GENERAL

Last Updated: May 24, 2018

Thank you for your interest in Taro Technology Incorporated. and its affiliated companies (“TARO”,“we,” or “us”) and in the various hardware, firmware, software, websites, applications, and services provided by us and on which a link to this Privacy Policy (this “Policy”) is displayed (each, a “Product” or “Service” and, collectively, the “TARO Products and Services”).

This Policy describes

• the information that we gather from you,
• how we use and share this information,
• the rights and choices you have regarding this information,
• the steps we take to protect this information,
• the limitations of this Policy regarding third party websites and content,
• how we transfer your information,
• how we may change this Policy, and
• how you may contact us.

By using TARO Products and Services, you consent to the privacy practices described in this Policy.  This Policy is incorporated into and is subject to the Terms of Use for the TARO Products and Services you use.

INFORMATION COLLECTED

Information We Collect on the TARO Products and Services

• User-provided Information. When you use TARO Products and Services, you may provide us with information about you, including your name, email address, mailing address, mobile phone number, and payment information (if you use TARO Products and Services to engage in purchases or financial transactions). You may provide us with information in various ways when using TARO Products and Services. For example, you provide us with information when you register for a TARO account, use TARO Products and Services, submit credentials or other information for account verification, upload or share photos or videos on or through TARO Products and Services, or send us customer service-related requests using TARO Products and Services or other means of communication.
• User-provided Information About Others. We may also collect and store information about other people that you or other users provide to us. If you use TARO Products and Services to send others (friends, relatives, colleagues, etc.) information that may interest them or messages (such as invitations to comment on videos or photos, use TARO Products and Services, or participate an event) through TARO Products and Services, we may store information about you and information relating to each such recipient. Similarly, if you use TARO Products and Services to upload, share and/or distribute content, photos, videos, or other submissions, and such content contains information about others, we may store, process, and disclose that information as provided for under this Policy. Please note, under such circumstances, you should obtain appropriate consent from others and inform them about this Policy.
• Cookies and Automatically Collected Information. When you use certain TARO Products and Services, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device.  We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies, you may not be able to utilize the features of TARO Products and Services to their fullest potential. We may use third party cookies as well.  For instance, we use Google Analytics to collect and process certain analytics data.  TARO does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use TARO Products and Services. We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use a Product or Service, the pages or other content you view or otherwise interact with on a Product or Service, and the dates and times that you visit, access, or use TARO Products and Services. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users, and may be connected with other information about you. Our use of cookies and other automatically collected information is explained further in our Cookie Policy.
• Device-Related Information. When you use TARO Products and Services, you may provide us with information relating to (i) your TARO Product or Service, your non-TARO device on which the TARO Product or Service is used (including computers, phones, or other devices where you install or access TARO Products and Services), and your photos or videos that you upload using TARO Products and Services. This information may include: (i) information about your non-TARO device (including your device ID, hardware version, and operating system); (ii) information about your TARO device (including the model and serial number of your device); (iii) geolocation data relating to your non-TARO device and TARO device and any photo or video you submitted using TARO Products and Services; (iv) information about any photo or video recorded, including the name of the video file, the length of the video, EXIF data relating to the photo or video; (v) other technical information, including the IP address used by your non-TARO device; and (vi) data associated with your TARO account. Some of the features of TARO Products and Services may enable TARO to access your location in order to tailor your experience with the TARO Products and Services based on your location (“Location-based Services”). In order to use certain Location-based Services, you may be required to enable certain features of your mobile phone (such as GPS, Wi-Fi, and Bluetooth), which enable TARO to identify your location through a variety of means, including GPS location, IP address, cell tower location, geo-fencing technology, or detection by physical on-location Wi-Fi or Bluetooth sensors. If your location is collected through Wi-Fi or Bluetooth sensors, please be aware that such sensors, and the associated data services, may be provided by a third party, which may access such information for the purpose of providing such data services to TARO.
• Third Party Web Beacons and Third Party Buttons. We may display third-party content on or through TARO Products and Services, including third-party advertising.  We also may enable you to connect your TARO account to, or otherwise interface with, third party services, including third party social networks and communications services.  In addition, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by TARO. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies. For further information, please review our Cookie Policy.
• Information from Other Sources. We may obtain information from third parties and sources other than TARO Products and Services, such as our business partners, contractors, advertisers, and other third parties.

USES OF COLLECTED INFORMATION

How We Use the Information We Collect

We use information we collect through TARO Products and Services in a variety of ways in providing the TARO Products and Services and operating our business. We will ensure that the use of information is generally required under the user agreements we have with you, or is in our legitimate interest as part of the TARO Products and Services we provide, or is with your consent. The use of information that we collect includes the following:

• We use the information that we collect through TARO Products and Services to operate, maintain, enhance and provide features of the TARO Products and Services, to verify and manage TARO user accounts, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to time by TARO.
• We use the information that we collect through TARO Products and Services to understand and analyze the usage trends and preferences of our users, to improve the TARO Products and Services, and to develop new products, services, features, and functionality. We will process your personal data in accordance with your preferences, which are expressed via TARO Products and Services.
• We may use your information to contact you for administrative and informational purposes, including for customer service. We may send direct marketing such as communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with. If you are an individual or consumer we will only send you direct marketing with your consent or as permitted by applicable law. You may send unsubscribe requests or withdraw your consent at any time.
• We may use information we collect to: (i) personalize TARO Products and Services; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of TARO Products and Services and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) review your entries, submissions, and status in any promotions or other activities involving TARO Products and Services. Where we do not do this with anonymized or aggregated data we will process the data in connection with the user agreement or where it is in our legitimate interest or where you have provided consent and where you have not objected or withdrawn any prior consent given.

When We Disclose Information

We will not disclose your information that we collect through TARO Products and Services to third parties except as described in this Policy or as we disclose to you at the time the information is collected. We may disclose information to third parties in the following circumstances:

• We may share your information with our parent company, affiliates and subsidiaries globally in order to provide you with TARO product and services.
• Any information that you voluntarily choose to upload to a publicly accessible site or venue using TARO Products and Services, or that you elect to make public, will be available to anyone who has access to that content, including other users.
• We work with third party service providers to provide payment facilitation, parcel transportation, application development, hosting, maintenance, account verification, and other services for us. We require these service providers to use or disclose, the information they process on our behalf, only as necessary to perform services on our behalf or comply with legal requirements.
• We may preserve and disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena, warrant or request, or to otherwise cooperate with law enforcement or other governmental agencies.
• We also reserve the right to preserve and disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activities, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the TARO Products and Services and any facilities or equipment used to make the TARO Products and Services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
• TARO uses a third party verification service provider to verify certain users of TARO Products and Services and TARO may disclose information to this service provider.  The service provider may retain credential information provided as part of account verification for compliance and other purposes and may provide such information, as well as your user login ID or email address, to government authorities, law enforcement agencies, regulatory agencies and other duly authorized parties as may be required by or permitted under applicable laws. We require this service provider by contract to use or disclose, the information they process on our behalf, only as necessary to perform services on our behalf or comply with legal requirements.
• If you consent to our disclosure of information to a third party, such as business partners, or as otherwise authorized under applicable law.
• Information about our users, including information you provided and any information collected through TARO Products and Services, may be disclosed and otherwise communicated to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• We may make certain aggregated, de-identified, or non-identifying information about users of TARO Products and Services available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; (iii) product safety analysis; or (iv) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality of TARO Products and Services.

RIGHTS REGARDING COLLECTED INFORMATION

Your Rights and Choices you have regarding this information

You can access and update your information on your TARO account page. Subject to applicable law, you may have the right to request access to additional information, including the right to request access to and receive certain information about the information we maintain about you, update or correct inaccuracies in the information we maintain about you have the information blocked, deleted, or erased, as appropriate. You also have the right to object to the processing of your information or to withdraw your consent to our processing of information about you, including to the transfer of information to other countries.

Note, however, that if you exercise your right to object or your rights of blocking, deletion or to be “forgotten,” or if you decline to share certain information with us, or if you withdraw your consent to our processing of information about you, we may not be able to provide to you some, or any, of the features and functionality of TARO Products and Services.

You may update, correct, or delete certain TARO account information and preferences by accessing your account preferences page, available through certain TARO Products and Services, including the taro.ai and certain TARO mobile applications. If you wish to access or amend any other information we hold about you or exercise any other rights you have under applicable data protection law, you may contact us at support@taro.ai.

Likewise, if you close your TARO account, you will not be able to sign in to TARO Products or Services or access any of your information. However, you can open a new account at any time. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit, as authorized under applicable law, for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

If you receive commercial email or text messages from us, you may unsubscribe at any time by following the instructions contained within the email or text message. You may also opt out from receiving commercial email or text messages from us by sending your request to us by email at support@taro.ai

We use Google Analytics to collect and process certain analytics data; Google provides some additional privacy options described at www.google.com/policies/privacy/partners.

Third-Party Services

TARO Products and Services may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through TARO Products and Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through TARO Products and Services, and we recommend that you view the privacy policies of each website that you visit.

Children’s Privacy

TARO Products and Services are not directed to children under the age of 13. We do not knowingly collect information from children under the age of 13 without obtaining parental consent.

DATA SECURITY

We use certain physical, organizational, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards.

ternational Transfers of Personal Data

TARO Products and Services connect to servers hosted in the United States, China, and Hong Kong. If you choose to use TARO Products and Services from the European Union or other regions of the world, then please note that you may be transferring your information outside of those regions for storage and processing. Also, we may transfer your data from the U.S., China, and Hong Kong to other countries or regions in connection with storage and processing of data, fulfilling your requests, and providing the services associated with TARO Products and Services. You should be aware that the local laws in such countries may be different from and offer less protection than the laws applicable in the EEA or elsewhere. For users located in the EEA, your information transferred is protected in a manner that is consistent with how your information will be protected by us in the EEA, such as requiring the data recipients to enter into contracts that include the model contractual clauses approved by the European Commission, or to be certified under the EU-US Privacy Shield. International transfers of data are necessary for the performance of our contract with you that makes available the TARO Apps.

Retention of Your Information

We retain your information to provide service to you, or as required by applicable laws or regulations. We aim to retain your information only for the period necessary to fulfil our obligations under this Policy, unless otherwise required or permitted by law.

POLICY CHANGES AND UPDATES

Changes and Updates to this Policy

We may update this Policy from time to time. If we modify this Policy, we will make it available on or through the TARO Products and Services, and indicate the date of the latest revision. We will make reasonable efforts to notify you of the change. Limited by applicable laws, your continued use of TARO Products and Services after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of this Policy.

Our Contact Information

Please contact us with any questions or comments about this Policy or our data practices by email at support@taro.ai.

COOKIE POLICY

What are Cookies?

When you use certain TARO Products and Services, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies, you may not be able to utilize the features of TARO Products and Services to their fullest potential. We may use third party cookies as well. For instance, we use Google Analytics to collect and process certain analytics data. TARO does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use TARO Products and Services.

We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons” (together with cookies, “cookies and similar technologies”). This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use a Product or Service, the pages or other content you view or otherwise interact with on a Product or Service, and the dates and times that you visit, access, or use TARO Products and Services. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users, and may be connected with other information about you.

Cookies Used by TARO

We use different types of cookies as listed below. They help us to provide and improve our service, such as showing you the most relevant information and your customized webpage. Some or all of the cookies listed may be stored in your browser or devices.

Cookies Use when You Use Mobile Devices

Some mobile devices share the same features with computers, such as the support of full-featured browsers. When you are using this type of devices such as smart phones, we use cookies in a similar way to when you are using computers. Other devices may use different technologies, such as local storage, Software Development Kits (SDKs), or Advanced Programming Interfaces (APIs) to facilitate aforementioned processes effectuated by cookies.

We may obtain or receive information about your device, our apps, or other apps. We may also use these technologies to store information on your device. For example, we may receive information about the make and model of your mobile device when you are asking others for help through our app.

Read of Particular Cookies

Browsers will send cookies for a particular domain (such as taro.ai) to the website each time a device with those cookies accesses content from that domain. This means if your device stores cookies for taro.ai, it will send those cookies to TARO when it accesses a webpage at taro.ai.