PRIVACY POLICY

PARO AI, INC. PRIVACY POLICY

PARO APP
Last updated February 21, 2020

GENERAL
Paro AI, Inc. (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our mobile application (the “Application”, “it”, or ”its”).   Please read this Privacy Policy carefully.  IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU MUST NOT ACCESS THE APPLICATION.

We reserve the right to make changes to this Privacy Policy at any time and for any reason.  We will alert you about any changes by updating the “Last updated” date of this Privacy Policy.  You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.  

You are gaining access to the Application as a result of an agreement (the "Agreement") that has been executed between Paro AI, Inc. and a third party such as your employer (the "Third Party") in which Paro AI, Inc. will supply certain services via the Application where certain data and information that may be supplied by the Third Party and could be used by Paro AI, Inc. in the performance of those services.  This data is owned by the Third Party and provided to Paro AI, Inc. only in order to perform the services required by the Agreement, but may include certain personal information about you, such as name and identifiable information, that may be used to validate you as an authorized user.  

Paro AI, Inc. generally does not store any data or collect any information for storage.  However, the Application may require certain permissions by you in order to allow functionality of the Application to perform as expected such as location permissions and access to other applications on your device such as phone, text, voice, microphone access, navigation and others.  Any personal information stored or collected by the Application will be maintained, in a manner consistent with this Privacy Policy.

All data, including personal information, used in the performance of the services, including any data, access and information that you supply, may be processed by the Application and reported back to the Third Party.  We will not share any personal information collected through the Application with anyone other than the Third Party for the purposes described in the Agreement.  The resulting data of any processes executed by the Application are returned to the appropriate data source and stored by that source when applicable.  The ownership of that data is subject to the Agreements governing any relationship between that source and the third party or exclusive to the third party such as the case may be and is in no way the responsibility of Paro AI, Inc.  Paro AI, Inc. claims no responsibility or warrants any guarantee of privacy by any third party and you are encouraged to read and understand the policies of any third party in question before agreeing to the terms of this policy.

Generally, Paro AI, Inc. will draw from data and information supplied by or authorized from the Third Party.  Additional information, access or other data may be requested to be supplied by you or provided by another third party.  It is our understanding that any third party who supplies us with data and information has the authority to do so and Paro AI, Inc. maintains no responsibility or liability with respect to data that is inappropriately provided to us.  Further, while processing the data and information, Paro AI, Inc. will execute its services in a manner that reasonably secures and protects the data and information provided to us.

Your access to the Application is subject to the terms and conditions as outlined in the Agreement.  The Third Party will determine and authorize your access to the Application's functions and will have complete control of decisions governing your access to the Application and its functions.

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include the length of time we have an ongoing relationship with you, when we have a legal obligation to which we are subject or advisable in light of legal requirements.

We may disclose non-personal information, aggregated with information about our other users, to our clients, business partners, merchants, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion. to have sound business reasons or justifications.

Paro AI, Inc. will not disclose your personal information except as described herein.  Additional reasons for disclosure of your personal information may include:

By Law or to Protect Rights If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.  This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.  

Interactions with Other Users If you interact with other users of the Application, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.  Such users will also be authorized to have access to the Application by the same Third Party.

Online Postings When you post comments, contributions or other content to the Application, your posts may be viewed by other users authorized by the Third Party.

Affiliates We may share your information with our affiliates or the affiliates of the Third Party the Third Party so authorizes, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our and the Third Party's respective parent company, subsidiaries, joint venture partners or other associated companies.

Business Partners We may share your information with our business partners.

Other Third Parties We may share your information with other third parties or investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Sale or Bankruptcy If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.  If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party.  You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

SECURITY OF INFORMATION
We use administrative, technical, and physical security measures to help protect the data and information we receive by third parties and your personal information.  While we have taken reasonable steps to secure the personal information you and others provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online is vulnerable to interception and misuse by unauthorized parties.  Therefore, we cannot guarantee complete security of all data and information provided to us by you or any third party.

TRANSPARENCY AND CHOICE
You may request access to your personal information by sending an email to info@paroai.com. We will try to locate and provide you with your personal information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. But, in either case, we may need to retain it for legal reasons or for legitimate business purposes. You may also remove any content that you post to the Application using the deletion or removal options within the Application. However, we (and you) are not able to control information that you have already shared with other users or made available to third parties.

If you need further assistance with removing any content you posted through the Application, you can email us at info@paroai.com. Removal of your posted content may not ensure complete or comprehensive removal from our computer systems.

To protect your privacy, we will take reasonable steps to verify your identity before granting access or making any changes to your personal information. We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your personal information. In any case, where we provide information access and correction , we perform this service free of charge, except if doing so would require disproportionate effort.

Please be aware that if you request us to delete your personal information, you may not be able to continue to use the Application. Also, even if you request that we delete your personal information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.

CHILDREN
The Application is not intended for users under 13 years of age. We do not knowingly collect personal information from users under 13 years of age. We do not authorize users under 13 years of age to use the Application.

YOUR CALIFORNIA PRIVACY RIGHTS
As you may know, California recently passed a new privacy law, the California Consumer Privacy Act of 2018 ("CCPA"). Under the CCPA, we are a "service provider" to the Third Party, which may be a "business" covered by the CCPA. As a "service provider," we process your personal information in order to provide our services to the Third Party, and in order to facilitate your interactions with the Application. To learn more about rights that you may have under the CCPA, such as the right to request information about the types of your personal information that has been collected, the right to request that your information be deleted, and the right to opt-out of the sale of your information, please contact the Third Party.

Paro AI, Inc. and the Application comply with the CCPA and other applicable laws. If you'd like to make a request to us regarding your personal information, please contact info@paroai.com, and we will reasonably try to accommodate your request unless we are prevented from doing so as a result of applicable law or a significant legitimate interest of ours. Please also note that, depending on the nature of your request, the fulfillment of your request may hinder or prevent our ability to provide you with certain features and functionalities of the Application.

THIRD PARTY WEBSITES AND APPLICATIONS
Please note that the Application may link or integrate with third-party websites, services or apps. We are not responsible for the privacy or security policies or practices or the content of such third parties. Accordingly, we encourage you to review the privacy and security policies and terms of service of those third parties so that you understand how those websites, services or apps collect, use, share your personal information.

CONTACT US
If you have questions or comments about this Privacy Policy, please contact us at:

Paro, Inc.
116 Research Drive, Bethlehem, PA 18015
800-509-8640
info@paroai.com