Latest Update: August 4th 2021

We are The Ora Way Inc. ( “The Ora Way”, “Ora”, “we”, or “us”)!

It’s important for us that you trust how we handle your personal information when you use our Services (as defined hereinafter). Therefore, this Privacy Policy (the “Policy”) provides you with the information that you need to understand how we collect, use and disclose your personal information. We used a question-and-answer format so that you can navigate this Privacy Policy easily. 

Please review carefully this Policy. By using our Services (as defined hereinafter), you consent to the collection, use and disclosure of your personal information, as precisely set out in this Policy, and as revised from time to time.

So, if you have any questions regarding the processing of your personal information, do not hesitate to reach out to us, we are here to support you! You can email us at hello@theoraway.com, or reach us by mail at the following address:

The Ora Way Inc. - Attention: Privacy Officer

CP 39003, rue Saint-Alexandre

Montreal (Québec) H3B 0B2

Canada

1. When does this Privacy Policy apply and what does it cover?

This Policy contains information about how we collect, use and disclose your personal information when you are:

• navigating our public websites such as www.theoraway.com (the “Websites”);
• exchanging with us by e-mails, social media or otherwise.  

In this Policy, we use the term “Services” to refer to all the above, and where there is no distinction to make between the different aspects of the Services.

The term “Website User” refers to someone who is navigating our websites, or is interacting with us by e-mails, social media or otherwise. 

The term “User” or “you” refers indistinctively to an App User or a Website User. A User can be both an App User and a Website User.

This Policy covers the use of your personal information for interest-based advertising. For more information about this topic, please jump directly to the relevant section of this Policy.  We do not conduct interest-based advertising within our websites or as part of our Services. We only conduct interest-based advertising through and social media.  

This Policy does not apply to third-party content accessible through the Services, or to the use of a third party for the purpose of connecting to the Service, as applicable. These third-party services are integration partners. You must have your own subscription with them, and they are not our service providers. These third parties collect, use and disclose personal information in accordance with their respective privacy policies. We invite you to consult these policies carefully.

2. What do we mean by “personal information”?

Personal information is information that relates to a natural person or allows for the identification of a natural person. Some information may not be personal on its own but may become personal information if associated with personal information or if the sum of the information allows us to identify you. For the purpose of this Policy, we consider that your cookies are personal information, regardless of applicable laws. 

The definition of what constitutes personal information is subject to the laws applicable in your jurisdiction, and this Policy shall be interpreted in accordance with applicable laws.

For the purposes of this Policy, we define personal information as any information which relates to a natural person and allows that person to be identified. For example, this means that we consider electronic identifiers, such as e-mails and passwords, as personal information. You should know that some laws do not include business contact information (ex. name, title, work email, etc.) and other employees' personal information in the legal definition of personal information. However, to be transparent with our Users, we included such personal information in our own definition of personal information. 

We include cookies in our definition of personal information, although some laws may not consider cookies as personal information. Cookies are messages that web services pass to your web browser when you navigate the Internet. Your browser stores each of these messages in a small file. Our definition of cookies also includes similar technologies, like pixel and web beacons that are installed on your devices. Cookies can track you across different websites, and serve different purposes. There are various types of cookies: (1) essential; (2) functional; (3) marketing and (4) analytics. Some stay installed only during your session on a website, others are installed for several months or years. 

3. What types of personal information do we collect, and why?

We collect personal information to provide you with our Services, for the purpose of obtaining analytics on your use of our Services, or in connection with our marketing activities. This section does not cover the cookies that we use. Our use of cookies is covered in the questions below. 

Category	Description	Justification
Services
Electronic Data	IP address, mobile identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and language.	This information is collected automatically by our Services to function effectively, to fix bugs, or to improve the security of our Services. We also use this information for analytics purposes to help know more about your use of our Services. These may be collected as part of cookies.
Usage Data	Time spent on the Services, pages visited, links clicked, language preferences, pages that led or referred you to the Website.	We collect this information for analytics purposes.
Communication Data	Email addresses  Identification data  Publicly available information Emails content	If you communicate with us by email, on social media, by subscribing to our services-related news communications on our Websites, or by any other means, we collect the personal information that you share with us, such as your email address and the content of your communication. If you communicate with us using social media, we will have access to your publicly available information.
Website and Marketing Activities
Newsletter	Email  Consent to receive e-mails	If you consent to receive our communications, we will send you e-mails about updates and specific app information. You can unsubscribe at any time directly in the emails or by contacting us.
Social Media	Publicly available information	If you follow us or interact with us on social media, we may process your personal information for marketing or advertising purposes, subject to applicable laws, including those on consent.
Events and academic seminars	Business contact information Registration information	If we interact with you as part of events or tradeshows, we may collect your contact information. If you register for our academic seminars or any other training sessions, we will collect personal information to register you.

 

4. What cookies do we use and why?

We use cookies for our Services to function as intended, to conduct marketing, to analyze our performance and to improve our Services’ security. Cookies are also useful to identify bugs and errors. We use both first-party and third-party cookies installed by partners on our Website.

There are different types of cookies. We use both first party and third-party cookies:

Type of cookie	Description
First Party	First party cookies are those that are issued by us, and they can only be set or retrieved by us.  They are used for purposes specific to us, such as to personalize the website.
Third Party	Third party cookies are placed on our websites or Apps by other entities, such as to create new functionalities or conduct advertising.

Cookies can also be categorized based on their roles. We collect cookies that classify in each of these categories:

Type of cookie	Description
Essential	Essential cookies are necessary to operate the core functions of our Services. These include login cookies, session ID cookies, language cookies as well as security cookies.
Functional	Functional cookies are used to provide you with some functionalities and to remember preferences, consents and configurations.
Analytics	Analytics cookies are used to generate aggregated statistical data about the traffic and behaviour of Users when using our Services. For instance, we can determine how much time Users spend on a page, and how successful our advertisings are. For instance, the cookie named _ga is used by Google Analytics to gather data about your behaviour on our Services.
Marketing	Marketing cookies are used to deliver relevant advertisings which requires tracking and analyzing users’ behaviour across websites. Cookies help us to do so through our partners. For instance, _fbp and fr are cookies installed by Facebook to deliver targeted advertising, and bcookie is a Cookie installed by LinkedIn to track users for advertising purposes on our Services.

 

5. Do we use Google Analytics? 

Yes, we do. We use Google Analytics as part of Analytics cookies on our Websites. Google Analytics is Google’s analytical tool that helps us to understand how Users engage with our websites. The information we collect through Google Analytics is page views, time spent through the Services, number of visitors, the source where they come from, the pages they have visited, session and Websites usage, the whole in an anonymous form. It uses a set of cookies to collect such information and report site usage statistics without allowing us to identify individual visitors. 

6. Do we conduct interest-based advertising (IBA)?

Yes. We use targeting cookies as part of our marketing strategy. This is called interest-based advertising, which is also referred to as targeted advertising or behavioural advertising. Re-targeting means that the ads that you are being served are personalized based on your behaviour when browsing online. This is enabled through cookies and requires the processing of electronic data that is considered personal information under certain laws. 

We do not conduct interest-based advertising within our Website or as part of our Services or using Users’ data when they are within the Website or using the Services. We only conduct interest-based advertising through social media.

We collect your Mobile Advertising ID (also called Identifier for Advertisers in iOS operating systems and Android Advertising ID in Android operating systems). A Mobile Advertising ID is a user-resettable ID assigned to a specific device that enables us to associate activity on a device to that specific device and to track usage of applications. The tool lets us convert your email address to a unique number that advertisers use to match to unique numbers it generates from email addresses of its users as part of real-time bidding.

If you are not comfortable with this, you can opt-out of interest-based advertising by managing your cookies and other tracking technologies. You can also use WebChoices which is a browser-based tool for opting out of interest-based advertising. Mobile users can also download the DAA Choice App in the Apple App Store, Google PlayStore or Amazon Store. AdChoices provides additional solutions and explanations to control block and control cookies, as well as plug-ins to retain opt-out cookie preferences, even if you delete your cookies.

7. To whom do we disclose your personal information to?

Let’s be clear, we do not sell your personal information to data brokers. However, we do share your personal information with certain types of third parties to provide you with the Services, conduct marketing and as required by the law. We can also share your personal information in the context of a merger and acquisition, as part of bankruptcy procedures or for other corporate requirements.

Category	Explanations
Service Providers	Service providers are used to providing you with some functionalities that are outsourced to third parties.
IT Service Providers	We use IT Service Providers to offer you the Services, such as Google Cloud Platform to host the Services and your personal information. For instance, we also use Sentry for crash reporting (click here to jump to their privacy policy).
Marketing Partners	We use marketing partners to (1) serve you relevant ads; (2) analyze our advertising campaigns performance; (3) manage our leads and (4) provide you with marketing content. All of these activities require the processing of your personal information, including through cookies.
Law enforcement and other authorities	We may receive requests by authorities to access your personal information. We will validate that the request is licit before responding. When possible, we will advise you. We will only share what is strictly required.

We encourage you to review the privacy statements and policies of those third parties so that you can understand how those third parties collect, use and disclose your personal information.

We may share your personal information with our financial and legal advisors or auditors if reasonably required, or in the event we would be required to do so to defend our rights and interests.

In the case of a merger or acquisition, sale of assets, corporate reorganization, bankruptcy filing, insolvency procedures or similar circumstances, your personal information would be considered our assets and property. In these circumstances, ownership of the personal information we collected may be transferred or we may have to share some of your personal information to conclude, negotiate or discuss with third parties. We will only share what we are required to share for these specific purposes.

8. Where do we store your personal information?

We use Google Cloud Platform to host our Services and store your personal information. The servers are located in the United States. However, our other suppliers and third-party service providers may process your personal information internationally.

9. How long do we retain your personal information?

We retain personal information for as long as necessary to provide you with the Services, to perform our marketing campaigns effectively or as required by applicable laws, whichever is longer. We use both persistent and session Cookies. Session cookies are deleted once you close your browser, whereas persistent cookies remain active on your device for some time. For instance, Google Analytics cookies remain installed on your device for 2 years. This allows Google Analytics to track you for analytic purposes, as well as for marketing purposes, and to provide us with aggregated data on your behaviour.

10. How do we keep your personal information secure?

We strive to implement physical, organizational, contractual and technological security features that are proportional to the risks, taking into consideration factors such as the sensitivity of the personal information that we collect.  

However, it is important to understand that we cannot guarantee the security of personal information on the Internet and that you must also take precautions, such as not sharing your credentials with anyone. No method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you are concerned that your account credentials are compromised), please contact us immediately using the contact information at the beginning of this Policy.  If we learn of a security breach involving your personal information, we will inform you and the relevant authorities of the occurrence of the breach as required under applicable law.

11. Can you manage your Cookie preferences?

You can always manage your Cookie preferences. However, some functionalities may require Cookies in order to perform as expected, or for security purposes. You can control your Cookie preferences through your browser. Depending on the browser that you are using, different instructions are applicable. Click on your browser for more information:

• Google Chrome
• You can also browse on Incognito Mode while using Chrome.
• Firefox
• Safari
• Internet Explorer
• Opera

12.  Do you have any rights over your personal information?

Yes! These rights vary depending on where you are located. 

You generally have the right to access your personal information and to correct your personal information if inaccurate, in certain circumstances

If you want to exercise your rights, you can contact us at hello@theoraway.com You can also reach out to us by mail at the following address: 

The Ora Way Inc. - Attention: Privacy Officer

CP 39003, rue Saint-Alexandre

Montreal (Québec) H3B 0B2

We will respond to your request within 30 days. If we can’t comply with your request, we will tell you why.

If you are located in Canada, note that the Office of the Privacy Commissioner of Canada drafted this FAQ to help you access your personal information when it is held by a business. You can also contact the Office of the Privacy Commissioner of Canada’s Information Center:

Telephone
9:00 am to 4:00 pm EST
Toll-free: 1-800-282-1376

Mailing address

Office of the Privacy Commissioner

30 Victoria Street

Gatineau, Québec

K1A 1H3

You can also use this online form.

If you have any issue with how we collect, use or disclose your personal information, or how we responded to your request, please let us know at hello@theoraway.com We will do our best to improve our processes to make certain that it does not happen again. We will also provide you with additional information about our practices if you would like us to do so. 

If you are still not satisfied, you can lodge a complaint to the Office of the Privacy Commissioner of Canada using this online form, or to your local privacy regulators.

13.  Can we change this Policy?

We may need to modify this Policy to reflect new processing activities, adapt to new laws and regulations or reflect technological changes or corporate changes, such as a result of a merger and acquisition. We may also change this Policy at our sole discretion. In case of material changes, we will send an email to App Users. You can view the date of the latest update at the top of this page, and you can always reach out to us at hello@theoraway.com, should you have any questions. Your continued use of the Services is deemed an acceptance of this Privacy Policy.

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