ORA | Privacy Policy

Last Updated: July 11, 2019

Creative Labs Management Inc. (“Creative Labs”, “we”, “us”, “our”) operates all Ora’s service platforms (“Service(s)”, “Product(s)”), including the Ora iOS app (“Mobile App”) and ourora.co (“Website”). This privacy policy (“Policy”) describes how we collect, use and disclose your personal information and how this personal information can be consulted and corrected when necessary. This Policy also explains how cookies are used on our Services. We are committed to protecting the privacy and security of your information, and strongly encourage you to read these terms carefully before using our products or services, so that you may use this information to make informed decisions.

By visiting Ora’s Website or using the Mobile App, contacting us or agreeing to receive emails from Ora, you accept the terms and conditions of this Policy. This Policy does not extend to websites operated by third parties. Creative Labs is therefore not liable for their privacy policies, procedures and practices.

Collection and Use Of Personal Information

The term “personal information” means any information relating to an identified or identifiable natural person. In each of the below cases, we collect and store only the information that is deemed necessary or appropriate to fulfill the purpose of our users’ interaction with Ora Services. Creative Labs does not disclose personal information other than those described in this Policy. You can always refuse to supply personal information, being aware that this may prevent you from interacting with certain services on the Website or Mobile App.

Using our Mobile App

In order to create and maintain your profile, we require a valid email address or Facebook token. Horoscopes are generated by storing your birth date, with natal chart information are generated by collecting a user’s birth date, time, and location. By opting to use the social aspects of the service, you agree to share some personal information with the users that you add as friends. This information is limited to astrological information, your username, and your display name, and does not include your email address or any of your birth time or location details. When you sign up with Facebook, we share the fact that you have an account with users whom you have added as a Facebook friend. We may also process personal information upon your consent, asking for it as appropriate.

Visiting our Website

We collect the Internet Protocol (“IP”) addresses of visitors to our Website and other information about your visit, such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity, and to monitor and improve our Website.

Email and Other Communications

We may collect your name, email address and other contact information to send you emails and other communications about products, services, promotions or events that may be of interest to you. You can opt-out of receiving our promotional messages by doing one of the following:

If you have received an email, you can follow the opt-out or “unsubscribe” instructions provided in your email.

You can always request to be unsubscribed by contacting us through the “Contact” page on our Website or using the contact information set out below.

Contacting Us

When you contact us with a comment, question or complaint, you may be asked to provide personal information (such as your name or email address) along with any additional information we need to help us promptly answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service.

Disclosure of Personal Information

Our policy is that we do not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out herein. Anytime we disclose your personal information to third parties, we take reasonable measures to ensure that the rules set forth in this Policy are complied with and these third parties provide contractual guarantees to implement appropriate technical and organizational measures.

Service Provider Arrangements

We may transfer (or otherwise make available) your personal information to third parties who provide services on our behalf. For example, we may use service providers to operate certain features or send email or other communications. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes.

Sale of Business

We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Ora or Creative Labs, as part of a corporate reorganization, or in connection with a stock sale or other change in corporate control.

Legal

Creative Labs and our Canadian, US and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by applicable Canadian, US or other law. We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims, or as otherwise permitted by law.

Cookies

Ora Services may use a technology called “cookies”. A cookie is a tiny element of data that our Services can send to your browser, which is stored on your hard drive so we may later be able to recognize your computer or other device while you interact with our Services. Most web browsers allow you to modify your settings to notify you when you receive a cookie or to reject cookies entirely. However, if you decide not to accept cookies from our Services, you may not be able to take advantage of all of their respective features.

We use Google Analytics to help us gather and analyze information about the areas that you visit in our Services to evaluate and improve the customer experience and the convenience of our Services, and to help us evaluate some of the specific information related to your visits. To opt-out of Google Analytics’ tracking of your Website visit across all websites, Google makes a tool available that you can install in your browser.

Security of Personal Information

We take steps designed to ensure that only those employees who need access to your personal information to fulfil their employment duties will have access to it. We have implemented measures designed to help protect personal information in our custody and control. We maintain reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.

Data Transfer

Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using our Services, you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than in your country. While such information is outside of the US or Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Policy and, if applicable, we will comply with the General Data Protection Regulation (“GDPR”) requirements providing adequate protection for the transfer of personal information from the EU/EEA to third country.

Rights Regarding Your Personal Information

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.

Under the GDPR, you may be entitled to specific provisions, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your personal information and certain other supplementary information, under certain conditions; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to erasure of personal information about you, under certain conditions; (v) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your personal information is inaccurate; (vi) the right to data portability of personal data concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection.

Data Retention and Deletion

We store your data for as long as you have an account. When you ​delete your account​, we permanently remove all data you have provided us or we have collected from our servers.

Changes to the Privacy Policy

This Privacy Policy may be updated periodically to reflect changes to our personal information practices. The revised Privacy Policy will be posted on the Website and will be accessible through the Mobile App. If we make material changes to this Privacy Policy, we will notify you by posting a notice on the front page of this Website and/or sending you an email notification. We strongly encourage you to please refer to this Privacy Policy for the latest information about our personal information practices. Your continued use of our Services after any change in this Policy will constitute your acceptance of such change.

Ability to Accept This Policy

In order to access and use our Services, you must have reached the legal age of majority in your jurisdiction of residence or possess legal parental or guardian consent, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Policy, and to abide by and comply with this Policy. We do not knowingly provide access to our Services to anyone under the age of 18 unless such user has parental or legal guardian consent. It is your responsibility to ensure that you are legally eligible to use our Services under any laws applicable to you in your jurisdiction of residence or otherwise. If we learn that personal information has been collected via the Website or Mobile App from persons under the legal age of majority and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has provided personal information, then you may alert us via the contact methods below and request that we delete that child’s personal information from our systems.

Contact

If you have any questions or comments about this Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside of the US or Canada, you may reach us by email at info@ourora.co or by sending mail to 420-725 Granville Street, Vancouver, BC V7Y 1K8.