us as set out below. We will do our best to resolve your complaint.

If you have any questions about this Privacy Policy please contact us by emailing support@auradevices.io