ORAI, INC.

PRIVACY POLICY

Orai respects the privacy of our users personal information and content. We want to earn user trust by being careful and transparent about user generated data.

This Privacy Policy explains what information Orai, Inc., a Delaware corporation (“Orai”, “us”, “we”, or “our”) collects about you and why, what we may do with that information and how we handle your Personal Information and User Content.

This Privacy Policy is incorporated and made part of Orai’s Terms of Service located at oraiapp.com/tos (the “Terms of Service”), and applies to the information obtained by us through your use of the Site,the App, the Services, the Software (collectively, the “Site”) and other Orai products and services.

WHAT INFORMATION DO WE COLLECT?

A list of the Personal Information Orai may collect, and why we collect it, follows:

Gathering this kind of information helps us administer our Products, provide convenient and personalized user access and improve the features and usability of our Products.

In addition, we gather information that indicates your association with one of our business partners or certain promotions. We use this information to determine the amount of revenue share payments to make to partners with whom we might have such arrangements and to provide anonymized aggregate reports.

HOW DO WE USE YOUR INFORMATION?

We may use the information we collect from you when you register, purchase products or services, respond to a survey or marketing communication or other Orai request, surf or use services offered through Orai, or use certain other Orai features in the following ways:

PERSONAL INFORMATION OR USER CONTENT:

Orai does not sell or rent user information, and we only disclose information when:

We do not share your information with third parties for the purpose of enabling them to deliver their advertisements to you.

However, non-personally identifiable information may be provided to other parties for industry or communication research, analysis, demographic profiling, publications, norm development or other uses.

DELETION/CORRECTION/UPDATING PERSONAL INFORMATION

You can correct or update your personally identifiable information, updating your account in the app, or by contacting us at the email mentioned below.

DO WE REVIEW USER CONTENT?

As a rule, Orai employees do not monitor or view your Personal Information or User Content stored in or transferred through our Products, but it may be viewed if we believe the Terms of Service have been violated and confirmation is required, if we need to do so in order to respond to your requests for user support, if we otherwise determine that we have an obligation to review it as described in the Terms of Service, or to improve our algorithms as described in the User Content section of our Terms of Service. Finally, your Personal Information may be viewed where necessary to protect the rights, property or personal safety of Orai and its users, or in order to comply with our legal obligations, such as responding to warrants, court orders or other legal process.

DO WE EVER MAKE ANY OF YOUR PERSONAL INFORMATION OR USER CONTENT PUBLIC?

No, except as otherwise described in this Policy.

Information access and disclosure

Does Orai share my Information?

We only disclose Personal Data to third parties when:

We may disclose Non-Personal Data publicly and to third parties – for example, in public reports about speech patterns, to partners under agreement with us, or as part of progress reports we may provide to users. We also use this in order to help users compare themselves to the general norm.

Orai does not share your Personal Data with third parties for the purpose of enabling them to deliver their advertisements to you.

Does Orai sell or rent my Personal Data?

No, Orai does not sell or rent your Personal Data.

Does Orai use cookies?

Cookies are small text files stored on your device and used by web browsers to deliver personalized content and remember logins and account settings. Orai uses cookies and similar technologies, including tracking pixels and web beacons, to collect usage and analytic data that helps us provide our Site, Software, and/or Services to you, as well as to help deliver ads for relevant Orai products and services to you when you visit certain pages on the Site and then visit certain third-party sites. Our products currently do not respond to Do Not Track requests.

Will Orai send me emails?

From time to time, we may want to contact you with information about product announcements, software updates, and special offers. We also may want to contact you with information about products and services from our business partners. You may opt out of such communications at any time by clicking the “unsubscribe” link found within Orai emails and changing your contact preferences. All Orai account holders will continue to receive transactional messages related to our Services, even if you unsubscribe from promotional emails.

For EEA users: We only send marketing communications to users located in the EEA with your prior consent.

Does Orai ever make any of my Personal Data or User Content public?

No, we do not share Personal Data or User Content except in the limited circumstances described by this Policy or Our Terms of Service.

Does Orai collect information from children?

Orai does not knowingly collect personal information from children under the age of 13. If we determine we have collected personal information from a child younger than 13 years of age, we will take reasonable measures to remove that information from our systems. If you are under the age of 13, please do not submit any personal information through the Site, Service, and/or Software. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Site, Service, and/or Software without their permission.

BILLING INFORMATION

Currently Orai does not directly obtain or process any Billing Information from our mobile application. Please refer to processing policies of the Google Play Store® and the Apple App Store®.

Data storage, transfer, retention, and deletion

Where is my Information stored?

Information submitted to Orai will be transferred to, processed, and stored in the United States. When you use the Software on your computing device, User Content you save will be stored locally on that device and synced with our servers. If you post or transfer any Information to or through our Site, Software, and/or Services, you are agreeing to such Information, including Personal Data and User Content, being hosted and accessed in the United States.

How secure is my Information?

Orai is committed to protecting the security of your Information and takes reasonable precautions to protect it. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure, and as a result, we cannot ensure the security of Information you transmit to us, including Personal Data and User Content; accordingly, you acknowledge that you do so at your own risk.

We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology.

Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. The security of the data stored locally in any of our Software installed on your computing device requires that you make use of the security features of your device. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Site, Software, and Services.

If Orai learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the Site.

How can I delete my Personal Account from Orai?

Please contact us regarding deletion of personal data from Orai at the contact information mentioned below.

What happens if you stop using orai ?

You can stop using our Products at any time. Residual copies of your Personal Information and deleted User Content may continue to exist on Orai’s back-up and archiving systems for up to one year due to the nature of those systems’ operations. You can contact us at anytime to request deletion of your data.

How long is Personal Data retained ?

You can remove your Personal Data from Orai at any time by deleting your account as described above. However, we may keep some of your Personal Data for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations.

What happens if Orai closes my account?

If Orai closes your account due to your violation of the Terms of Service, then you may contact Orai to request deletion of your data. We will evaluate such requests on a case by case basis, pursuant to our legal obligations. Depending on the case we may delete all your data when closing your account as well.

For EEA users

Orai uses, processes, and stores Personal Data , as necessary to perform our contract with you, and based on our legitimate interests in order to provide the Services. We rely on your consent to process Personal Data to send promotional emails and to place cookies on your devices. In some cases, Orai may process Personal Data pursuant to legal obligation or to protect your vital interests or those of another person.

What rights do I have, and how can I exercise them?

Individuals located in the European Economic Area (EEA) have certain rights in respect to their personal information, including the right to access, correct, or delete Personal Data we process through your use of the Site, Software, and/or Services. If you’re a user based in the EEA, you can:

Who is our EEA Representative?

To obtain our EEA representative information please contact EEA@oraiapp.com

Will this Privacy Policy ever change?

As Orai evolves, we may need to update this Policy to keep pace with changes in our Site, Software, and Services, our business, and laws applicable to us and you. We will, however, always maintain our commitment to respect your privacy. We will notify you of any material changes that impact your rights under this Policy by email (to your most recently provided email address) or post any other revisions to this Policy, along with their effective date, in an easy-to-find area of the Site, so we recommend that you periodically check back here to stay informed of any changes. Please note that your continued use of Orai after any change means that you agree with, and consent to be bound by, the new Policy. If you disagree with any changes in this Policy and do not wish your information to be subject to it, you will need to delete your Orai account.

YOUR CALIFORNIA PRIVACY RIGHTS

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2017 will receive information regarding 2016 sharing activities).

To obtain this information from Orai please send an email message to hello@oraiapp.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Contact us

Email: hello@oraiapp.com

Orai, Inc.

3230 Market Street

Philadelphia PA

19104

USA