Privacy Policy

Introduction

We are Aro Technology, Inc., a Delaware corporation, or as we like to go by “we”, “our”, “us” or “Aro”, and our mission is to help people experience life, uninterrupted! 

To accomplish this mission, we offer Products (as defined in our Terms of Sale), Services (as defined in our Terms of Service), and technologies allowing our users (“Users”) to engage the life that’s in front of them by setting goals, building habits, and tracking improvements through our website and digital application (“Platform”).  We are committed to protecting our User’s privacy through compliance with this Privacy Policy (“Policy”).

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our Policies and practices, do not use our Platform or purchase our Products. 

How to Contact Us

If you have any questions about our practices or this Policy, please contact us by email at privacy@goaro.com.

Application of this Policy

When you access our Platform or use our Products, you become a User and you agree to this Policy, our Terms of Service and Terms of Sale (collectively, “Policies”).  

This Policy describes the types of information we may collect from you or that you may provide to us when you visit, register, use, or access our Platform or Products, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Information We May Collect or Receive

Our Products, Services, and Platform allow Users to track, manage, and share personal growth, time management, and wellness related Information collected using our Products, including the Aro Box, which is then transmitted, hosted, and stored on our Platform. 

The Information (as defined below) that a User may provide through our Products or Platform is broad.  We may receive Information directly from you when you provide it to us (such as by registering for Membership (as defined in our Terms of Service) on the Platform or uploading such Information to your profile on our Platform) or automatically as you access, use, or interact with our Products or Platform (such as your internet connection, the device you used, or the location of that device). 

There are many occasions when you provide information to us that identifies, relates to, describes, references, or is reasonably capable of being associated with or linked with, directly or indirectly, you, your household, or your device, such as a name, internet protocol (IP) address, or email address (“Personal Information”).  Personal Information may also have the meaning given to that term or similar terms (e.g., “personal data”) under the law law such as the General Data Protection Regulations (EU) 2016/679 (“GDPR”) or the California Consumer Privacy Act (“CCPA”), to the extent those laws are applicable, if at all.

Because Users have the ability to upload a broad range of information on our Platform, we may receive sensitive information such as your date of birth, sex, or similar information (“Sensitive Information”).  We do not require our Users to provide Sensitive Information, but such Information may be, directly or indirectly, collected by us through your use of our Products or Platform.  

Additionally, our Products and Platform may allow you to upload and share information that is not Personal Information or Sensitive Information, such as how you spent your time while your device was enclosed within our Products (e.g., our Aro Box) (“Other Information” and together with Personal Information and Sensitive Information, collectively, “Information”).  Because our Platform allows you to choose the Information associated with your account, we may tie Other Information to Personal Information or Sensitive Information about you.

We may collect or receive from you the Information outlined below:

Third-Party Sources, Cookies, and Other Tracking Technologies

We may also collect or receive Information from third-party sources and the Platform may contain links to other sites.  Any Information you provide on the linked pages is provided directly to that third-party and is subject to their terms and policies.  This Policy does not apply to such linked third-party sites, and we are not responsible for the content or privacy and security practices and policies of these sites or any other sites that are linked to or from our Platform.

Some Information on the Platform may be served by a third-party, including advertisers, ad networks and servers, content providers, and application providers.  These third parties may use cookies in conjunction with web beacons or other tracking technologies to collect Information about you.  The Information they collect may be associated with your Personal Information or Sensitive Information or they may collect Information about your activities over time and across different websites and other online services.  Third parties may use this Information to provide you with interest-based advertising or other targeted content.  We do not control third-party tracking technologies or how they may be used.  If you have any questions about an advertisement or other targeted content, you should contact the responsible provider.

We may collect Information regarding your usage of our Products and Platform, including the links you viewed, time spent using our Platform, demographic data such as server locations, connection speed, and Other Information that does not identify you.  Like most online services, we also use cookies, log files, clear GIFs, tracking pixels, web beacons, and other technologies that may collect Personal Information.

When you visit our Platform, we may send one or more “cookies” – small data files – to your device to uniquely identify your browser/operating system and allow us to help you enhance your navigation of our Platform.  A cookie may convey Information about how you use our Platform or Products so we can provide you with a more personalized experience.  A persistent cookie remains on your device after you close your browser/application so that it can be used by your browser on subsequent visits to our Platform. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser.  Our Platform may use the following types of cookies, logs, web beacons, and other tracking technology:

How Can I Disable Cookies

You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. To do this, follow the instructions provided by your browser (usually located within the “settings”, “help” or “tools” function).  Many browsers default to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Platform and Products and some features of our Platform or Products may not function properly.  For example, we may not be able to recognize your device and you may need to log in every time you visit our Platform.

Visit www.allaboutcookies.org or www.whatarecookies.com for more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them.

Currently, we do not respond to web browsers’ “do not track” signals that provide a method to opt-out of the collection of Information about User activities on the Platform.  If we do so in the future, we will provide relevant information in this Policy.

How We Use Your Information

We use Information that we collect about you or that you provide to us:

• To present our Platform and its contents to you and to personalize and improve our Platform and Products. 

• To provide you with information, products, or services that you request from us.  For example, if you share your Personal Information (e.g., name and contact information) to ask a question about our Products, we will use that Information to respond to your inquiry. If you provide your Personal Information to purchase a Product (e.g., name and delivery information), we will use that Information to process your Order and facilitate delivery.  We may also save your Personal Information to facilitate Orders, process returns, or notify you of our offerings.

• To allow you to participate in interactive features on our Platform or through our Products.  

• To provide you with notices about your Membership, accounts, or subscriptions, including expiration and renewal notices.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to our Platform or any Products.

• To help maintain the safety, security, and integrity of the Platform, Products, databases, and other technology assets.

• For testing, research, analysis, and product development, including to develop and improve our Platform and Products.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• In any other manner we describe when you provide the Information or as otherwise set forth under applicable law.

• For any other purpose with your consent.

Disclosure of Your Information

We may share your Information with third parties to provide our Products, Services, Platform, Content, and their security, or to market or sell our Platform, Products, or Services.  We do not sell your Personal Information.

We may disclose Information that you provide to us or we collect from you as described in this Policy:

In connection with your use of our Platform or Products.  Our Platform and Products allow you to transmit your Information from your Products to the Platform.

To our service providers, affiliates, agents, subprocessors, advertising partners, internet service providers, data analytics providers, agents, and related third parties.  We engage employees, contractors, service providers, agents, and other third parties to support our Platform and Products, including, for example, Platform or Product development, search engine optimization, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, background and compliance reviews, and other services, which may require them to access, process, or use your Personal Information.

To our processors and subprocessors.  We use certain subprocessors and service providers to support our Platform and Products.  A subprocessor is a third-party data processor that we have engaged and will potentially have access to or process your Personal Information.  We engage the following processors or subprocessors:

With your consent or for any other purpose disclosed by us when you provide the Information.

In connection with a business transfer.  We may sell Aro or its assets to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Aro's assets, in which Personal Information may be among the assets transferred.

In fulfilling our legal obligations.  We may disclose your Personal Information to comply with a court order, law, or legal process, including to respond to any government or regulatory request, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Aro, our Platform or Products, or our Users, customers, or third parties.  We may also disclose your Personal Information to enforce or apply our Policies and other agreements, including for billing and collection purposes.

For analytics or research purposes.  We may partner with third parties to collect certain Information to research, analyze, audit, research, and report such Information.  These third parties may use cookies, web beacons, and similar tracking technologies.

Aggregated information or data.  We may disclose aggregated demographic information about our Users and the activity on our Platform or with our Products.

Where We Store Your Information

We maintain our Platform in the United States and market our Products, Platform, and Services in the United States.  The Information that you provide us may be stored, processed, and accessed by us, our employees, contractors, and third parties (including the subprocessors and service providers listed in the Disclosure of Your Information section) with whom we share Information in the United States or elsewhere for the purposes described in this Policy.  We may also store Information in locations outside our direct control (for instance, on servers or databases co-located with hosting providers). By accessing or using our Platform or Products and providing us with your Personal Information, you consent to and authorize the transmission of Personal Information to the United States and its storage and use as specified in this Policy.  The laws of the United States might not be as comprehensive or protective as laws in the country where you live.

How Long We Store Your Information

Unless you request that we remove your Personal Information as described in the Your Rights Related to Your Personal Information section below, we retain your Information for as long as it is reasonably needed for the purposes set out in this Policy.  We will retain your Information for so long as we reasonably believe necessary to use it for these purposes unless a longer retention period is required by law.  This may include keeping your Personal Information for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

• You may request a copy of the Personal Information we hold about you and to check that we are lawfully processing it.  You may request confirmation from us on whether or not we are processing or storing any of your Personal Information. 

• You may request receipt of certain information about our collection and use of your Personal Information.

• You may request that we correct any incomplete or inaccurate Information we hold about you.  You can review and change your Personal Information by logging into the Platform and visiting your account page.  We may not be able to delete your Personal Information except by also deleting your profile or account.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the Information to be incorrect.

• You may request that we delete or remove your Personal Information where there is no proper reason for us to continue to process it. You may also ask us to delete or remove your Personal Information where you have exercised your right to object to processing.  Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the Information applies.

• If we are relying on a legitimate interest as the legal basis for our processing and there is something about your situation, which makes you want to object to processing of your Personal Information, you may object to such processing.

• You may request us to provide you, or a third-party you have chosen, your Personal Information in a structured, commonly used, machine-readable format.

• If we are relying on consent to process your Personal Information, you have the right to withdraw your consent.  If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Platform or Products. 

How to Exercise Your Rights

If you want to exercise any of the rights described above, please contact us by email at privacy@goaro.com.  

Only you, or someone legally authorized to act on your behalf, may make a request to know, access, or delete your Personal Information.  We may need specific information from you to help us confirm your identity and ensure your right to access such Personal Information (or to exercise any of your other rights).  This is a security measure to ensure that Personal Information is not disclosed to any person who does not have the right to receive it.  

We will confirm receipt of your request within ten (10) business days.  We try to respond to all legitimate requests within one (1) month of our receipt.  Occasionally, it may take us longer than one (1) month if your request is complex or you have made a number of requests. In such a case, we will notify you and keep you updated on the status of your request.  We retain the right to respond within longer timeframes set forth under applicable law or as reasonably necessary.

For data portability requests, we will select a format to provide your Personal Information that is readily usable and allow you to transmit the Information from one entity to another entity without hindrance.

If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

How We Protect Your Information

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.  All Information you provide to us is stored on our secure servers. Any payment transactions are processed through Stipe, in accordance with their respective terms and security protocols. 

The safety and security of your Information also depend on you.  Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential.  You should not share your password with anyone. 

We have put in place procedures to deal with any actual or suspected breach of Personal Information. In the event that Personal Information is compromised as a result of such a breach of security, we will promptly notify the persons whose Personal Information has been compromised in accordance with the notification procedures set forth in this Policy or as otherwise required by applicable law.

Unfortunately, the transmission of Information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to or through our Products or Platform.  Any transmission of Personal Information is at your own risk.  We are not responsible for circumvention of any privacy settings or security measures contained on the Platform. 

Children Under the Age of 13

The Children's Online Privacy Protection Act of 1998 and its rules, as amended (collectively, "COPPA") require us to inform parents and legal guardians (as used in this section, "parents") about our practices for collecting, using, and disclosing Personal Information from children under the age of 13 ("children"). It also requires us to obtain verifiable consent from a child's parent for certain collection, use, and disclosure of the child's Personal Information.

The Platform is not intended for children under 13 years of age unless such a child is using our Platform with the direction, consent, and supervision of a parent.  We do not intentionally collect Personal Information from children under age 13, but do understand that children and their parents also desire to experience life uninterrupted by using our Products, Platform, and Services!  

This section notifies parents that we collect information from children as set forth in other sections of this Policy, and as more specifically set forth below.

Like other Users, a child must provide us with certain Personal Information (e.g., name, birth date, an email address) to register an Account to access our Services and Platform. As stated in this Policy, we may also collect other Information from a child related to their use of the Platform or Services (see Information We May Collect) (e.g., when a child’s electronic device was placed in an Aro Box). 

However, we do not monitor or review this Content or Information before it is posted or received, and we do not control the actions of third parties with whom your child shares his or her information (e.g., sharing an Aro Session on Facebook). We encourage parents to educate their children about safe internet use and to monitor their children's use of social features.

We do not sell any Personal Information of children (including children under age 16).  However, we do disclose such Information in accordance with this Policy (see Disclosure of Your Information) (e.g., to third-party service providers necessary to provide our Platform or Services).

At any time, you may review the child's Personal Information maintained by us, require us to correct or delete the Personal Information, and/or refuse to permit us from further collecting or using the child's information.

You can review, change, or delete your child's Personal Information please see the How Long We Store Your Information and How to Exercise Your Rights sections, or contact us at support@goaro.com.

Contact Information

To ask questions or comment about this Policy, our privacy practices, or if you need access in an alternative format due to a disability, please contact us at privacy@goaro.com. 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits Users that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.  To make such a request, please send an email to privacy@goaro.com. 

Changes to Our Privacy Policy

You understand that this Policy is subject to change by us without prior written notice at any time, at our sole discretion.  Any changes to this Policy will be in effect as of the “Last Updated Date” or “Last Revised Date” referenced on the Platform.  Accordingly, you should review our Policies before purchasing or using our Products, Platform, or Services.  Your continued use of the Platform or any Product after the “Last Updated Date” or “Last Revised Date” will constitute your acceptance of and agreement to such changes.