Effective Date: 01/01/23
Table of Contents
1. Collection of Information We may collect your personal information when you interact with us through the Website, share your information with us, or by other means. We may also automatically collect information regarding your use of our Website.
2. Use of Information We may use your personal information for various purposes connected with your interest in Aurora and our Products and Services, and to allow us to maintain and improve them.
3. Sharing of Information We may share your personal information with certain third parties, such as with our service providers, as directed by you, and to provide you with opportunities that we believe may be of interest to you.
4. Children’s Privacy You must be at least 16 years old or older to use our sites.
5. Information Security The security of your personal information is of utmost importance to us and we maintain appropriate safeguards to protect it.
6. Transfer of Information to the U.S. and Other Countries Aurora is based in the United States and personal information you provide will be transferred to the U.S. and other countries.
7. Linked Sites Our Website may contain links to other websites that are not operated by us and that are subject to third party privacy policies and other terms.
8. Your Rights and Choices You may have certain rights and choices regarding our collection, use, and disclosure of your personal information.
9. Cookies and Tracking Technologies When you visit the Website, we may collect certain information from you automatically through cookies and other tracking technologies.
10. California Privacy Notice We provide additional disclosures and rights to California residents.
11. Contact Us You may contact us for comments or questions in various ways.
Collection of Information
a. Information You Provide to Aurora
We collect personal information you voluntarily provide directly to us. For example, we may collect personal information when you fill out a form, provide feedback, participate in any interactive features of the Website, participate in a contest or promotion, communicate with us via third party sites, or otherwise communicate with us, such as in connection with our Products and Services. The types of personal information we may collect directly from you include your first and last name, email address, postal address, phone number, and any other information you choose to provide.
b. Information We Collect Automatically
When you visit our Website, Aurora may automatically collect personal information about you, through the following technologies:
Log Information: We may collect log information about your use of the Website, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Website.
Other similar technologies: We may also automatically collect personal information through Web beacons, tracking pixels, and other tracking technologies on our Website. For example, Aurora uses Google Analytics to help us understand your use of our Website and improve your experience. You can learn about opting-out of Google’s collection by visiting this site.
We also collect personal information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. For example, we use Google Analytics on our Website to help us analyze your use of our Website and diagnose technical issues.
Please review our “Cookie and Other Tracking Technologies” section below for more information.
c. Information Aurora Collects From Other Sources
Use of Information
We may use your personal information for various purposes, including to:
Provide, maintain, and improve Aurora’s Website and its Products and Services;
Provide any information you request;
Respond to your comments, questions, and requests;
Communicate with you about Products and Services, as well as offers, promotions, rewards, and events offered by Aurora and others, or provide news and information we think will be of interest to you;
Monitor and analyze trends, usage, or activities in connection with the Website;
Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Aurora and others;
To maintain and improve the quality of the Website and our Products and Services, including to perform research and development, understanding trends, and understanding the effectiveness of our marketing and advertising;
Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
Link or combine with information we get from others to help understand your needs and provide you with better service;
To serve our advertisements to you through third-party platforms, on other sites and apps or across your devices, as may be consistent with notice and any opt-in or opt-out rights for such uses under applicable law;
Effectuate our performance on any contracts or agreements that we may have with you or others; and
Comply with our legal obligations; respond to subpoenas, court orders or legal process; and to establish or exercise our legal rights or defense against legal claims.
3. Sharing of Information
We may disclose your personal information with the following categories of service providers and third parties:
Our service providers. We may share your personal information with vendors, consultants, and other service providers who need access to such personal information to carry out work on our behalf.
Law Enforcement. In accordance with or as required by any applicable law, regulation, or legal process, such as in response to a subpoena, government inquiry, litigation, dispute resolution or similar legal process, or when we believe in good faith your actions are inconsistent with our user agreements or policies, or doing so is necessary to either protect the rights, property and safety of Aurora or others or to investigate fraud.
Business transfers. We may share your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.
Our affiliates. We may share your personal information between and among Aurora and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership.
We may also share aggregated or de-identified information that cannot reasonably be linked to you.
The Website may offer social sharing features and other integrated tools, which let you share information with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
4. Children’s Privacy
Aurora does not intentionally or knowingly collect personal information from children under the age of 16. If we find out that a child under 16 has given us personal information, we will take steps to delete that information. If you are a parent or guardian and you are aware that a child under the age of 16 has provided us with personal information without parental consent, please contact us at email@example.com.
5. Information Security
Aurora takes reasonable and generally accepted measures to help protect your personal information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure or misuse.
6. Transfer of Information to the U.S. and Other Countries
Aurora is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Website or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the U.S. and other countries, where you may not have the same rights and protections as you do under local law, and in certain circumstances, your personal information may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions.
7. Linked Sites
The Website may contain links to third-party websites that are not owned or controlled by Aurora. Aurora has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third-party websites, including third-party websites enabling our social media presence. Please review the privacy policies of any sites you visit before providing information to or otherwise using those third-party websites.
8. Your Rights and Choices
Your California privacy rights. California residents have certain rights with respect to our collection, use, and sharing of their personal information. Please review our California Privacy Notice for more information about those rights.
9. Cookies and Tracking Technologies
Necessity. To enable features that are necessary for providing you the services on our Sites, such as keeping you signed in, improving security, and preventing and detecting fraud.
Preference. To allow us to remember your preferences and identify you when you return to our Sites.
Analytics. To allow us to understand how our Sites are being used, track site performance and content views, and make improvements to the content, products or services.
Advertising. To deliver targeted advertising based on your preferences, location, and/or interests across different services and devices and measuring effectiveness of ads.
Social Media. To enable the sharing of content from our Sites through social networking and other sites.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Website.
If you wish to opt out of our sharing of the data that is gathered when you visit our Site for purposes of targeted digital advertising, we encourage you to visit the Network Advertising Initiative or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements. You may also visit these websites for more information on how you can opt back into the sharing of data.
Opting out of advertising networks does not necessarily mean that you will not receive advertisements while using our Website or on other websites.
We do not support Do Not Track functionality. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
10. California Privacy Notice
For the purposes of this California Privacy Notice, except where a different definition is noted, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or California household. For California residents or California households, personal information does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified; or information that has been aggregated. For purposes of this section, “publicly available information” includes: information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.
Please note that because Aurora’s Products and Services are generally not available to consumers or the general public, the majority of the personal information subject to this California Privacy Notice is personal information collected about individuals acting in an employment, contractor, or other agency capacity for business, government organization, or other legal entity with which Aurora does business (“Business-to-Business Data” or “B2B Data”).
The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to access, delete, and restrict the sale of certain personal information we collect about them. California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA. If you are a California resident, you may submit a request to exercise these rights by completing our online webform or by emailing us using the information provided in the Your Privacy Rights section below.
a. Personal Information We Collect
Aurora may collect, or has collected, the following categories of personal information over the past twelve (12) months:
Identifiers, which includes first and last name; email address; postal address; telephone number; and Internet Protocol (“IP”) address.
Professional or employment-related information, which includes, as may be collected from our business-to-business contacts, employer name and location; job title or role; business unit or division; and professional memberships, licensing, and certifications.
Internet or other electronic network activity information, which includes cookie identifiers; tracking pixels containing an ID number; online tracking technology; IP address; browser software; your computer’s operating system; the website that referred you to our site and/or the search terms you entered into a search engine to reach our site; internet service provider (“ISP”); date/time stamp; clickstream data; keylogging and computer mouse movement tracking; and device platform, version, and other device characteristics which may include settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”);
Geolocation, which includes approximate location collected from a device’s IP address;
Audio, electronic, visual, thermal, olfactory, or similar information, which includes photographic images; and call and voicemail recordings.
Voluntary information or inferences drawn from the personal information listed above.
Please note that because of the overlapping nature of certain of the categories of personal information identified above, which are required by state law, some of the personal information we collect may be reasonably classified under multiple categories.
b. Uses of Personal Information
Identify and communicate with employees and other representatives of Aurora’s enterprise and institutional customers and potential customers;
Maintain and improve Aurora’s ability to serve those individuals and the enterprises and institutions that they represent; and
Negotiate, execute, and perform on contracts and other arrangements to receive our Products and Services.
We will retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether you have provided, and the nature of, your directions and/or consent to us or others; (iii) whether there is a legal obligation to which we are subject; (iv) whether there is a privacy right for which the personal information has been exercised (such as a request to delete); and (v) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
c. Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
From our business partners and others, including our current and potential customers and our industry partners.
We may supplement the personal information collected from the categories of sources described above with personal information we obtain from other sources.
d. Disclosure of Personal Information
This includes disclosure of your personal information to service providers for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed each category of personal information listed in Section 10(a) for a business purpose.
Aurora does not “sell” personal information to third parties for monetary or other valuable consideration as that term is defined by the CCPA.
The CCPA requires us to identify the categories of personal information that we have “sold” or “shared” under the CCPA in the preceding twelve (12) months.
In the last twelve (12) months, we have disclosed (or “shared”) the following categories of personal information to advertising partners for cross-context behavioral advertising purposes:
Internet or other electronic network activity information
e. Your Privacy Rights
If you are a California resident, you have the right to make the following requests under applicable California law in relation to your personal information, subject to certain exceptions:
Right to Know. You have the right to, up to twice in a 12-month period, request what personal information we collect, use, disclose, and/or sell, and to whom, as applicable, as well as the categories of sources from which the personal information is collected, the purposes of collecting, using, or sharing the personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information that we collect.
Right to Delete. You have the right to request, under certain circumstances, the deletion of your personal information that we collect.
Right to Opt-Out of Sale or Sharing. You have the right to opt-out of the sale or sharing of your personal information as those terms are defined under California law.
Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide employment-related services to you. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Right to Correct. You have the right to request the correction of your inaccurate personal information.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
How to submit a request. You may exercise any of the rights described in this section by emailing us at firstname.lastname@example.org, by utilizing our interactive webform and following the instructions, or by calling 1 (888) 583-9506.
Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on. To verify you, you must provide us with first name, last name, and e-mail address. These rights are also subject to various exclusions and exceptions under applicable laws.
Authorized agents. You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. If you should use an authorized agent to exercise your various rights under the CCPA, we may require that you provide your authorized agent with written permission to exercise your various rights and to verify your own identity with us. If your authorized agent does not submit proof that they have been authorized by you to submit verified requests for disclosure and deletion, we reserve the right to deny such a request that we have received and will explain to your authorized agent why we have denied such request. The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to email@example.com.
Household data. We currently do not collect household data. If we receive a request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13, as we do not collect personal information from any person under the age of 13.
Responses. We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.
We will continue to update our business practices as direct regulatory guidance becomes available.
f. Notice of Right to Opt-Out
If you wish to opt-out of the “sharing” of personal information for purposes of cross-context behavioral advertising, as described in Sections 10(d) and 10(e) above, please utilize our webform or contact us using the information in the “Contact Us” section below.
Aurora Operations, Inc.
Phone: 1 (888) 583-9506
Mailing address: 280 N. Bernardo Avenue
Mountain View, CA 94043