Privacy Policy


Last updated: 02/22/2020
Effective date: 01/27/2020

Our Privacy Policy describes the information collection practices of Nara’s corporate website and the proprietary technology that we use to perform services for our customers.

Introduction

Nara is a leading audio player software and audio management platform (collectively, the “Nara Voice Technology”). Our customers are businesses that use the Nara Technology to host, embed and stream content and advertising over the web (collectively, the “Nara Player Services”).

Nara has prepared this Privacy Policy to describe our practices regarding the information we collect from:

  • Visitors to our website located at www.naravoice.com (the “Corporate Website”), including all subdomains
  • Users who listen to our customers’ audio on websites, apps, mobile apps, and other software powered by the Nara Voice Technology (each, a “Customer Property”) using a desktop or laptop PC, mobile phone, tablet, connected TV, set-top box, kiosk, virtual reality hardware, or other device

This Privacy Policy does not describe the information collection practices of our customers that use the Nara Technology on their Customer Properties. We are a third-party service provider to our customers. We recommend that you refer to our customers’ privacy policies to learn about their information collection practices.

Changes to this Privacy Policy

Nara will update this Privacy Policy to reflect changes to our practices. We will post all Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice. The Privacy Policy posted on this page will say when that version went into effect. If you visit the Corporate Website or listen to audio on a Customer Property after a change, then you will have accepted Nara’s new Privacy Policy. You are advised to review our Privacy Policy periodically for any changes.


A. Corporate Website


1. INFORMATION COLLECTED BY THE CORPORATE WEBSITE

Our Corporate Website provides information about our company, business, and the services we provide. It is also the portal used by our customers to sign into the customer dashboard for the Nara Services.

The Corporate Website collects Personal Data, Usage Data, and Tracking Data when you visit the site at www.naravoice.com. As used in our discussion about the Corporate Website in this Section A:

  • Personal Data” is the information about an individual that can be used to identify that individual. If you access the Corporate Website from the EEA, Switzerland or the UK, we use a different definition of Personal Data to comply with the General Data Protection Regulation (GDPR).
  • Tracking Data” is the information collected by cookies and similar tracking technologies (e.g., pixel tags, web beacons, or scripts) that we use to keep track of visitor activity on the Corporate Website. (Note that the Tracking Data collected by the Nara Technology is different, and is discussed in Section B.)
  • Cookies are small files that contain a small amount of data, typically including a unique identifier. They are generally placed on your browser by a website or other browser-based service. Our Corporate Website uses cookies.
  • Other tracking technologies, in the context of the Corporate Website, include pixel tags, web beacons, and scripts, and are used to track usage and performance. (See Section B below for the tracking technologies used by the Nara Technology.)
  • Usage Data”, in the context of the Corporate Website, is the information that your browser sends to Nara’s servers when you visit the Corporate Website.

As with other Internet services, our web servers gather information automatically each time your browser or device interacts with the Corporate Website, and store that information in “log files.” The information stored in our web servers’ log files includes information that we call Personal Data, Usage Data and Tracking Data, and that we describe more fully in the following sections.

Note for visitors who access the Corporate Website from the EEA, Switzerland or the UK:

  • Personal Data. In the EEA, Switzerland and the UK, Personal Data is defined differently than in the U.S., and means a variety of data that identifies or can identify a particular unique user or device (e.g., names, addresses, cookie identifiers, mobile device identifiers, precise location data and biometric data). For visitors who access the Corporate Website from the EEA, Switzerland, or the UK, elements of Usage Data and Tracking Data – such as a visitor’s full Internet Protocol (IP) address, and the information that we associate with a unique identifier (like a cookie or other tracking technology) – are Personal Data under the General Data Protection Regulation (GDPR).
  • Legal grounds for processing your Personal Data when accessing the Corporate Website. For visitors who access the Corporate Website from the EEA, Switzerland, or the UK, we process your Personal Data for the purposes set out in Section A.2. on one or more of the following legal grounds:
    • You provided your consent;
    • It is necessary for our contractual relationship;
    • The processing is necessary for us to comply with our legal or regulatory obligations;
    • The processing is in our or a relevant data controllers’ legitimate interest, for instance, where we use data to protect the security and integrity of our systems and to provide services or other benefits.

Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/

ABOUT PERSONAL DATA

a. Personal Data Collected by the Corporate Website. Personal Data includes your name, email address, postal address, and telephone number. It also includes any information that we have associated with your Personal Data.

The Corporate Website collects Personal Data from you when you engage in any of the following:

  • Request information about a product or service on the Corporate Website.
  • Register on the Corporate Website for emails, newsletters or other communications.
  • As an employee or authorized agent of a Nara Service, use a login account on the Corporate Website to access the customer dashboard for the Nara Technology.

We may combine Personal Data that you submit on or through the Corporate Website with information that we collect from and about you from other sources, offline and online.

b. How We May Use Personal Data. We use the Personal Data that you provide on the Corporate Website for the following activities:

  • Provide the services that you request.
  • Send you administrative information, including information regarding changes to the Corporate Website’s terms, conditions and policies.
  • Personalize your experience on the Corporate Website (including through the use of cookies and similar technologies).
  • Send you messages that you request.
  • Target you to receive ads and other marketing messages from us about the Nara Services.
  • For our business purposes, such as data analysis, audits, developing new products, enhancing the Corporate Website, improving our services, and identifying usage trends and determining the effectiveness of our marketing.
  • As we believe appropriate (a) to comply with applicable law and legal process, including to respond to valid requests by public authorities (e.g., a court, government agency, or law enforcement), (b) to enforce our terms and conditions, (c) to prevent or investigate possible wrongdoing in connection with the Corporate Website, Nara technology or the like, (d) to protect our operations or those of our affiliates, (e) to protect our rights, property, privacy, safety, or that of our affiliates, you or others, or (f) to allow us to pursue available remedies or limit the damages that we may sustain (these purposes, collectively, the “Compliance Purposes”).

c. When We May Disclose Personal Data. The Personal Data that you provide to the Corporate Website may be disclosed:

  • Service Providers. To our third-party service providers who provide services such as hosting, data analysis, IT infrastructure, IT services, customer service, email delivery, payment processing, billing and collections, data enhancement, order fulfillment, auditing, security, fraud, and other services to enable them to provide such services. These third parties have access to your Personal Data only to perform these tasks on our behalf.
  • Transfer of Business. To a third party to which we have transferred our business, assets or stock if Nara is involved in a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of some or all of our business, assets or stock, including during due diligence related to any such transaction (and also including in connection with any bankruptcy or similar proceeding).
  • As we believe appropriate for Compliance Purposes.

d. How Long We Retain Personal Data. We retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required for the security or integrity of the Corporate Website, or to comply with our legal obligations, resolve disputes, or enforce our legal agreements or policies.

e. No Sensitive Information. Please do not disclose through the Corporate Website any sensitive Personal Data (e.g., social security numbers, detailed financial information, health information, information related to racial or ethnic origin, political opinions, religion or other beliefs, criminal background or trade union membership).

f. ABOUT USAGE DATA AND TRACKING DATA

  1. Usage Data and Tracking Data Collected by the Corporate Website. The Usage Data and Tracking Data collected by the Corporate Website include:
    1. Information collected through cookies, pixel tags and other tracking technologies.
    2. Browser type and version.
    3. Your Internet Protocol (IP) address.
    4. If you are accessing the Corporate Website through a mobile phone, tablet, connected TV, set-top box, kiosk, virtual reality hardware, or other device: the type of device, unique device ID, device IP address, device operating system, and diagnostic data.
    5. Information about how you interact with the Corporate Website, such as the date and time of your visit, the pages that you visit, and the time spent on those pages.
    6. Other aggregated information.
  2. How We May Collect Usage Data and Tracking Data. Usage Data and Tracking Data are collected by the Corporate Website:
    1. When your browser or device sends it. Standard information is sent by most browsers. This information includes your device type, screen resolution, operating system version, and Internet browser type and version.
    2. Through web technologies. We and our service providers may use cookies, pixel tags, web beacons, and other similar technologies to, among other things, facilitate your ongoing access to and use of the Corporate Website, present you with more tailored information about our products and services, and collect and store information about your use of the Corporate Website.
    3. When you volunteer it. You may volunteer demographic information, as well as other information, such as your preferred means of communication.
    4. Through activity reports. Information about how you interact with the Corporate Website is collected with every visit, and is used to determine usage levels, diagnose server problems, and operate and maintain the Corporate Website.
    5. By aggregating information. We may aggregate or de-identify information collected by the Corporate Website.
  3. How We May Use and Disclose Usage Data and Tracking Data. We may use and disclose Usage Data and Tracking Data collected on the Corporate Website for any purpose permitted by applicable law.
    • Note: If we are required by law to treat any element of Usage Data or Tracking Data as Personal Data, then we will handle those elements as Personal Data. If we combine any Usage Data or Tracking Data with Personal Data, we will treat the combined information as Personal Data as long as it is combined.

3. YOUR CHOICES ON THE CORPORATE WEBSITE

  1. Your Choices Regarding Cookies. If you do not want cookies on the Corporate Website to collect information about you, there is a simple procedure on most devices that allows you to decline the use of cookies. To learn more about cookies, please visit www.allaboutcookies.org. However, if you choose to decline cookies, then some or all of the features, functionality and promotions available through the Corporate Website may not be available to you.
  2. How You Can Access, Change or Delete the Personal Data About You Collected by The Corporate Website. If you have a login to the Corporate Website (i.e. you are a Nara customer), log into your account to make changes to the Personal Data we have on file for your account. If you do not have a login to the Corporate Website (_e.g._, a prospective customer or a website visitor) and would like to access, change, or delete the Personal Data that you have previously provided to the Corporate Website, contact us by emailing us at privacy@naravoice.com to make the requested changes. We will comply with your request as soon as reasonably practicable. If you have requested that some Personal Data be deleted, note that we may need to retain some of the information for backup or Compliance Purposes. In addition, there could remain residual traces of the deleted Personal Data in our databases and other records. We are not responsible for changing or deleting information from the databases of third parties that have previously accessed your information.
  3. Your Choices Regarding Use of Your Personal Data. You may opt out from receiving marketing-related messages from us either by using the unsubscribe mechanism provided in the message or by emailing us at privacy@naravoice.com. If you opt out from receiving marketing-related messages from us, we may still send administrative messages to you. You cannot opt out from receiving administrative messages.
4. SERVICE PROVIDERS

We use third party companies and individuals to provide services and functionality for the Corporate Website. These service providers may have access to your Personal Data in order to perform tasks on our behalf (e.g., to send you information that you request or that we believe is of interest to you).

5. TRANSFER OF INFORMATION

As Nara works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who are likely located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Note for visitors who access the Corporate Website from the EEA, Switzerland or the UK: If we transfer Personal Data outside of the EEA, Switzerland or the UK, we will take steps to make sure that appropriate safeguards are in place to protect your Personal Data.


B. Nara Player Technology


1. INFORMATION COLLECTED BY NARA PLAYER TECHNOLOGY ABOUT USERS

Our customers are primarily web publishers (each, a “Customer”) that deploy NARA Player Technology on their properties to provide their visitors (each, a “User”) with a high-quality audio experience. In Section B, we describe the information that is collected from Users who listen to audio and ads on a Customer Property. The Nara Player Technology collects Usage Data and Tracking Data from Users. Note that the Tracking Technologies used in the Nara Player Technology are different from the Tracking Technologies used on the Corporate Website.

2. ABOUT USAGE DATA AND TRACKING DATA
  1. Usage Data and Tracking Data Collected by the Nara Player Technology. The Nara Player Technology collects Usage Data and Tracking Data from a User when he or she listens to audio on a Customer Property. As used in our discussion about the Nara Player Technology in this Section B:
    • “Usage Data” is the information that a User’s browser automatically sends to Nara Player’s servers when a User accesses audio or listens an ad on a Customer Property. This information includes a User’s device type, screen resolution, operating system version, and Internet browser type and version.
    • “Tracking Data” is the information collected by the Nara Player Technology from Users who access audio on a Customer Property, and consists primarily of the following:
    • Proprietary tracking technologies used by the Nara Player Technology for audio delivery and performance reporting. These tracking technologies include the following:
      • Local ID, which is stored on a User’s computer to identify a User’s player on a given Customer Property.
      • Global ID, which is stored on a User’s browser and Nara Player’s servers and identifies a User across different players and Customer Properties. The Nara Player Technology does not assign a Global ID to Users whose Internet Protocol (IP) addresses are based in the EEA, Switzerland and the UK.
      • Viewer ID, which is stored on Nara Player’s servers to identify a User.
    • Other tracking technologies include pixel tags, web beacons, and scripts, and are used for ad delivery and reporting.

As with other Internet services, our web servers gather information automatically each time a User’s browser or device interacts with the Nara Player Technology, and store that information in “log files”. The information stored in our web servers’ log files includes Usage Data and Tracking Data. The Usage Data and Tracking Data collected by the Nara Player Technology include:

  • Information collected through tracking technologies.
  • Browser type and version.
  • User’s Internet Protocol (IP) address.
  • Unique identifiers set by our tracking technologies to identify audio players, Users, and audio sessions.
  • If a User is accessing the Nara Player Technology through a mobile phone, tablet, connected TV, set-top box, kiosk, virtual reality hardware, or other device: the type of device, unique device ID, device IP address, device operating system, and diagnostic data.
  • Information about how a User interacts with the Nara Player Technology, such as the date and time of a User’s visit, audio story listens, and the time spent listening to those audio stories.
  • Other aggregated information.

Note for visitors who access the Nara Player Technology from the EEA, Switzerland or the UK:

  • Personal Data. As previously noted, some elements of Usage Data and Tracking Data, for example, a visitor’s full Internet Protocol (IP) address, and the information that we associate with a unique identifier (like a cookie or other tracking technology) are Personal Data under the General Data Protection Regulation (GDPR), and we treat those elements as Personal Data when collected by the Nara Player Technology from Users whose IP addresses are based in the EEA, Switzerland or the UK. Note that the Nara Player Technology does not assign a Global ID to a User accessing the Nara Player Technology from an EEA, Swiss or UK IP address. We will retain those elements of Usage Data and Tracking Data that are Personal Data under the GDPR for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required for the security or integrity of the Nara Player Services or Nara Player Technology, or to comply with our legal obligations, resolve disputes, or enforce our legal agreements or policies.
  • Legal grounds for processing Personal Data on Customer Properties. For Users who access the Nara Player Technology from IP addresses in the EEA, Switzerland, or the UK, we process the elements of Usage Data and Tracking Data that are considered Personal Data under the GDPR. The GDPR makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). When we handle Personal Data strictly on behalf of our customers in order to provide our services to them, as is the case with the Nara Player Technology, we are a data processor and our customers, as the data controllers, have primary responsibility for your Personal Data and are responsible for obtaining a legal basis to collect such data. If you have questions about Personal Data that is used primarily by a Customer Property on which the Nara Player Technology is embedded or utilized, you should contact those companies with your questions about how they handle your Personal Data.

With that in mind, if you have concerns about Nara Player, you may contact our privacy officer, at privacy@naravoice.com.

b. How We May Use Usage Data and Tracking Data. We use Usage Data and Tracking Data collected by the Nara Player Technology for the following purposes:

  • Deliver audio to Customer Properties, and ads on behalf of advertisers.
  • Recommend audio that a User may enjoy.
  • Prepare reports and analytics for our customers.
  • For our other business purposes, such as data analysis, identifying usage trends, diagnosing technical problems, operating, maintaining, enhancing and improving the Nara Player Technology and Nara Player Service, and developing new products and services.
  • As we believe appropriate for Compliance Purposes.

c. When We May Disclose Usage and Tracking Data. We may disclose Usage Data and Tracking Data collected by the Nara Player Technology for the following purposes:

  • Service Providers. To third-party service providers who provide services such as hosting, data analysis, IT infrastructure, IT services, customer service, auditing, security, fraud, and other similar functions to us or our Customers. These third parties have access to User Usage and Tracking Data to perform these tasks on our behalf.
  • Transfer of Business. To a third party to which we have transferred our business, assets or stock in the event that Nara is involved in a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of some or all of our business, assets or stock, including during due diligence related to any such transaction (and also including in connection with any bankruptcy or similar proceeding).
  • As we believe appropriate for Compliance Purposes.
3. USER CHOICES FOR THE NARA PLAYER TECHNOLOGY
  1. For Users who access the Nara Player Technology from the EEA, Switzerland, and the UK: The Do Not Track Browser Setting. Certain versions of the Nara Player Technology support Do Not Track for Users in the EEA, Switzerland, and the UK. Do Not Track is a preference Users can set in their web browser to inform websites that they do not want to be tracked. Users can enable or disable Do Not Track by visiting the Preferences or Settings page of their web browser. We make reasonable efforts to maintain compatibility between our technology and Do Not Track functionality across different web browsers. However, you should be aware that, despite our reasonable efforts, there may be circumstances in which a particular Do Not Track setting is not recognized and honored.
  2. Note that even if a User enables and Nara Player recognizes Do Not Track, the Nara Player Technology will continue to collect Usage Data about each visit to a Customer Property, because Usage Data are automatically sent by the User’s web browser. However, the Usage Data will not be associated with a unique identifier, and the Nara Player Technology will not be able to associate such User Data collected with User.

  3. Check Our Customers’ Privacy Policy. Users interact with the Nara Player Technology, because our Customers have implemented the Nara Player Technology in their Customer Properties. We recommend that Users check the privacy policy of the Customer Properties that they visit for information about the user choices available from our Customers. Many Customer Properties use third-party advertising companies for interest-based advertising or online behavioral advertising. If you want more information about these third-party advertising companies, please visit the ad industry choice mechanism at www.aboutads.info/choices/.
4. FOR USERS WHO ACCESS THE NARA PLAYER TECHNOLOGY FROM THE EEA, SWITZERLAND, AND THE UK: TRANSFER OF INFORMATION

See 1 for information regarding those elements of Usage Data and Tracking Data that are Personal Information under the GDPR.

5. SERVICE PROVIDERS

We work with third parties that provide services and functionality for the Nara Player Technology. These service providers may have access to Usage Data and Tracking Data of the Nara Player Technology in order to perform tasks on our behalf. Occasionally, we may give our service providers explicit permission to use the Usage Data or Tracking Data to enhance the fraud-detection, security, or other features of their services. At our Customers’ instruction, we work with the service providers of our Customers. We may provide Usage Data and Tracking Data collected on a Customer Property to that Customer’s service providers.

C. Other Information


1. ABOUT DATA SECURITY

Nara employs security measures to prevent the loss, misuse or alteration of information collected by the Corporate Website and Nara Player Technology. However, no data transmission over the Internet or data security system can be guaranteed to be 100% secure.

2. LINKS TO OTHER SITES

Our Corporate Website and Nara Player Technology may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

3. CHILDREN’S PRIVACY

The Corporate Website and Nara Player Technology are not targeted to anyone under the age of 13 (“Child”). We do not knowingly collect Personal Data from anyone under the age of 13, unless agreed in writing with a particular Customer. If we know that the Personal Data we have collected is from or about a Child, we place that Personal Data in a separate category for restrictive handling. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a Child without verification of parental consent, we will take steps to remove that information from our servers.

4. RECOURSE, PRIVACY COMPLAINTS BY EUROPEAN UNION AND SWISS RESIDENTS: PRIVACY SHIELD

Nara complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States, respectively. Nara is subject to the investigatory and enforcement powers of the FTC with respect to our adherence to Privacy Shield. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program please visit www.privacyshield.gov. In compliance with the EU-US and Swiss-US Privacy Shield Principles, Nara commits to resolve complaints about your privacy and our collection or use of your Personal Data. In the hope that we can resolve any complaints or questions that you have in a fair an amicable way, we ask that European Union and Swiss individuals with inquiries or complaints regarding this privacy policy first contact us via email at: privacy@naravoice.com. Nara has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

D. How to Contact Nara


If you have any questions about this Privacy Policy, please contact us at:

Email

privacy@naravoice.com


Address

Nara Voice Inc (“Nara”)

29 Norman Ave

Brooklyn, NY 11222

USA