Notes
This Privacy Notice for ARAORA ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share
("process") your personal information when you use our services ("Services"), including when you:
Download and use our mobile application (Swing Delay), or any other application of ours that links to this Privacy Notice
Engage with us in other related ways, including any marketing or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for
making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use
our Services. If you still have any questions or concerns, please contact us at [email protected].
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by
clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information
depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more
about personal information you disclose to us.
Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain
jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal
information.
Do we collect any information from third parties? We do not collect any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate
with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your
consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your
information.
In what situations and with which parties do we share personal information? We may share information in specific situations and
with specific third parties. Learn more about when and with whom we share your personal information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights
regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by
contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.
TABLE OF CONTENTS
WHAT INFORMATION DO WE COLLECT?
HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
HOW LONG DO WE KEEP YOUR INFORMATION?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our
products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Sensitive Information. We do not process sensitive information.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such
personal information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud
prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process
your information for other purposes only with your prior explicit consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an
individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to
do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual
obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process
your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a
specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations,
such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your
information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests
of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a
specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including,
for example:
If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and
the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada
or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the
purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations
We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality
commitments
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of
company assets, financing, or acquisition of all or a portion of our business to another company.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required
by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer
retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require