This Policy was last updated on July 28, 2022
Automatic collection of information
When you use the Services, we and/or or our third party analytic providers, may automatically collect technical and/or analytics information about how you use and/or interact with our Services that your browser or device sends or is otherwise collected via cookies and/or similar technologies as described in the section “Cookies” below. This data may include, but is not necessarily limited to, information or Personal Information such as your user settings, history of your purchases on the Services, online identifiers, your device’s IP address and approximate location (as determined through your IP address), browser type and device name and version, plug-ins, operating system type and version, language preferences, Internet service provider or mobile carrier, the webpage you were visiting before you came to the Services, applications and/or ads that referred you to the Services, pages of the Services that you visit, the time spent on those pages, the information you search for on the Services, access times and dates, and other statistics.
This data and information is used to help us:
- Compile statistics and analytics about your use of and interaction with the Services, including details about how and where the Services are accessed, how often you visit or use the Services, the date and time of your visits, your actions on the Services, and other similar traffic, usage, and trend data, which allow us to better understand the functionality of our Services on your device and gain insights about how our Services are used in order to improve your experience;
- Gather important functionality, testing, and performance data about the Services, including performance data related to the Services, such as networking activity, CPU load, and resource usage, among other relevant data;
- Moderate user behavior on the Services, such as protecting against fraud and other inappropriate activities;
- Gather demographic information about our user base;
- Provide you with notifications, recommendations, and information about specific features of the Services and/or additional products, services, or features we believe may be of interest to you; and
- Advertise our Services across the Internet (as further explained in the section “Targeting Advertising” below).
Typically, all device and/or usage data is collected in anonymous form and does not identify you personally; however, some of the data collected, whether alone or in conjunction with other data, could identify you. Please note that this device and usage data is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes. To the extent any device and/or usage data is linked or tied to personally identifiable information, such information is deemed Personal Information and we will use process it as Personal Information in accordance with this Policy.
Collection of Personal Information You Provide Us
You can access and use the Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Services, you may be asked to provide certain Personal Information (for example, your name and e-mail address).
We receive and store any information you knowingly provide to us when you create an account, make a purchase, or fill any forms on the Services. When required, this information may include the following:
- account details (such as user name, unique user ID, password, etc.)
- contact information (such as email address, phone number, etc.)
- basic personal information (such as name, country of residence, etc.)
- geolocation data of your device (such as latitude and longitude)
- certain features on the mobile device (such as contacts, calendar, gallery, etc.)
- any other materials or information you willingly submit to us (such as articles, images, feedback, biography, picture or other likeness of yours, etc.)
You can choose not to provide us with your Personal Information, but then you may not be able to enjoy certain features of the Services. Users who are uncertain about what information is mandatory to be able to use the Services are welcome to contact us at firstname.lastname@example.org.
We do not require you to provide any sensitive data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health and genetics, or biometric data to use the Services.
Privacy of minors
We do not target the Services to, nor knowingly collect personal information from, persons under the age of 13 or the equivalent age as specified by law in the applicable jurisdiction (e.g., 16 years of age if you are located in the EEA). Therefore, we ask you not to provide us with personal information of persons under the age of 13 or the equivalent age as specified by law in your jurisdiction. If we learn that personal information of persons under the age of 13 or the equivalent age as specified by law in the applicable jurisdiction, has been collected on or through the Services, then we may deactivate the account or otherwise terminate access to the Services and/or make the user content inaccessible.
Purpose of use and processing of collected information
We act as a data controller and a data processor when handling Personal Information, unless we have entered into a data processing agreement with you, in which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information.
We act in the capacity of a data processor in situations when you submit Personal Information through the Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller.
In order to make the Services available to you, or to meet a legal obligation, we may collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested Services. Any of the information we collect from you may be used for the following purposes:
- create and manage user accounts
- fulfill and manage orders
- deliver products or services
- improve products and services
- send administrative information
- send marketing and promotional communications
- send product and service updates
- respond to inquiries and offer support
- request user feedback
- improve user experience
- post customer testimonials
- deliver targeted advertising
- administer prize draws and competitions
- enforce terms and conditions and policies
- protect from abuse and malicious users
- respond to legal requests and prevent harm
- run and operate the Services
Processing your Personal Information depends on many factors, including how you interact with the Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; or (v) processing is necessary for the purposes of the legitimate interests pursued by us.
We may also combine or aggregate some of your Personal Information in order to better serve you and to improve and update our Services.
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other legal basis.
In case of any Services requiring payment, you may need to provide your credit card details or other payment account information, which will be used solely for processing payments. We use third-party payment processors, Stripe and PayPal (collectively, the “Payment Processors”) to assist us in processing your payment information securely.
Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council. Sensitive and private data exchange happens over an SSL secured communication channel and is encrypted and protected with digital signatures, and the Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.
Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. The Payment Processors’ use of your Personal Information is governed by their respective privacy policies, which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.
You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates, partners or as required by applicable law, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so by contacting us at email@example.com.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our trusted subsidiaries and joint venture partners, affiliates, contracted companies, and service providers (collectively, the “Service Providers”) we rely upon to assist in the operation of the Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. Unless otherwise specified herein, we will not share any personally identifiable information with third parties and will not share any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.
We may also disclose any Personal Information we collect or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States, or other applicable jurisdiction. Under such circumstances, unless prohibited by applicable law, we will attempt to provide you with prior notice that a request for your personal information has been made in order to give you an opportunity to object to the disclosure. We will attempt to provide this notice by email, if you have given us an email address. However, government requests may include a court-granted non-disclosure order, which prohibits us from giving notice to the affected individual. In cases where we receive a non-disclosure order, we will notify you when it has expired or once we are authorized to do so.
In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of our assets, your user account, and your Personal Information, will likely be among the assets transferred.
In addition, we may hire individuals and retain third-party companies to perform services on our behalf, or in our name, as independent contractors with whom we need to share certain information, including your Personal Information, to operate the Services, including the Website and the Mobile Application and to perform our Services. These independent contractors may perform various services, including sales, marketing and customer support, data analysis, including search results and links, credit card or other payment processing. These independent contractors do not have any right to use or share any of your Personal Information except as necessary to perform the services instructed by us.
There may be situations where you are asked to consent, or have the ability to choose, to share personal information with third parties for additional reasons not included in this Policy. In such event, we will only share such personal information if we have received your prior consent, or at your choice and direction, as applicable, and only for the purposes as listed in the applicable request or direction to share such information.
Information required under the Act on Protection of Personal Information of Japan, Act No. 58 of 2003, as amended
We may provide your Personal Information to third parties located in the United States based on your consent to this Policy. Information regarding the United States is as follows:
- Information regarding systems for protection of personal information in the United States can be found here.
- Information regarding measures taken by the third parties to protect Personal Information: the third parties in general takes the same level of measures required under the Act on Protection of Personal Information in Japan with respect to handling of personal data.
- Such third parties include:
Retention of information
We will retain and use your Personal Information for as long as your user account remains active and for any longer period necessary to comply with our legal obligations, to enforce our agreements, to resolve disputes, and for a longer retention period as required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information will be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
California privacy rights – Shine the Light Law
We do not share your personal information with any unaffiliated third party for its direct marketing purposes without your express consent.
California residents who have provided us with personal information have the right (under California Civil Code§ 1798.83) to request and obtain from us, once each year, the details of any personal information we shared with a third party for that third party’s direct marketing purposes during the prior calendar year. The details would include the categories of personal information and the names and addresses of the third party with which it was shared.
To request information about this sharing, you may submit a request with "Your California Privacy Rights" in the subject line, along with your first and last name, and complete mailing address (including street address, city, state, and zip code) by either: sending an email message to the email address specified in the section “Contacting Us” below.
If you do not submit and send your request with complete information as set forth above, we will not be able to process it.
Nevada privacy rights
Under Nevada law, certain Nevada residents may opt out of the sale of covered personal information (which includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online) to a person for that person to license or sell such information to additional persons.
We do not currently sell your covered information as defined under applicable Nevada law; however, you may submit an opt-out request, which we will honor as required by Nevada law should we engage in such a sale in the future.
You may submit an opt-out request by sending an email message to us at the email specified in the section “Contacting Us” below; along with your full name, any user name, and complete mailing address (including street address, city, state, and zip code), email address (so that we can contact you, if needed, in connection with the request) and confirmation that you are a Nevada resident.
You must provide us with information reasonably requested by us to verify your identity and the authenticity of the request. We typically process these requests within 60 days from the day we receive it (and will notify you within that period if we need an additional 30 days to do so).
How to exercise your rights
Any requests to exercise your rights can be directed to us through the contact details provided in this Policy. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.
You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
Unless required by applicable laws or expressly set forth in this Policy, you have the right not to consent to any collection, sharing or use of your Personal Information. Subject to applicable laws, you may withdraw your consent at any time after having given it and we will process your withdrawal as soon as reasonably practicable, except that you acknowledge and agree that any collection, sharing or use of your Personal Information during the effectiveness of your consent is legal and legitimate. Subject to applicable laws, you may also have the right to object to or complain about legitimate grounds of collection, sharing or use of your Personal Information. You acknowledge and agree that certain features on the Services, including the Website, the Mobile Application, may not be available if you do not provide certain Personal Information.
You may unsubscribe from marketing, notices or any other communications received from us via an email by either clicking the “unsubscribe” link in such email or emailing us at firstname.lastname@example.org. You acknowledge and agree that your (un)subscription does not affect the legal nature of certain notices or other communication in any manner and you are solely responsible for checking this Policy as updated.
You have all the rights available to you under applicable laws in your jurisdiction. For example, the laws of certain jurisdictions (which may not be applicable to you) allow you to (a) obtain confirmation that we collect, share and use your Personal Information, (b) receive electronic or printed copies of your Personal Information, (c) object to or limit the collection, sharing or use of your Personal Information, (d) have your Personal Information anonymized or permanently deleted or destroyed, (e) request access and receive information about your Personal Information and (f) lodge a formal complaint with supervising authorities regulating data protection and privacy.
We or authorized third parties may collect certain information (including, without limitation, the deice and/or usage information describe in the section “Automatic Collection of Information” above) by automated means using technologies such as cookies, web beacons, embedded scripts, pixels, browser analysis tools, server logs, and mobile identifiers, and similar technologies that are deployed, and typically stored on your device and have a unique identifier, when you visit a website, when you open an email or click on links or images within an email, and/or when you interact with online advertisements.
These technologies may be used for many different purposes. For example, they can be used to show that you have previously visited and/or used a feature of the Services and to identify which parts of the Services we offer you might be most interested in, or used to improve your online experience by storing your preferences during your visit and/or use of the Services. These technologies can also be used for security, fraud detection and authentication purposes. We use these technologies for the purposes described in this Policy.
We not directly track users across third party websites; however, certain third partner advertising partners may track you across third party websites as described in the section “Targeted Advertising” below. For information regarding how you can manage your cookie preferences, please see the section “How to Manage Cookie Preferences” below.
We may use third party advertising partners (e.g., Facebook, Inc. and Google, Inc.) who use targeting/advertising cookies and similar technologies to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Targeting or advertising cookies will often be linked to site functionality provided by the other organizations. We utilize the third party advertising partners listed below that use these cookies to:
- Advertise our business, and our products and services across the Internet;
- Track the performance and efficacy of our advertisement campaigns;
- Keep track of how many visitors click on the advertisement;
- Keep track of which advertisements you have already been shown so that you are not always shown the same ones; and
- Tailor our marketing to better suit your needs and only display ads that are relevant to you.
For information regarding how you can manage your targeting/advertising preferences, please see the section “How to Manage Cookie Preferences” below.
How to Manage Cookie Preferences
Where required by applicable law, we will obtain your consent prior to setting cookies (except for strictly necessary cookies). Most web and mobile device browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set.
In order to manage your cookie preferences, you may alter the cookie settings in your browser settings at any time. You may accept all, or certain, cookies. If you do disable our cookies in your browser settings, you may find that certain features and/or functionality of the Services do not work. In addition, please note that even if you opt out of cookies through your browser and/or through any of the other mechanisms described below, advertisements may still be visible to you when using the Services.
To learn more about cookies, including how to manage cookies and opt-out of cookies being placed on your device, please visit http://www.allaboutcookies.org/manage-cookies/index.html. While tracking is widespread over the internet, there are things you can do to minimize these activities with respect to browser cookies; however, please note that even if you opt out using the mechanisms described below, advertisements may still be visible to you when using the Services.
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.
Google Analytics Opt-Out:
You can download the Google Analytics opt-out browser add-on at: https://tools.google.com/dlpage/gaoptout/
You can opt out of targeted advertising by:
- Meta (Facebook, Instagram) - https://www.facebook.com/settings/?tab=ads
- Google - https://www.google.com/settings/ads/anonymous
In addition, some of our third party analytics and/or advertising/targeting partners may be members of the Network Advertising Initiative ("NAI") or Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. NAI and DAA each provide information regarding procedures for opting-out of targeted online advertising from participating companies.
- For information from NAI about opting out, click here
- For information from DAA about opting out, click here or visit: http://optout.aboutads.info/
On your mobile device, your operating system may provide you with additional options to opt out of interest based advertising or to otherwise reset your mobile identifiers. For example, you may use the “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.
Social media features
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the “Use and processing of information” section of this Policy or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the U.S. Controlling the Assault of Non-Solicited Pornography and Marketing Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.
We offer push notifications to which you may also voluntarily subscribe at any time. To make sure push notifications reach the correct devices, we use a third-party push notifications provider that relies on a device token unique to your device that is issued by the operating system of your device. While it is possible to access a list of device tokens, they will not reveal your identity, your unique device ID, or your contact information to us or our third-party push notifications provider. We will maintain the received information in accordance with applicable laws and regulations. If, at any time, you wish to stop receiving push notifications, simply adjust your device settings accordingly.
Links to other resources
The Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Services and to read the privacy statements of each and every resource that may collect Personal Information.
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. 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 control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet that are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.
In the event we become aware that the security of the Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected Users if we believe that there is a reasonable risk of harm to the Users as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Services or send you an email.
Changes and amendments
We may revise this Policy if it is in the general interest of our customers or if we deem it reasonably necessary and appropriate to do so. If we decide to modify this Policy, we will disclose such modification and specify the effective date of such modification on https://www.naro.tv/privacy-policy or through other appropriate means, including by posting a prominent notice on our websites and/or via email. Notwithstanding the foregoing, the resolution of any dispute that arises between you and us will be governed by the Policy in effect at the time such dispute arose.
Your continued use of the Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us at email@example.com.
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.