Privacy Policy

Last updated February 12, 2024

At Naro, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our website(s), products, services and applications (collectively, the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.

Naro’s technology helps organizations manage and better utilize their marketing and sales content. In the ordinary course of providing these services, we may process personal data on behalf and at the direction of our enterprise customers. We are not the controllers of such personal data and our processing of such data is governed by the agreement in place between Naro and the applicable enterprise customer. The enterprise customer’s privacy policy or other agreement between the enterprise customer and you or your organization, and not this Privacy Policy, applies to such processing. If we process your personal data on behalf of one of our enterprise customers and you wish to discontinue such processing or otherwise exercise rights that may be available to you under applicable privacy laws, please contact the enterprise customer on whose behalf we are processing such data.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Naro website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as“personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations.This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as“personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations.This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Business or Commercial Purpose(s) for Collection
Categories of Third Parties With Whom We Disclose this Personal Data
Profile or Contact Data such as first and last name, email, phone number, and unique identifiers.
·  Providing, Customizing and Improving the Services
·  Corresponding with You
·  Service Providers 
Categories of Personal Data (and Examples)
Online Identifiers such as account name and passwords
·  Providing, Customizing and Improving the Services
·  Service Providers 
Payment Data such as payment card type, last 4 digits of payment card, and billing address, phone number, and email.
·  Providing, Customizing and Improving the Services
·  Service Providers (specifically our payment processing partner, currently Stripe, Inc.)
Commercial Data such as purchase history.
·  Providing, Customizing and Improving the Services
·  Service Providers 
Device/IP Data such as IP address, device ID, and type of device / operating system / browser used to access the Services.
·  Providing, Customizing and Improving the Services
·  Service Providers 
Web Analytics such as web page interactions, referring webpage / source through which you accessed the Services, non-identifiable request IDs, and statistics associated with the interaction between device or browser and the Services.
·  Providing, Customizing and Improving the Services
·  Service Providers 
Social Network Data such as user name and info from social media profile.
·  Providing, Customizing and Improving the Services 
·  Service Providers 
Professional or Employment-Related Data such as job title.
·  Providing, Customizing and Improving the Services
·  Service Providers 
Inferences Drawn From Other Personal Data Collected such as attributes, user behavior, and predispositions.
·  Providing, Customizing and Improving the Services
·  Service Providers 
Other Identifying Information that You Voluntarily Choose to Provide such as emails, letters, texts, or other communications you send us.
·  Providing, Customizing and Improving the Services 
·  Service Providers 

Our Commercial or Business Purposes for Collecting Personal Data

Providing,Customizing and Improving the Services
· Creating and managing your account or other user profiles.
· Processing orders or other transactions; billing.
· Providing you with the products, services or information you request.
· Meeting or fulfilling the reason you provided the information to us.
· Providing support and assistance for the Services.
· Improving the Services, including testing, research, internal analytics and product development.
· Personalizing the Services, website content and communications based on your preferences.
· Doing fraud protection, security and debugging.

Marketing the Services
· Marketing and selling the Services.

Corresponding with You
· Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Naro or the Services.
· Sending emails and other communications according to your preferences or that display content that we think will interest you.

Other Permitted Purposes for Processing Personal Data 

In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Naro or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

When you provide such information directly to us.
· When you create an account or use our interactive tools and Services.
· When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
· When you send us an email or otherwise contact us.

When you use the Services and such information is collected automatically.
· Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).

From the government, public social media posts or other sources. 

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your PersonalData. For more information, please refer to the state-specific sections below. 

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:   · Hosting, technology and communication providers.  
· Security and fraud prevention consultants.  
· Support and customer service vendors.  
· Product fulfillment and delivery providers.  
· Payment processors. Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment.   Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.
· Gmail Data. By connecting your Google Workplace email account with Naro, you are allowing us access to your email data so we can recommend follow-up actions and content. We may analyze some data using third-party large language models (such as OpenAI) and store the information about your data for further analysis and to improve the recommendations we provide you.
· Google Drive Data. (Optional) By connecting your Google Workplace Drive account with Naro, you are allowing us access to your data and files in Google Drive. We only read the files and data that you explicitly select through the Naro application after integration in order to provide content suggestions in your emails and sales workflows. We may analyze some data using third-party large language models (such as OpenAI) and store the information about your data for further analysis and to improve the recommendations we provide you.

Parties You Authorize, Access or Authenticate
· 
Social media services.

Legal Obligations 

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other PermittedPurposes for Processing Personal Data” section above.  

Business Transfers 

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).  

Data that is Not Personal Data 

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve theServices and promote our business, provided that we will not disclose such data in a manner that could identify you.  

Tracking Tools, Advertising, and Opt-Out 

TheServices use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services.Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please see our Cookie Policy for an explanation of how we use Cookies.

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account.Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:
·      We retain your profile information and credentials for as long as you have an account with us.
·      We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at hello@narohq.com.  

State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at hello@narohq.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
720-552-5202
narohq.com    
hello@narohq.com

Naro Technologies, Inc.
1150 Wewatta St #200
Denver CO 80202