Privacy Policy Effective Date: December 17th, 2020

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Oromoon, Inc. (“us”, “we”, or “our”) operates the https://oromoon.com website and the Oromoon mobile application (the “App”).

Welcome to the Oromoon Privacy Policy ("Policy"). This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our Terms and Conditions. Whilst you're enjoying the Oromoon mobile application ("App"), we collect some information about you. In addition, you may choose to use the App to share information with other members of the Oromoon community, including your friends and contacts ("Guests"). We may also need to share your information sometimes.

If you have any questions or comments about this Policy, please feel free to contact us at ➪ support@oromoon.com

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1. Information Collection

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i. Registration‍

When you download the App and create an account ("Account"), we may collect certain information ("Registration Information") about you, such as:

• Name;
• Email address;
• Mobile number;
• Gender identity;
• Date of birth;
• Time of birth;
• Location of birth;
• Sexual preference;
• Photographs;
• Location;
• Other information (“Personal Information”); and
• Login information and friend lists for social media accounts that you connect to your Oromoon Account (this could include, for example, your Instagram or Spotify account (“Social Media Accounts”).

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Once you register, you will be able to review and make changes to this information at any time by accessing your “Settings.” You control your user profile and are able to correct or update your information at any time simply by logging into Oromoon.

The information we collect helps to enhance the App and verify our Guests (robots not welcome). Registration Information such as your name and age may be visible to the public on your profile page.

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ii. Additional Information

We may ask you to provide your full name, address and email address. Such details may be shared with third parties for purposes relating to, for example, any of our loyalty programs, sending gifts or delivery of merchandise.

We may also collect additional information in connection with your use of Oromoon, for example if you use our messaging function.

If you contact our Customer Support team, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you).

We recommend and encourage you (and all our guests) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ license details and other sensitive information on your profile which is open to abuse and misuse.

Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. You may also choose to add sensitive information about yourself, such as your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on Oromoon may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of your information and making this public to other users.

When you post information about yourself or use the messaging function, the amount of personal information you share is at your own risk. Please see below for more information on who can access what you post on Oromoon. If you post anything that is inconsistent with our Terms and Conditions, we reserve the right to terminate your Account.

For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and might ask for your phone number. We want to make sure you’re human and avoid fake Oromoon accounts being created which can be used for malicious activities and cybercrime—they threaten the Oromoon network and spoil the fun for our guests. We use a third-party provider for account verification who will keep your phone number for up to 90 days for fraud identification purposes. We collect and use your phone number on the basis of our legitimate interests identified below and for the prevention of fraud.

It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

To prevent abuse of the app/site, Oromoon uses automated decisions to block accounts as part of its anti-spam procedures. In order to do this, our systems check accounts and messages for content that indicates breaches of our Terms and Conditions. If an account or message meets certain criteria that demonstrate that the Terms and Conditions are likely to have been breached, the relevant account will automatically be blocked. All users of accounts that have been blocked will be notified that their account has been blocked and affected users can contact Oromoon to contest the decision.

Please note that if your account is blocked, any account(s) that you have on our other group platforms/applications may also be blocked as part of our anti-spam and anti-fraud procedures.

If you decide to purchase any of our premium Apps, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

For users who are California residents, the data we may collect falls within the following categories of “Personal Information,” as defined by the California Consumer Privacy Act (CCPA):

1. Identifiers, such as name and location;
2. Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
3. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
4. Commercial information, such as transaction information and purchase history;
5. Biometric information (notrelevant here);
6. Internet or network activity information, such as browsing history and interactions with our websites and apps;
7. Geolocation data, such as mobile device location;
8. Audio, electronic, visual and similar information, such as photos and videos;
9. Professional or employment-related information, such as work history and prior employer;
10. Non-public education information; and
11. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

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iii. Log & Usage Data

When you access the App by or through a mobile device, we may collect certain information automatically, including but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, and the type of mobile Internet browser you use and other statistics (“Log Data”) as long as required for legitimate business purposes and as permitted by applicable law.

We delete or anonymize your information upon deletion of your account (following the safety retention window), unless:

1. We must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
2. We must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
3. There is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. The information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

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In addition, we may use third-party Apps such as Google Analytics that collect, monitor and analyze this type of information in order to increase our App's functionality. These third-party App providers have their own privacy policies addressing how they use such information.

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iv. Google Analytics

Google Analytics is a web analytics App offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our App. This data is shared with other Google Apps. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy and Terms web page ➪ https://policies.google.com/privacy?hl=en

Please see the section regarding Location Information below regarding the use of your location information and your options.

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v. Data Storage

By using our App, you acknowledge that Oromoon is a global app operating through servers located in the United States. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence.

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vi. Device Information

We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address.

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vii. Links

We may keep track of how you interact with links available on Oromoon including third-party Apps and clients by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

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viii. Geolocation Information

We may use and store information about your location depending on the permissions you have set on your device. We will collect information on longitude and latitude and may save your device’s coordinates to offer you particular features. We use this information to provide features of our App by enabling the information to be displayed and shared with other members choosing to view “nearby” posts, and to improve and customize our App. You can enable or disable location Apps when you use our App at any time through your iPhone app mobile device settings by following these steps:

1. Settings
2. Privacy
3. Location Apps
4. Oromoon

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ix. Cookies

They are small data files that are transferred to your computer’s hard disk; they are basically a tool that stores information about website visits, recognizes you and your preferences each time you visit Oromoon, and ensures site functionality and enables us to provide the services our members request.

The cookies we collect enable us to learn how people interact with Oromoon, helping us make a better product for you. Cookies store information about your website visits and can recognize you and your preferences each time you visit the Oromoon site. They help us to provide you with better service.

Oromoon’s use of cookies and local storage devices is basically related to the performance of Oromoon’s site, such as analytics that help us determine how our site is performing and ensuring a smooth and trouble-free experience for our members and visitors.

Below explains Oromoon’s cookie functions and why they’re used.

If for any reason you decide that you do not want all of your Oromoon activities to be stored you may set your browser and mobile settings to block cookies and local storage devices, but please remember that if you do so, you may not be able to access all of the features Oromoon offers.

We use the following types of cookies:

1. Analytics and Research

We use Google Analytics to collect information about how visitors use the site. The cookies collect information in an anonymous form, including the number of visitors to the App, where visitors have come from and the pages they visited. For more information about Google’s Privacy Policy, please visit http://www.google.com/intl/en/policies/.

   2. Performance

We need to use certain cookies and save data to your local storage devices to ensure our members have the best possible experience. They assist with your navigation of our site, ensuring pages load quickly and respond promptly to your requests.

Our use of cookies and local storage devices, including the specific cookie names, may change overtime, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. Please visit this page regularly so that you are aware of any changes.

If you would like to know more about cookies, including flash cookies/local storage devices, the following websites provide useful information:

• www.allaboutcookies.org
• www.youronlinechoices.eu
• http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html

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2. Use of Information

Our main goal is to ensure your experience on Oromoon is safe as much as it's enjoyable. In order to achieve an enjoyable experience to you, we may use your Registration and other information to:

• offer you our services and features;
• contact you with information about the App (e.g., updates and new offerings);
• personalize the App and the content we deliver to you;
• conduct research and analytics about how you use and interact with the App;
• resolve disputes between you and other Users; and
• investigate fraud, protect our legal rights, and to enforce our Terms and Conditions.

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3. Disclosure of Information

Our policy is to not disclose your Registration Information, except in the limited circumstances described here:

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i. Your Consent

If you consent, we may share or disclose your Registration Information, such as when you use a third-party web client or application to access your Account. [This could include all data, including all CCPA Categories listed above].

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ii. Service Providers

We may employ third-party companies and individuals to facilitate our App, to provide the App on our behalf, to perform App-related Apps and/or to assist us in analyzing how our App is used. 

These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose. [This could include all data, including all CCPACategories listed above].

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iii. Moderators

To monitor activity on the apps and approve content. [Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, E, and H)].

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iv. Advertising Partners

To serve targeted advertisements to Guests. [DeviceID, geolocation data, demographic data (CCPA Categories C, F, and G)].

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v. Payment Processing and Telecommunications Companies

To facilitate payments for our premium services. [Card holder name, cardholder address, card number, payment amount, transaction date/time(CCPA Categories A, B, and D)].

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vi. Law and Harm

As we mentioned in the Terms and Conditions, we find it important that all Oromoon Guests behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behavior or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us. [This could include any personal data that Oromoon holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above].

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vii. Compliance with Laws

As mentioned in the Terms and Conditions, we think it is very important that all Oromoon Guests behave responsibly and with compassion when using our App. We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our App.  

Oromoon, Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation.
• To protect and defend the rights or property of Oromoon, Inc.
• To prevent or investigate possible wrongdoing in connection with the App.
• To protect the personal safety of Guests of the App or the public.
• To protect against legal liability.

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We will cooperate with all third-parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behavior or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g.,through anti-spam providers to protect the App from criminal activity or to protect our rights or property or those of third-parties. In such cases we may raise or waive any legal objection or right available to us.

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viii. Business Transfers

In the event that Oromoon or any of our affiliates that undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data. [This could include any personal data that Oromoon holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above].

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ix. Anti-Spam and Anti-Fraud

Your data may be shared with other Oromoon group companies, for example, to block accounts and suspected fraudulent payment transactions aspart of our anti-spam and anti-fraud procedures. [Email address, phone number, IP address and IP session information, social network ID, username, user agent string, and transaction and payment data (CCPA Categories B, F and D)].

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x. Aggregated Information

We may share aggregated information with third-parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling. You may opt-out of receiving marketing messages by using the opt-out mechanisms and links provided in each email.

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

Oromoon does not sell your data and has not sold your personal data in the previous 12 months.

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4. What Others May See About You

Our App is designed to make it easier for you to connect with other Guests and to interact with them. When using Oromoon, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Guests of the App and non-Guests of the App. We want our Oromoon Guests to be careful about posting information that will eventually be made public.

We think our Guests are awesome, and we want you to share how awesome you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them. If you register or log in to the App using your Facebook account, you are authorizing us to access certain Facebook account information, including information you make available via Facebook, your friends list, current location and those friends you have in common with other Guests. You also understand that your Oromoon profile and other information you make available via the App, including information you provide directly or indirectly through Facebook (i.e., your photos, your name, age, approximate location, and other profile information), may be viewed and shared by Guests with individuals who may or may not be Users or via third party applications in such Guests’ discretion. You might share information like the photos and messages you send or upload and any metadata provided with those messages, along with any comments or information you provide in connection with your photos.

When using Oromoon, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both byUsers of the App and non-Users of the App. We want our Guests to be careful about posting information that will eventually be made public.

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5. Security

At Oromoon we pride ourselves on taking reasonable security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.

No website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

1. Please make sure you log out of your Account after use; you may never know who may stumble onto your Account.

We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.

WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORIZED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.

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6. Transfer of Data

Your information, including Personal Information, may be transferred to (and maintained on) computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the information, including Personal Information, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

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7. Links to Other Sites

Our App 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 since you are giving them personal information when register with a third-party.

We have no control over, and assume no responsibility for the content, Privacy Policy or practices of any third-party sites or Apps.

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8. Modifying Your Registration Information

You may access or modify the Registration Information you provided at any time or permanently delete your Account. When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. For up to 30 days it is still possible to restore your Account if it was accidentally or wrongfully deactivated. After 30 days, we begin the process of deleting your Account from our systems. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.

To prevent abuse and/or misuse of Oromoon by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our Terms and Conditions and to ensure compliance with all laws and regulations.

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other Users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third-party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of App or privacy policies.

Removed and deleted information may persist in backup copies for up to 30 days to enable restoration, but will not be available to others in the meantime.

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9. Our Policy Towards Age:

Only persons age 18 or older have permission to access and use our App. Our App does not address anyone under the age of 18 ("Children”).

We do not knowingly collect personally identifiable information about or market to Children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us ASAP via email ➪ support@oromoon.com. If we become aware that Children, minors or anyone under the age of 18 have registered with us and provided us with Personal Information, we take immediate steps to remove and terminate that person’s registration and delete their Registration Information from Oromoon and our servers. If we do delete a profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new profile.

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10. Changes to this Privacy Policy

This Privacy Policy is effective as of November 22, 2020 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time as Oromoon evolves, and we recommend you check this Privacy Policy periodically. Your continued use or access of the App after we post any modifications to the Privacy Policy on this page and after those changes become effective, will constitute your acknowledgment and agreement of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

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11. Your California Privacy Rights

For users who are California residents, you have the following rights (in addition to those listed at section 11 below) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

There are three types of content that you will be able to access on the App:

1. You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

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California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us via email ➪ support@oromoon.com

From time to time we may disclose your contact information to third parties to allow them to market their products or Apps to you or for other marketing purposes. This may be information we received from you offline and online. If you want us to stop further sharing your email contact information with third parties (if we have your email contact information), you may notify us via email ➪ support@oromoon.com. Please follow the instructions provided to you by third parties to unsubscribe from their messages. If you have opted-out as described above, and thereafter you choose to use a App or promotion that requires us to contact you or share your information with a third-party, then your previous opt-out preferences will not apply to such App.

In addition, under California law, operators of online Apps are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third-party online Apps, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online Apps. This law also requires operators of online Apps to disclose whether third parties may collect personal information about their users’ online activities over time and across different online Apps when the users use the operator’s App. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online Apps when using the App.

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12. About Us

Your access to the App, as well as this Privacy Policy are governed and interpreted by the laws of the State of New York, other than such laws, rules, regulations and case law that would result in the application of the laws of a jurisdiction other than the State of New York. By using the App, you are consenting to the exclusive jurisdiction of the courts of the United States and the State of New York. You agree that such courts shall have personal jurisdiction and venue and waive any objection based on inconvenient forum. You agree that you will not file or participate in a class action against us. In the event there is a discrepancy between this English language version and any translated copies of the Policy, the English version shall prevail.

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13. Contact Us

If you have any questions about this Privacy Policy, please contact us via email ➪ support@oromoon.com

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