# Privacy Policy

Aura Sub, LLC and its affiliates (collectively referred to as “Aura”, “We”, or “Us”) is a leading provider of digital security products for consumers. This General Privacy Policy describes how we collect and process personal data provided to Aura in connection with your use of our products, services, apps, and websites (including when you are a prospective customer, customer, or former customer (“Customer”)) that link to this policy (collectively as our “Services”).  The term “personal data” refers to information that is related to an identified or identifiable natural person (aka ‘personal information’ or ‘personally identifiable information’).

## 1. What Information Do We Collect About You?

This section describes the various categories and types of personal data we collect from and about you when you use our website, apps, and when you interact with us in relation to our Services. The personal data we may collect may differ depending on which product you use. Please see our Products Privacy Notices for more information.

The information we collect includes:

### 1.1 Personal Data You Provide to Us

We and our service providers may collect personal data about you to provide our Services, respond to your requests, and manage your account with us. We collect this information via forms on our websites and apps, when you contact us or register an account, and in our communications with you. Where service components go beyond the base service, we provide you with clear choices to decide if you want these additional functions.

1. **Account Information**. We collect data when you create or update your account.  This may include your name, username, email address, phone number, password, your government ID numbers (when you use our Identity Protection Products) and certain other information from you, including if applicable, your account and login information with our affiliate Circle. For our identity protection products, we will also request your Social Security Number (excluding Social Insurance Numbers in Canada) and other personal data.

2. **Billing and Payment Information**. To purchase a Service, we may collect certain details such as billing name, billing contact details (street addresses, email addresses), and payment instrument details.

3. **Identity Verification Information**. To verify your identity, we may collect personal data such as your full legal name, email addresses, your date of birth, social security number, home address, or phone numbers.

4. **Communications and Submissions**. We collect data when you communicate with us (e.g. via email, phone, or chat for support or to inquire about our services), including when you fill out an online form, respond to surveys, provide feedback, post comments to our website, participate in promotions, or submit information through our Services.

5. **Photos and Documents**. You may choose to upload and provide us with images and files that are stored on your device in relation to your use of our Services.

6. **Marketing and Advertising Data**. We collect data on your participation in promotions, survey responses, your marketing choices, information regarding your preferences based on your use of our Services, your interactions with advertising and marketing communications, and information regarding your customer profile. This may include demographic information such as age and gender.

7. **Emails**. If you activate our email protection services and connect your email service provider inbox to Aura, we will collect the emails in your inbox and emails that you receive on an ongoing basis. We will collect all data associated with the emails except for any files attached to your emails. This includes, but is not limited to, the sender’s email address, the content of the email, and the subject line.

8. **Product-Specific Information**. Some of our products, such as our Parental Controls software, may require you to provide us with third party account-specific information such as credentials to access child-specific social media accounts. Please see the specific Product Privacy Notices for more information on the specific categories, identities, purposes, and data retention of third parties that we share data with.

### 1.2 Information Collected Automatically when You Use Our Services

We automatically collect personal data about your use of our Services to monitor for problems and look for opportunities to make improvements. Some of this personal data is collected using cookies and similar technologies.

1. **Usage Information**. We collect information about how you interact with our Services, such as how often you use our Services, how much bandwidth you use, and when and for how long you use our Services.

2. **Device Information**. We collect information such as device identifiers (such as IP address or mobile device identifiers), browser types, device types and settings, device manufacturer and model, operating system versions, mobile, wireless, and other network information, and application version numbers.

3. **Diagnostic Information**. We may collect information about the nature of the requests that you make to our servers.

4. **Location Information**. We may collect your _approximate_ location by calculating an imprecise latitude and longitude based on your IP address to provide you with better service.

### 1.3 Information Provided to Us by Third Parties

As part of our Services, with your consent or where authorized by law, we can receive personal data about you from third parties. We take the same level of precautions and transparency of use that we provide for personal data you provide us directly.

1. **Referrals**. If you are invited to use an Aura service, the person who invited you may submit information about you, such as your email address or other contact information.

2. **Third Party Accounts**. Some services may allow you to register an account using a third-party account, and in some cases, you may register third party accounts with us. If you do so, that third party may send us some information about you that they have.

3. **Threat Information**. We receive information from reputable members of the security industry to help improve our services.

4. **Business Customers**. Organizations that use our business and enterprise products may submit personal data to facilitate account management and invite individuals to use those products.

5. **Monitoring Services**. For some of our products and Services, we will collect publicly available personal data from third parties to provide the extent of disclosures to you.

## 2. How Do We Use Your Personal Data?

Aura uses your information for the purposes described below. Aura employs internal risk management functions to ensure we continue to only use your personal data for the purposes we disclose to you and are taking appropriate steps to protect that personal data from exposure.

1. **To Provide, Maintain, Troubleshoot, and Support Our Services**. We use your personal data for this purpose on the basis that it is required to fulfill our contractual obligations to you.

2. **For Billing and Payment Purposes**. We use your personal data in order to perform billing administration activities and process payments.

3. **To Communicate With Users and Prospective Users**. We use your personal data to communicate with you via email, SMS, push notifications or other messaging.

4. **To Promote, Operate or Improve Our Services and Advance Our or a Third Party’s Legitimate Interests**. We want to offer you the best Services and user experiences we can.

5. **For Measurement, Research and Analytics, Including to Develop New Services**. Where applicable, we have a legitimate interest in using your personal data for measurement, research and analytics.

6. **For Advertising And Marketing Our Services, Including Targeted Advertising, Through The Use Of Cookies**. For more information on targeted advertising and cookies, please see our Cookie Policy.

7. **Aggregated or Anonymized Data, For Any Purpose Where The Information Is Aggregated or Anonymized So That No Individual Data Is Directly, or Indirectly, Identifiable**.

8. **To Prevent Harm or Liability**. We may use your personal data for security purposes.

9. **For Legal Compliance**. We internally use your personal data as required by applicable law, legal process, or regulation.

## 3. Who Do We Share Your Information With and Why?

In some situations, Aura may share your personal data with third parties who may collect, store, use, process and transfer the data for Aura.

1. **In Accordance with Your Instructions or Consent**. For example, some services may allow you to register an account using a third-party account.

2. **To Your Business Organization (For our Business Services)**. If a business customer is providing you with access to our Services through a business account.

3. **For Collaborating with Others**. Your information will be shared in connection with those activities if you choose to engage in them.

4. **Affiliates**. We may share your name, email address, and other contact information with our subsidiaries and affiliates.

5. **With our Partners**. We may provide your personal data to partners to confirm your eligibility for joint or co-branded offers.

6. **Third-Party Service Providers**. We may disclose the data we collect to service providers to help us provide some aspects of our services.

7. **For Security Research Purposes**. A de-identified subset of our threat intelligence data may be shared with selected reputable members of the cybersecurity industry.

8. **In Connection with a Business Transaction**. If a corporate transaction occurs.

9. **Aggregated or De-Identified Data**. We may aggregate and de-identify any data we collect and use and share such data.

10. **To Comply with Legal Process and The Law**. If you use our VPN product, we help protect your privacy by ensuring that we do not log or record online activities.

11. **To Enforce Our Rights and Prevent Fraud and Abuse**. We may share limited amounts of your information to enforce our agreements and protect against fraud.

## 4. Tracking Technologies & Cookies

For more information on Tracking Technologies and Cookies and how we use Tracking Technologies and Cookies please see our Cookie Policy.

## 5. Security

Securing personal data is an important aspect of protecting privacy. Aura employs a range of administrative, organizational, technical, and physical safeguards designed to help protect your data.

## 6. Cross-Border Data Transfers

Aura may transfer your personal data to regions, including the United States, other than the one in which you reside.

## 7. Data Retention

Aura generally retains your personal data for as long as is needed to provide the services to you, or for as long as you have an account with us.

## 8. Your Rights with Your Personal Data

If you live in the United Kingdom, Australia, or European Economic Area (“EEA”), you may have certain legal rights in relation to your personal data that we maintain.

1. Be informed of the source(s) from which we obtained your personal data;
2. Access and receive a copy of your personal data that we hold;
3. Request an update or correction of your personal data;
4. Request that we provide you with the categories of personal data we collect, disclose or sell about you;
5. Object to or restrict our use or processing of your personal data;
6. Unsubscribe from marketing communications;
7. Lodge a complaint with a data protection authority.

## 9. Legal Basis for Our Processing of Your Personal Data

We may only process personal data where we have a sufficient legal basis, such as your consent or where authorized by law.

| Aura Processing Activity | Legal basis under GDPR | Legal basis under Canadian Law |
| --- | --- | --- |
| Placement of cookies on Our Site | Consent | Consent |
| Collecting, processing, and sharing your child’s personal data | Consent* | Consent* |
| Collection and Processing of your personal data to maintain and fulfill the Services | Contract | Consent |
| Processing your personal data to improve our Services | Legitimate Interest | Consent |
| Using your personal data to send you email communications and updates | Legitimate Interest | Consent |
| Processing your personal data for market research | Legitimate Interest | Consent |
| Processing your personal data necessary for compliance with a legal or regulatory obligation that we are subject to | Legal Obligation | Authorized By Law |

## 10. Your State Privacy Rights (US Only)

Certain U.S. states may grant you enhanced privacy rights related to our processing of your personal data.

## 11. Technology Licensing

Aura occasionally licenses its technology to third party partners who may integrate it with applications developed and offered by those partners.

## 12. Age Restrictions

The administration, configuration and management of Aura accounts are not intended for and may not be used by minors.

## 13. Privacy Policy Updates

We may revise this policy from time to time and we will notify you of any changes.

## 14. Contact Us

If you have any questions or complaints about our privacy practices, you can contact us by telephone at +1 (844) 914-2991, via email at privacy@aura.com, or by mail.