Privacy Policy

Kasiel Solutions Inc. (“Kasiel”/“we”/“us”/“our”) is committed to protecting your privacy. We make the website oraforyou.com (the “Website”) available together with our wearable alert device called ORA Link (the “ORA Link”), and the ORA Mobile Application (the “App”, and collectively with the ORA Link, the “ORA Solution” or “Solution”) which communicates with the Wearer’s Network, are more fully described in the Purchase and Subscription Agreement or Terms of Use (the “Service”). This Privacy Policy describes how we collect, store, use and distribute certain Personal Information (as defined below) of yours that we collect through the ORA Solution and the Service. Any capitalized terms not defined in this Privacy Policy shall have the meaning given to such terms in our Terms of Use (https://oraforyou.com/pages/terms-of-use) and/or the Purchase and License Agreement. This Privacy Policy is to be read together with and form part of our Terms of Use and the Purchase and Subscription Agreement for use of the Solution and Services (https://oraforyou.com/pages/purchase-and-subscription-agreement). Any capitalized terms not defined herein have the means set forth in the Purchase and Subscription Agreement. 

Consent

By using the Website and/or the Solution and Services, you consent to the use of your Personal Information as outlined in this Privacy Policy. Your Personal Information will not be used for any purposes other than those described herein. We will not actively collect Personal Information for the purpose of sale or marketing in a way that specifically identifies the individual. You may withdraw your consent to our use of your Personal Information at any time; however, withdrawing your consent may result in your inability to continue using all or part of the Service. Except as otherwise stated herein, this Privacy Policy applies to all of the Personal Information of yours that we have on record.

Collection of Information

We aim to collect, use and disclose only such information as is required to enable us to manage your account, to provide the Solution and Services, to maintain our customer/visitor lists, to respond to your inquiries or provide feedback, for identification and authentication purposes, for service improvement and analytics. We will maintain the confidentiality of any contact information you provide to us on signing up for our Services or contacting us with questions or for further information and we will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties.

Two types of information may be collected through the Solution: Personal Information and Non-Personal Information. This Privacy Policy does not extend to the collection, use or disclosure of the following information which is currently not limited by applicable privacy laws: (a) information that is publicly available, such as names, addresses, telephone numbers and electronic address when listed in a directory or made available through directory assistance; or (b) Non-Personal Information (as defined further below).

"Personal Information" is personally identifiable information, such as your name, phone number, address, location, e-mail address, credit card information, birth date and gender. It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information, in some instances you may not be able to register to use the Website or App or be able to access and use the Website or App at all. In other instances, your choice not to provide certain other Personal Information may mean that you will not be able to use certain features of the Website or App. We collect and store some Personal Information relating to your account registration, transmission of information from the ORA Link to the App, communications between users in the same Network, communications with you, user support, user surveys, and your use of the Service.

"Non-Personal Information" is non-personally identifiable information, such as your internet protocol address (IP Address), provided the address has been stripped of all personal information, the domain used to access the Service, and the type and version of browser or operating system used by visitors of the Website or the type of mobile device on which the App is installed. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, and average time spent on the Website or in the App is not considered Personal Information. Similarly, business contact information such as the name, title, business address, or telephone number of a business or professional person or an employee of an organization is not considered Personal Information

Although the use of Non-Personal Information collected, used or disclosed through the internet as described herein is not restricted by law, we provide information in this Privacy Policy about our collection and use of such information for the sake of transparency. Such Non-Personal Information may be collected or derived by us through the Solution and the Service.

Collection and Use of Personal Information

We collect Personal Information for the following purposes:

  • Registration Information: We collect some Personal Information when you create an account with the Service, including your name, username, password and mobile phone number. You have the option to add additional information to your User profile, including a profile picture. Your username is visible to all Users of the Service, as is the information in your profile page, including your profile picture and mobile phone number.
  • Wearer Information. Once the subscription for the Service has been activated, the ORA Link will collect and transmit information to the App while the ORA Link is within range of the Bluetooth signal on the Wearer’s smartphone. In addition to transmitting alert notifications that are triggered by the Wearer, the ORA Link tracks and transmits the Wearer’s location, and also transmits accelerometer information about the Wearer, which will be displayed in the App as the Wearer’s activity levels.
  • Information Sharing between Wearer and Network Members: The Wearer of the ORA Link will be able to invite individuals to join the Wearer’s Network. In the event of an emergency or when an alert is transmitted by the ORA Link, the Network will be contacted via the App and notified of the location of your mobile device. The App displays your activity levels to members of the Network.
  • All payments for the Solution, including purchases of the ORA Links and/or ongoing subscription fees are payable in advance by credit card. Payments can be made by submitting your credit card information to our merchant account gateway provided and hosted by Shopify. Shopify collects and stores all payment information, and we do not collect or store any payment information or process any payments.
  • Marketing Communications. If you opt-in to receive marketing communications from us, we will keep you up to date on our ORA Links and services. You may withdraw your consent to receiving marketing communications from us at any time by following the opt-out instructions in each communication, or by contacting our marketing department at support@oraforyou.com.
  • Transactional Notifications. We provide notifications for certain activities relating to your use of the ORA Solution despite your indicated e-mail preferences. For example we will send you receipts for your purchases on the Website, and we may send you notices of any updates to our Terms of Use or Privacy Policy, or updates to our ORA Links or Services.
  • User Conversations: We keep a record of your communications with other Users in order to be able to provide you with a log of the conversations in which you have taken part. This information is kept confidential and, except as otherwise specified in this Privacy Policy, is not shared with any third parties.
    • Mobile Device Information: We collect some information about the device through which you access the Service, such as device model, screen size, and operating system version.
    • Statistics: We collect statistics about use of the ORA Solution. This information will be kept confidential; however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to other members or third parties.
    • System Logs and Cookies: We use system logs to track and create an audit trail of all activity within the Network including invitations to join the Network, changes to members of the Network, alerts, calls and messages. Cookies are used by us to track content usage and traffic on the Website. The audit trail information is stored by one of our third party service providers, stream.io. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server. The Website uses cookies to help it compile aggregate statistics about usage of this Website, such as how many users visit the Website, how long users spend viewing the Website, and what pages are viewed most often. This information is used to improve the content of the Website. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the Website. We do not link any of the information obtained from cookies to any personally identifiable information.

Your IP address is reported by your web browser whenever you visit a page on the Website. This information is recorded together with your registration information on our databases.

If we plan to use your Personal Information in the future for any purposes not identified above, we will only do so after informing you by updating this Privacy Policy (see further Amendments to this Policy below).

Disclosures and Transfers

We have put in place contractual and other organizational safeguards with our agents (see further below) to ensure a proper level of protection of your Personal Information (see further Security below). In addition to those measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy (see further Important Exceptions below).

As at the date of this Privacy Policy, we share Personal Information about you in respect of the ORA Solution only with our third party service providers which include our website host, cloud service provider, audit trail hosting provider, email marketing service provider and payment processors. Our servers are located in Canada, and accordingly your Personal Information may be available to the Canadian government or agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.

From time to time we may employ third parties to help us improve the ORA Solution and Website. These third parties may have limited access to databases of user information solely for the purpose of helping us to improve the ORA Solution and Website and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose.

Important Exceptions: We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the ORA Solution or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Security

The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information or your password for the Services to third parties.

Retention

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained personal information will remain subject to the terms of this Privacy Policy. If you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints.

Amendment of this Policy

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post an appropriate notice on the Privacy Policy page located at https://www.oraforyou.com/pages/privacy-policy. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective 30 days from their posting on the Website. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the ORA Solution signifies your acceptance of any changes.

Access and Accuracy

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

Contact Us: You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions or if you find any errors in our information about you, please contact us at support@oraforyou.com.

Last updated: January 12, 2017