At Ory, we care about privacy. We know that you care about how your information is used too. We want to ensure that we are providing you with transparency on how we use your information including Personal Information (as defined below). Accordingly, this Privacy Policy (this “Privacy Policy”) describes the ways in which we collect, receive, process, or store information in connection with our business operations (“Business Operations”), including the services we provide that reference this Privacy Policy (collectively, the “Services”). The Services include: (i) our application programming interfaces; (ii) our website available at https://www.ory.sh/ (the “Website”); and (iii) our mobile application (“App”). By the way, when we use the term “Ory,” “we,” “us” or “our” we generally mean Ory Corp or an affiliate or subsidiary of Ory Corp; please refer to Section 2 (Controller) for details. We use the term “Personal Information” to mean any information that identifies you as an individual, is about you as an individual, or is otherwise defined as personal information, personal data, or similar under applicable law.

Scope of this Privacy Policy

It is important to understand the scope of this Privacy Policy. Except as provided in this Section, this Privacy Policy applies to anyone that interacts with our Business Operations or that uses the Services (collectively, “you”). If you are interacting with our Business Operations or using the Services on behalf of a company or other legal entity (“Your Organization”), then (i) you represent and warrant that you have authority to act on behalf of, and to bind Your Organization, and (ii) for all purposes in this Privacy Policy, the term “you” means Your Organization on whose behalf you are acting. Please note, however, that this Privacy Policy does not apply to the extent that you have entered into an agreement, privacy policy, or other terms with a third party that governs your provision of Personal Information through our Services. In such context, we will collect, use, share, and otherwise process your Personal Information on behalf of the applicable third party, strictly to fulfill our obligations under our agreement with such third party. In such circumstances, please contact the applicable third party if you have inquiries regarding the Personal Information that we collected on behalf of such third party, or if you would like to exercise any rights that You may have with respect to such Personal Information under applicable law. If you are unsure if this Privacy Policy applies to you, please contact us using the contact information set out in Section 13 (Contact Information).

Controller

The controller, i.e., the entity that is responsible for the processing of your Personal Information, and which is referred to by the term “Ory”, “we”, “us” or “our” in this Privacy Policy, is Ory Corp, a Delaware corporation with offices at 132-A Veterans Lane, Suite 128, Doylestown, Pennsylvania, USA 18901. If the controller is one of our affiliates or subsidiaries (collectively, our “Affiliates”), this will be explicitly stated at the point where the data is collected or, respectively, where you have been referred to this Privacy Policy, and the full address of the respective controller will be given at the same location. For Ory Corp's representative in the European Union / European Economic Area (“EEA”) see Section 8.3.2 (Representative).

Collection of Information

Here are the types of information that we collect about you and how we collect it from you:

Information that You Provide

We collect information that you provide to us, including when you interact with us in the course of our Business Operations or when we provide the Services. Information that you may provide includes your name, employment information, mailing address, telephone number, email address, and date of birth. If you choose to use social login functionality, then we will also collect your social account information from you. Ory also collects information that you provide to us by email. If you visit our office in person and meet with our employees, we may ask you to provide us with information, including Personal Information (“Offline Personal Information”). Offline Personal Information may be collected using: (i) in person communications and interactions with us; (ii) paper forms; and (iii) other information you provide to us in person or via mail, fax, telephone, or other means. If you provide Offline Personal Information to us, we will provide you with a written notice of this Privacy Policy or will provide you with a reference to this Privacy Policy so that you can familiarize yourself with its terms.

Device Identifies; Logs; Tags

We may automatically collect certain information from you, including certain technical information from your computer or mobile device when you use certain Services, such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the Website, the pages you view immediately before and after you access the Website, and the search terms you enter on the Website (if any). This information allows Ory to provide the Website to you, and to improve the Business Operations, the Website, and the Services.

Cookies

We may collect certain information using “cookies,” which are small text files that the Website saves on your computer or mobile device, or similar technologies that allow us to recognize your computer or mobile device. We will always ask for your consent before we place cookies on your device, except for cookies that are strictly necessary to provide Website features explicitly requested by you. For further information, see the Cookie Privacy Policy in Section 7 (Cookie Privacy Policy) below.

Web Beacons and Tags

The Services may use certain data collection technologies that rely on: (i) beacons; (ii) pixel tags and object hyperlinking tags; and (iii) other means to link an object to an Internet address, a remote software application, a remote database, or other remote means of receiving or processing information. We may use these technologies to tell us what portions of the Services have been visited or to measure the effectiveness of searches that users perform via the Services. We will always ask for your consent before we use these technologies to collect data that is stored on your device.

User-Generated Content

We may provide you with the ability (either directly or through a third-party service that may include social media channels) to engage with us and others in public exchanges, and these may include opportunities for you to provide comments, reviews, recommendations, information related to the Services, and other input (collectively, “User-Generated Content”). Please understand that anything you supply as User-Generated Content will be accessible to others to read, collect, re-publish, and otherwise freely use. We will only take down, remove, or edit User-Generated Content in our sole discretion, except as required by applicable law. If you include any information relating to others in your User-Generated Content, then you represent that you have full permission and authority to do so.

Geolocation Information

The Services may determine your location (your “Geolocation Information”) using your device or browser features and/or through the information provided by a third party, such as Google or Facebook. We will always ask for your consent before we access Geolocation Information on your device or browser. You may revoke consent for accessing your Geolocation Information at any time, in particular by disabling the GPS and other applicable features in your device or browser settings. To the extent Your Geolocation Information is combined with any Personal Information (to the extent that Geolocation Information itself does not constitute Personal Information under applicable law), we will treat it as Personal Information. We may use Your Geolocation Information to send communications to you, and for other purposes set out in this Privacy Policy.

Anonymous Information

We may also collect, process, and use information that does not identify you or your devices, and which is neither stored on your device or already present on your device, including information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individuals cannot be re-identified, or (ii) anonymizing the information with techniques (such as via GA4) that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information”). Information that meets these criteria might include, for example, demographic information, statistical information (e.g., page views and hit counts), and general tracking information.

Collection of Information

Business Operations and Services

We use your Personal Information for Business Operations. This includes, providing you with the Services you request or access, such as accessing or using the Services, creating and managing your user accounts, and communicating with you about our Services.

Analysis and Improvement

We may use your Personal Information and Anonymous Information to perform internal administration, auditing, operation, and troubleshooting in connection with Business Operations, including to evaluate and improve our Services, and to develop and test Services.

Information and Notices

If you submit your Personal Information to us, we may provide you with information about Business Operations and the Services or required notices. Ory does not sell or share your Personal Information with other companies for purposes of marketing their goods or services to you. In some jurisdictions, you have the explicit right to request that we do not share your Personal Information with, or sell your Personal Information to, certain third-parties, and we will honor such requests in accordance with applicable law.

Security

We may use your Personal Information for safety and security purposes, including sharing of your information for such purposes, when it is necessary to pursue our legitimate interests in ensuring the security of Business Operations and the Services, including detecting, preventing and responding to fraud, intellectual property infringement, violations of agreements with Ory or its service providers, violations of law or other misuse of the Services. We may also share your Personal Information when we believe, in good faith, that disclosure is necessary to protect our rights, the rights of other users of the Services, the integrity of the Services, your safety, or the safety of others.

Comply with Legal Obligations

We may have a legal obligations to collect, use, retain, or process your Person Information. If those obligations exists, then we will use your Personal Information to satisfy such obligations.

Responding to Your Requests

We use your Personal Information to respond to your requests through various channels (which may include in person, email, phone, and chat).

Other Purposes for Which We Seek Your Consent

We may seek for your consent to use your Personal Information for additional purposes that we communicate to you.

Sharing Information

This Section describes how we share the information we have collected about you. We are not in the business of selling your Personal Information, but we may share your Personal Information as described below in accordance with applicable laws. Unless otherwise required by applicable law, we take reasonable efforts to ensure that any entity that we share your Personal Information with has privacy practices at least as protective as those in this Privacy Policy.

Third-Party Service Providers

We may engage third-party service providers to perform functions on our behalf, and these may include maintaining the Website or App, responding to and sending email or other messages, data analysis, and other functions useful to Business Operations or the Services. Such third-party service providers will have access to Personal Information to the extent needed to perform their function, but will not be permitted to use Personal Information for other purposes.

Consultants

We may engage attorneys, accountants, and other consultants and subject matter experts to advise and assist it in connection with the Services. We will provide such consultants with access to Personal Information to the extent needed to perform their function, but will not permit them to use your Personal Information for purposes unrelated to their engagement with us.

Business Transfer

Ory may also transfer your Personal Information to a third party of Affiliate in the event of any reorganization, merger, acquisition, assignment, transfer or other disposition of all or any portion of Ory’s business or assets, provided that any such entity that Ory transfers Personal Information to will not be permitted to process your Personal Information other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.

Our Affiliates

We may share information we collect with our Affiliates, which are any entity that is closely related to us, such as any entity that controls, is controlled by, or is under common control with Ory. Our Affiliates will be subject to the terms of this Privacy Policy.

Other Disclosure

We may disclose Personal Information about you to others: (i) if we have your valid consent to do so; (ii) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (iii) to enforce any of our terms and conditions or policies; or (iv) as necessary to pursue available legal remedies or defend legal claims.

Storage

Securing and storing your information is important to us. In this Section, we describe how we store and secure your information.

Security

We have implemented reasonable measures to protect your information from unauthorized access, use or disclosure. Ory maintains administrative, technical and physical safeguards designed to protect the collected information that are appropriate to the nature, size, and complexity of our Business Operations. Ory is not responsible for the security of information that you transmit over networks that Ory does not control, including the Internet and wireless networks. Retention. Ory retains information (including associated Personal Information) in accordance with applicable law and accepted retention practices. We will keep your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including any legal, accounting or reporting requirements. In particular:

Retention

Ory retains information (including associated Personal Information) in accordance with applicable law and accepted retention practices. We will keep your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including any legal, accounting or reporting requirements. In particular:

• Personal Information that we use to provide our Website to you will generally be deleted or anonymized immediately after you leave our Website. In case of actual or suspected security incidents, we may keep the relevant information for up to seven days in order to investigate said incidents.
• Personal Information processed for the purpose of performing a contract will generally be kept during the term of the contract and the subsequent statute of limitation period for claims arising out of the contract.
• If there is a legal obligation to retain Personal Information, in particular for tax purposes, Personal Information will be kept for as long as required by the applicable laws.

Reviewing, Deleting, or Correcting Information

Ory is committed to empowering you to understand the information we have about you. In addition to any additional legal rights you may have that are described in Section 8.2 (United States State-Specific Notices Regarding Your Privacy Rights) and Section 8.3 (EEA-Specific Notices Regarding Your Privacy Rights), if you wish to review, correct, or request that we delete information about you (including incorrect Personal Information), you may send a written request to Ory using the contact information provided in Section 13 (Contact Information). Please understand that we may not be able to change or delete your information if the information is necessary for our Business Operations or necessary for compliance with applicable law.

Cookie Privacy Policy

This Section provides Ory’s cookie policy (“Cookie Privacy Policy”) and describes how Ory uses Cookies (as defined below) and similar technologies.

Cookies

Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. Ory uses cookies, web beacons and similar technologies (collectively, “Cookies”) to enhance your user experience, understand your usage of the Website, detect if you have returned to the Website, and to perform analytics. Cookies may also be set by other websites or services that run content on the page you are visiting. The provision of your data via Cookies is based on your consent except for those Cookies that Ory places on your device that are strictly necessary for Website features requested by you. Ory uses “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave the Website. A persistent Cookie may remain on your device for much longer until you manually delete it.

Use

Cookies can contain the following information about you and your use of the Website: browser type, search preferences, data relating to which pages of the Website that you have visited and the date and time of your use. Ory uses Cookies for the following purposes:

• To enable and support security features, prevent fraud, and protect your data from unauthorized access.
• To enable features and help us provide you with personalized content.
• To analyze how you use the Website and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how you reached the Website.

Third-Party Cookies

Ory uses the following third-party Cookies on the Website:

Your Choices Regarding Your Personal Information

Opt-Out of Marketing Communications

If you have chosen or otherwise consented to receive, bulletins, updates, or other marketing-related materials, we will provide you with the ability to decline – or “opt out” – of receiving such communications. instructions for opting-out will be provided if and when we determine to send you such a communication. For example, if you no longer wish to receive email messages from us, you can opt out of this Service by either (i) following the “unsubscribe” instructions located near the bottom of each email message, or (ii) contacting us as provided in Section 13 (Contact Information). Opt outs will be free of charge; however, your telecommunications provider or the postal service may charge you normal rates for sending us your opt out request. Please understand that we may continue to communicate with you in connection with administrative notices concerning any transactions, operation of the Services and legal notices.

United States State-Specific Notices Regarding Your Privacy Rights

Shine the Light Law
California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third-parties for direct marketing purposes. The California “Shine the Light” law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third-parties for their direct marketing purposes.

California Consumer Privacy Act Disclosure
The California Consumer Privacy Act (the “CCPA”) provides various rights to individuals and households with respect to the collection and use of Personal Information that we have collected about California residents. We use the term “resident” to refer to a California resident to whom the CCPA applies. Among other rights under the CCPA, as further set out in this Section, a resident has the right to request that we (i) disclose to the resident Personal Information that we have about such resident (including Personal Information about such resident that is sold), and (ii) subject to certain exceptions, delete Personal Information that we have about such resident. A resident may request a copy of the following using the mechanism set out in Section 8.2.3 (Submission of a Consumer Request): (a) the categories of Personal Information we collected about such resident; (b) the categories of sources from which the Personal Information is collected; (c) the business or commercial purpose for collecting or selling the Personal Information; (d) the categories of third-parties with whom we share Personal Information; and (e) the specific pieces of Personal Information we have collected about such resident. A resident may submit a request for such information no more than twice in any twelve (12) month period, and our disclosure of such requested information shall only cover the twelve (12) month period preceding our receipt of such request. Additionally, a resident may request that we delete such resident’s Personal Information using the mechanism set out in Section 8.2.3 (Submission of a Consumer Request). A resident’s rights as to such deletion requests are set out in Section 6.3 (Reviewing, Deleting, or Correcting Information).

Submission of a Consumer Request
We are in the process of implementing methods for residents to submit requests to us to access or delete their Personal Information. In the interim, please submit such requests to the email address provided in Section 13 (Contact Information). We will respond to your request within forty-five (45) days or as permitted by applicable law.

Other California Disclosures
We do not provide a financial incentive or a price or service difference to customers in exchange for the retention or sale of their Personal Information. We may send promotions and other offers to those individuals subscribing to our marketing communications and, unless an individual has opted out of such communications, the individual will continue to receive such communications irrespective of whether a disclosure, deletion, or “Do Not Sell” request has been submitted. We do not offer financial incentives to deter customers from making such requests.

• We do not illegally discriminate against any customer for exercising their privacy rights.
• If you are a job applicant submitting Personal Information to us in connection with an application for employment, you will be provided with a privacy notice regarding how we handle such information as part of the application process.
• If you have any questions about our privacy practices in connection with the California Consumer Privacy Act, please contact Us as directed in Section 13 (Contact Information).

Nevada Disclosures
For Nevada residents, please note that We do not sell personal information as defined by Nevada law. You can submit a request to Us as set out in in Section 13 (Contact Information).

Further Resources
If you wish further information concerning privacy policies in general, you should visit the following site: www.ftc.gov/privacy/index.html.

EEA-Specific Notices Regarding Your Privacy Rights

GDPR
Regulation (EU) 2016/679 (General Data Protection Regulation) (“EU GDPR”) EEA, i.e., the European Union, Iceland, Liechtenstein and Norway when accessing our website or being offered products or services by us. It also applies where your data is processed by one of our Affiliates or other establishments in the EEA. Likewise, the UK General Data Protection Regulation tailored by the Data Protection Act 2018 (“UK GDPR”) applies when you are located in the United Kingdom of Great Britain and Northern Ireland (“UK”) under the same circumstances.

Representative
The representative of Ory Corp in the EEA is Ory Systems GmbH, Schloßschmidtstraße 5, 80639 München, Germany.

Legal Basis for Processing
For purposes of the GDPR, the legal basis for the processing of your Personal Information is as follows:

• Where we use your Personal Information for Business Operations (Section 4.1 – Business Operations and Services), the processing is generally necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (Article 6(1)(b) of the GDPR). Where you are not our actual customer but a contact person of our customer, the legal basis our legitimate interest (Article 6(1)(f) of the GDPR) to communicate with our customer through you.
• Where we use your Personal Information for internal administration, auditing, operation, and troubleshooting in connection with Business Operations (Section 4.2 – Analysis and Improvement), the processing is generally based on our legitimate interest (Article 6(1)(f) of the GDPR) to (i) operate and improve our business efficiently; (ii) to enforce any of our terms and conditions or policies; or (iii) to pursue available legal remedies or defend legal claims. We may also ask for your consent (Article 6(1)(a) of the GDPR) to obtain additional information, in particular in connection with the operation of our Website and the use of Cookies.
• For the use of your Personal Data to provide you with information about Business Operations and the Services (Section 4.3 – Information and Notices), the legal basis is generally our legitimate interest (Article 6(1)(f) of the GDPR) to market our business to you. Notwithstanding, if you request more concrete information, the processing may also be necessary to take steps prior to entering into a contract (Article 6(1)(f) of the GDPR). For notices required by law, the processing of your personal data is necessary for compliance with such legal obligation (Article 6(1)(c) of the GDPR).
• The use of your Personal Information for safety and security purposes (Section 4.4 – Security) is generally based on our legitimate interest (Article 6(1)(b) of the GDPR) in ensuring said safety and security. In some situations, there may also be a legal obligation to implement such measures (Article 6(1)(c) of the GDPR).
• In other cases where we need to comply with a legal obligation (Section 4.5 – Comply with Legal Obligations), the processing is based on the necessity to comply with such obligation (Article 6(1)(c) of the GDPR).
• Where we use your Personal Information to communicate with you (Section 4.6 – Responding to Your Requests), the legal basis will be one of the above depending on the purpose of such communication.
• Where we seek your consent for other purposes (Section 4.7 – Other Purposes for Which We Seek Your Consent), the legal basis is consent (Article 6(1)(a) of the GDPR).

Transfers to Third Countries
We may process your Personal Information in countries outside the EEA (“Third Countries”), including in the United States. We may also disclose your Personal Data to Affiliates and third parties (cf. Section 5 – Sharing Information) in Third Countries.

• If we disclose Personal Information to recipients in Third Countries, we may rely on an adequacy decision of the European Commission that confirms that the laws of the Third Country in question provide for an adequate protection of Personal Information.
• For other Third Countries, we will take steps to protect your privacy and fundamental rights in accordance the GDPR, and arrange for additional safeguards. Such safeguards will typically be based on a contract that binds the recipient in the Third Country to adhere to data protection standards similar to those under the GDPR. We will usually rely on the standard contractual clauses pre-approved by the European Commission or on other clauses approved by a competent data protection authority. If available, we may also rely on so-called binding corporate rules of the recipient approved by a competent data protection authority. These safeguards will generally include you as a third-party beneficiary, allowing you to enforce the data protection standards directly against the recipient. In order to obtain a copy of the safeguards used for a recipient, you may contact us using the contact information provided in Section 13 (Contact Information).

Your GDPR Rights
Under the GDPR, you have the following rights in relation to your Personal Information each subject to the legal requirements set out in the respective provisions of the GDPR:

• The right to request access to information regarding our processing of your Personal Information (Article 15 of the GDPR);
• The right to obtain rectification of your Personal Information that is inaccurate (Article 16 of the GDPR);
• The right to obtain the deletion of your Personal Information (Article 17 of the GDPR), or the restriction the processing of your Personal Information (Article 18 of the GDPR);
• The right to receive a copy of your Personal Information in a structured, commonly used and machine-readable format (data portability) (Article 20 of the GDPR);
• Where processing of your Personal Information is based on your consent (cf. Section 8.3.3 – Legal Basis for Processing), the right to withdraw consent at any time, without affecting the lawfulness of processing based on such consent before such withdrawal;
• Where processing takes place for the purpose of direct marketing, the right to object to the use of your Personal Information (Article 21(2) of the GDPR) at any time;
• Where processing is based on our legitimate interest (cf. Section 8.3.3 – Legal Basis for Processing), the right to object to the use of your Personal Information on grounds relating to your particular situation (Article 21(1) of the GDPR)and any time; we may, however, continue the processing if (i) we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms; or (ii) for the establishment, exercise or defense of legal claims.
• If you wish to exercise any of your rights above, please contact us using the contact information provided in Section 13 (Contact Information). You also have the right to lodge a complaint with your local competent supervisory authority or any authority that applies to Ory.

Feedback

We respect the our customers and we want to encourage your feedback. If you have a suggestion or concerns you would like us to address, please contact us using the contact information provided in Section 13 (Contact Information). Certain jurisdictions may also provide you with additional avenues for lodging complaints. Please check with your jurisdiction’s consumer protection authority.

Third-Party Websites and Platforms

The Services and our communications may contain links to websites and platforms operated by third-parties. You acknowledge and agree that Ory is not responsible for the collection and use of your information by such websites or platforms that are not under Ory’s control. We encourage you to review the privacy policies of each website and platform you visit or access so you understand such website operator’s privacy practices.

Children’s Information

The Services are not directed to, nor does Ory knowingly collect information from, children under the age of 13 in connection with Business Operations. If you become aware that your child or any child under your care has provided information without your consent, please contact Ory immediately using the contact information provided in Section 13 (Contact Information).

Changes to this Privacy Policy

From time to time, we may change this Privacy Policy for our business purposes and to comply with changes in applicable law. If we make any substantive or material changes, then we will communicate these changes to you by posting the updated Privacy Policy on the Website, App and/or notifying you of the change via the Services, email, or other methods. Where permitted under applicable law, your continued use of the Services following such notice constitutes your agreement to follow and be bound by the updated Privacy Policy.

Contact Information

We welcome your feedback or suggestions. If you have any questions about this Privacy Policy or the collection or use of information about you, please contact Ory at Office+Privacy@ory.sh. You may also contact us by other means at the address set out or referred to in Section 2 (Controller). If you are in the EU/EEA, you may also contact our representative at the address set out in Section 8.3.2 (Representative).

Relationship to Terms of Service

This Privacy Policy must be read in conjunction with (i) other agreements into which you and Ory may enter concerning the Services (if any), and (ii) our Terms of Service, available here: https://www.ory.sh/tos/. The provisions of our Terms of Service are incorporated herein. To the extent this Privacy Policy conflict with our Terms of Service, this terms of this Privacy Policy shall control. Similarly to the extent this Privacy Policy conflict with terms and conditions of any specific agreement you enter with us, the terms and conditions of such specific agreement shall control.

Do Not Track Notice

Our Website does not change its behavior when receiving “Do Not Track” signals from browser software. We will instead ask for your explicit consent before we place Cookies that are not necessary for Website features requested by you.

Automated Decision-Making

We do not make decisions which will have a legal effect for you or otherwise affect you in a significant way on the sole basis of automated processing, including profiling.

Effective Date

The effective date of this Privacy Policy is December 06, 2021.

Copyright and Legal Notice

© 2021 Ory Corp. All rights reserved. No part of this content may be reproduced, stored in any form without written permission from Ory.