Privacy policy

At Nara, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.

Remember that your use of Nara's Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Site, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

If you are a resident of a U.S. state with a consumer privacy law like Washington, Nevada, or Connecticut, please refer to the Consumer Health Privacy Policy for additional information.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Certain parts of this Privacy Policy may only apply to you if you have a particular relationship with us. You may be a “Visitor” when you visit the Site, sign up for newsletters or product updates, enter a promotional giveaway we may offer, or otherwise engage with us without being a Customer. You may be a “Customer” when you download our mobile application, create a Nara account, download and use our mobile application, purchase a Product or other part of the Services.

Personal Data

Categories of Personal Data We Collect

The following tables describe the kinds of Personal Data we may collect or may have collected about you in the last 12 months. One or more tables may apply to you depending on your relationship with us.

Visitors

Category of Personal Data (and Examples)	Business or Commercial Purpose(s) for Collection	Categories of Third Parties With Whom We Disclose this Personal Data
Contact Data such as first and last name, email, and phone number.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Advertising Partners Business Partners Parties You Authorize, Access or Authenticate
Device/IP Data such as IP address, IP address-based location data, device ID, domain server and type of device/operating system/browser used to access the Services.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Advertising Partners Parties You Authorize, Access or Authenticate
Web Analytics such as web page interactions, referring webpage/source through which you accessed the Services, non-identifiable request IDs, statistics associated with the interaction between device or browser and the Services and browsing or search history.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Advertising Partners Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide such as surveys, emails, letters, and texts you send us, or through promotional giveaways.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Parties You Authorize, Access or Authenticate

Customers:

Category of Personal Data (and Examples)	Business or Commercial Purpose(s) for Collection	Categories of Third Parties With Whom We Disclose this Personal Data
Contact Data such as first and last name, email, phone number, and mailing address.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Business Partners Parties You Authorize, Access or Authenticate
Nara Account Data such as username and unique identifiers.	Providing, Customizing and Improving the Services Corresponding with You	Service Providers
Payment Data such as payment card type, last 4 digits of payment card, billing address, billing phone number and billing email.	Providing, Customizing and Improving the Services Corresponding with You	Service Providers (specifically our payment processing partner, currently Stripe, Inc.)
Commercial Data such as purchase history and related preferences.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Parties You Authorize, Access or Authenticate
Device/IP Data such as IP address, IP address-based location data, device ID, domain server and type of device/operating system/browser used to access the Services.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Parties You Authorize, Access or Authenticate
Web Analytics such as web page interactions, referring webpage/source through which you accessed the Services, non-identifiable request IDs, statistics associated with the interaction between device or browser and the Services and browsing or search history.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Parties You Authorize, Access or Authenticate
Consumer Demographic Data such as, zip code, and your or your child’s date of birth.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Business Partners Parties You Authorize, Access or Authenticate
Sensory Data such as photos or videos that you may upload to the Services.	Providing, Customizing and Improving the Services Corresponding with You	Service Providers Business Partners Parties You Authorize, Access or Authenticate
Categories of Data Considered “Sensitive” Under the U.S. State Privacy Laws such as health data.	As described in the Nara Consumer Health Data Privacy Policy	As described in the Nara Consumer Health Data Privacy Policy
Inferences from Personal Data drawn from your use of our Services (e.g. what kind of features you like to use).	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers
Other Identifying Information that You Voluntarily Choose to Provide such as surveys, reviews, emails, letters, and texts you send us, or through promotional opportunities and giveaways.	Providing, Customizing and Improving the Services Marketing the Services Corresponding with You	Service Providers Business Partners Parties You Authorize, Access or Authenticate

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

Creating and managing your account or other user profiles.
Processing orders or other transactions; billing.
Providing you with the products, services or information you request.
Meeting or fulfilling the reason you provided the information to us.
Providing support and assistance for the Services.
Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, Site content and communications based on your preferences.
Doing fraud protection, security and debugging.
Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), the Colorado Privacy Act (the “CPA”), the Connecticut Data Privacy Act (the “CTDPA”), the Delaware Personal Data Privacy Act (“DPDPA”), the Iowa Consumer Data Protection Act (“ICDPA”), the Montana Consumer Data Privacy Act (“MCDPA”), the Nebraska Data Privacy Act (“NDPA”), the New Hampshire Privacy Act (“NHPA”), the New Jersey Privacy Act (“NJPA”), the Oregon Consumer Privacy Act (“OCPA”), the Texas Data Privacy and Security Act (“TDPSA”), the Utah Consumer Privacy Act (“UCPA”), or the Virginia Consumer Data Protection Act (“VCDPA”) (collectively, the “U.S. State Privacy Laws”).

Marketing the Services

Marketing and selling the Services.
To the extent you are a Visitor, showing you advertisements, including Targeted Advertising.

Corresponding with You

Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Nara or the Services.
Sending emails and other communications according to your preferences.

Other Permitted Purposes for Processing Personal Data

In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Nara or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You
- When you create an account or use our interactive tools, the Site, and the Services.
- When you voluntarily provide information in free-form text boxes through the Site or Services, through responses to surveys or questionnaires, or through promotional events or giveaways.
- When you communicate with us
- Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
- If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
- If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

When you provide such information directly to us.
When you use the Site or Services and such information is collected automatically.

Third Parties
- We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
- We may use vendors to obtain information to generate leads and create user profiles.
- We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.
- That you may permit us to collect data from (such as a social media post).

Vendors
Advertising Partners
Other Third Parties

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the “U.S. State Privacy Rights” section below.

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
- Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment.
- Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.

Hosting, technology and communication providers.
Analytics providers for web traffic or usage of the site.
Security and fraud prevention consultants.
Support and customer service vendors.
Product fulfillment and delivery providers.
Payment processors.

Advertising Partners. These parties help us market our services and provide Visitors with other offers that may be of interest to Visitors. They include:

Ad networks.
Data brokers.
Marketing providers.

Business Partners. These parties partner with us in offering various services. They include:

Businesses that you have a relationship with, interact with, or otherwise direct us to disclose data to.
Companies that we partner with to offer joint promotional offers or opportunities.

Parties You Authorize, Access or Authenticate.

Third parties you access through the services.
Social media services.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Cookies and Targeted Advertising

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
Retargeting/Advertising Cookies. To the extent you are a Visitor, Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Targeted Advertising.”

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our Site and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

Targeted Advertisements

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Site (“Targeted Advertising”). These advertisements may be targeted to individuals who fit certain general profile categories or display certain preferences or behaviors. Targeted Ads may be provided to us by you, or derived from the usage patterns of particular users on the Site and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Site. To accomplish this, we or our third parties (such as our Service Providers or Advertising Partners) may collect or receive Personal Data via Cookies placed via our Site.

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

We retain your profile information and credentials for as long as you have an account with us.
We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at hello@nara.com.

U.S. State Privacy Rights

If you reside in certain U.S. states, such as California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia, you may have certain rights afforded to you (as described below) depending on your state of residence. Please see the “Exercising Your Rights under U.S. State Privacy Laws” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Please note that your rights may be subject to certain conditions or exceptions in accordance with applicable U.S. State Privacy Laws.

If you have any questions about this section or whether any of the following rights apply to you, please contact us at hello@nara.com.

Access: You may have the right to request confirmation of or access to the Personal Data that we process about you. You can also request access to a portable copy of your Personal Data. If you are an Oregon resident, you also have the right to request a list of specific third parties, other than natural persons, to whom we have disclosed Personal Data.
Deletion: You may have the right to request that we delete the Personal Data that we have collected about you.
Correction: You may have the right to request that we correct any inaccurate Personal Data we have collected about you.
Portability: You may have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible

Targeted Advertising

The disclosure of your Personal Data to third parties for the purposes of targeted advertising (also referred to as cross-contextual behavioral advertising or Targeted Advertising, as described in the “Tracking Tools, Advertising and Opt-Out” section above) including via Cookies may be deemed a “sale” or a “share” under certain U.S. State Privacy Laws.. Depending on your state of residence, you may have the right to opt out from these activities. We may share the following categories of Personal Data with Advertising Partners for our advertising purposes.

Contact Data
Device/IP Data
Web Analytics

We do not “sell” your Personal Data for monetary consideration. To our knowledge, we do not sell or share the Personal Data of minors under 18 years of age.

You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the “Exercising Your Rights under U.S. State Privacy Laws” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.

Processing of Sensitive Personal Data

As needed, we may reach out to you to provide us with Personal Data that may be deemed “sensitive” under certain U.S. State Privacy Laws (“Sensitive Personal Data”). The categories of Sensitive Personal Data we collect and our purposes for collecting such Sensitive Personal Data is described in the “Categories of Personal Data We Collect” section above.

Depending on your state of residence, you may either have the right to opt-in, the right to opt-out, or if you are a California resident, the right to limit our use of your Sensitive Personal Data to permitted purposes, by following the instructions in the “Exercising Your Rights under U.S. State Privacy Laws” section.

Anti-Discrimination

We will not discriminate against you for exercising your rights under applicable privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under applicable privacy laws. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

To exercise any of your rights for these certain processing activities, please follow the instructions under the “Exercising Your Rights under U.S. State Privacy Laws” section.

Exercising Your Rights under U.S. State Privacy Laws

To exercise the rights described in this Privacy Policy, you or, if permitted by applicable U.S. State Privacy Laws, your Authorized Agent (if applicable and as defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (for example your Contact Data), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

Request to Opt-Out of Sale, Share and/or Targeted Advertising

You may opt-out from any “sales”, “shares” or targeted advertising, by emailing us at hello@nara.com.

Request to Withdraw Consent for or Opt-Out from the Processing of, or Limit the Use of, Sensitive Personal Data

If you are a California resident, you may request to limit our use of your Sensitive Personal Data to only the permitted purposes set forth in section 7027(m) of the CCPA regulations. If you are a resident of another state, you may withdraw your consent or opt-out from our processing of your Sensitive Personal by emailing us at hello@nara.com.

Request to Withdraw Consent to Certain Processing Activities

As applicable and depending on your state of residence, you may have the right to withdraw your consent allowing us to sell, or process your Personal Data for Targeted Advertising or Profiling after you have exercised your right to opt-out, or to process your Personal Data for Secondary Use (as defined in applicable U.S. State Privacy Laws), by emailing us at hello@nara.com.

Request to Access, Delete, or Correct

You may submit a Valid Request for any other rights afforded to you in this Privacy Policy and applicable U.S. State Privacy Law by using the following methods:

Email us at: hello@nara.com
Call us at: 1-877-GOT-NARA

If you are a California, Colorado, Connecticut, Delaware, Montana, Nebraska, New Hampshire, New Jersey Oregon, or Texas resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Appealing a Denial

If you are a Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision if permitted by applicable U.S. State Privacy Laws. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the U.S. State Privacy Laws (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by the following methods:

Email us at: hello@nara.com (title must include “[STATE OF RESIDENCE] Appeal”)
Call us at: 1-877-GOT-NARA

If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, and Virginia.

Financial Incentive and Bona Fide Loyalty Program

From time to time, we may also provide other programs, such as a points-based loyalty program, sweepstakes, contest, or other similar promotional campaigns (each, a “Program”). When you participate in a Program, we may ask you to provide certain Personal Data. Because Programs may involve the collection of Personal Data and offering of certain benefits, they might be interpreted as a “financial incentive” program under the CCPA, “bona fide loyalty program” under the CPA, and a “loyalty program” under NJPA. Under the CCPA, the value of your Personal Data to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program, less the expense related to offering those products, services, and benefits to Program participants.

You may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program rules.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at hello@nara.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting us at hello@nara.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

European Union, United Kingdom Data, and Swiss Subject Rights

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Nara will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at hello@nara.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

Contact Data
Nara Account Data
Identifiers
Payment Data
Commercial Data
Categories of Data Considered “Sensitive” Under the U.S. State Privacy Laws
Other Identifying Information that You Voluntarily Choose to Provide

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:

Device/IP Data
Web Analytics
Consumer Demographic Data
Commercial Data
Sensory Data
Inferences from Personal Data
We may also de-identify or anonymize Personal Data to further our legitimate interests.

Examples of these legitimate interests include (as described in more detail above):

Providing, customizing and improving the Services.
Marketing the Services.
Corresponding with you.
Meeting legal requirements and enforcing legal terms.
Completing corporate transactions.

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Disclosing Personal Data

The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data with third parties.

EU, UK and Swiss Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at hello@nara.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about Nara's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Nara and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Nara in the U.S. and will be hosted on U.S. servers, and you authorize Nara to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

1-877-GOT-NARA
https://nara.com/
hello@nara.com
250 Greenwich St, 39th Floor, New York, New York 10007