📱 ORO TECHNOLOGIES LLC

APP PRIVACY DISCLOSURE FOR APPLE APP STORE

Global Privacy, Voice Technology, Accessibility and Data Governance Disclosure

Apple App Store Compliance Framework – Holding Version

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Last Updated: May 2026 – Effective Immediately

This App Privacy Disclosure (the “Disclosure”) constitutes an official corporate compliance disclosure issued by ORO TECHNOLOGIES LLC, a company duly organized and existing under the laws of the State of Florida, United States of America, together with its subsidiaries, affiliates, controlled entities, licensors, contractors, technology operators, and authorized international partners (collectively, “ORO,” the “Company,” the “Platform,” or the “ORO Corporate Group”).

This Disclosure is published for purposes of transparency, regulatory alignment, and compliance with the requirements established by Apple Inc., the Apple App Store Review Guidelines, applicable international privacy regulations, consumer protection frameworks, accessibility standards, and global digital platform compliance obligations.

This Disclosure forms an integral part of ORO’s global legal and compliance architecture and shall be interpreted jointly with the:

• Global Terms and Conditions

• Global Privacy, Security and Data Governance Policy

• Accessibility, Voice Technology & Artificial Intelligence Policy

• Payments, Fees and Financial Flow Policy

• Community Standards and Safety Policies

• and any additional governing legal instruments published by ORO.

In the event of conflict between this Disclosure and any other governing legal instrument, the Global Privacy, Security and Data Governance Policy and Terms and Conditions shall prevail to the maximum extent permitted by applicable law.

1. CORPORATE POSITIONING, TECHNOLOGY STATUS AND STRUCTURAL LIMITATIONS

ORO operates exclusively as a technology platform and digital intermediation infrastructure facilitating connectivity between independent users and independent third-party service providers.

ORO is not:

• a transportation company;

• a logistics operator;

• a delivery carrier;

• a fleet owner;

• a courier company;

• a payment institution;

• a financial entity;

• a telecommunications provider;

• a healthcare provider;

• an emergency response provider;

• an employer of drivers or couriers.

All transportation, delivery, mobility, accessibility-related, and operational services available through the Platform are independently performed by third-party providers operating under their own responsibility, licensing, regulatory compliance, insurance coverage, and operational control.

Nothing in this Disclosure shall be interpreted as creating operational control by ORO over third-party providers or real-world services.

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2. PRIVACY-BY-DESIGN, ACCESSIBILITY-FIRST AND VOICE-FIRST ARCHITECTURE

The Platform has been developed under a privacy-by-design, security-by-design, and accessibility-first technological architecture intended to facilitate digital inclusion for elderly individuals, persons with disabilities, users with reduced mobility, visually impaired users, and individuals requiring simplified interaction systems.

Because accessibility constitutes a core structural principle of the Platform, ORO utilizes a voice-first interaction model designed to reduce technological barriers and improve usability.

The Platform may integrate:

• voice interaction systems;

• speech recognition technologies;

• accessibility-oriented interfaces;

• artificial intelligence processing systems;

• contextual assistance systems;

• simplified navigation structures;

• automated response mechanisms.

Such technologies are implemented exclusively for legitimate operational, accessibility, security, safety, and service-related purposes.

To the maximum extent permitted by law, ORO does not guarantee uninterrupted accessibility functionality, voice recognition accuracy, or compatibility with all devices, environments, jurisdictions, or assistive technologies.

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3. SCOPE AND NATURE OF PERSONAL DATA PROCESSING

ORO processes personal data solely to the extent reasonably necessary for the operation, integrity, accessibility, security, compliance, and functionality of the Platform.

All processing activities are governed by principles of:

• data minimization;

• proportionality;

• necessity;

• lawful basis;

• purpose limitation;

• security and confidentiality.

Depending on the nature of the service, jurisdiction, device configuration, accessibility settings, and user interactions, ORO may process categories of personal data including the following.

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4. CATEGORIES OF DATA COLLECTED AND PROCESSED

4.1 Account and Contact Information

The Platform may process:

• name;

• email address;

• telephone number;

• authentication credentials;

• account identifiers.

Such information is processed exclusively for:

• account creation;

• authentication;

• fraud prevention;

• customer support;

• regulatory compliance;

• security verification;

• operational communication.

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4.2 Location and Geolocation Data

Because the Platform facilitates real-world interactions between independent participants, the Platform may process:

• real-time geolocation data;

• background location data;

• contextual movement information;

• trip-related coordinates;

• location history associated with active sessions.

Location processing may be necessary for:

• service coordination;

• accessibility functionality;

• voice-based navigation;

• fraud prevention;

• operational integrity;

• emergency assistance features;

• S.O.S. functionality;

• safety-related systems.

Users acknowledge that disabling certain permissions may materially impair Platform functionality.

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4.2.1 Device Permissions and Functional Dependencies

Certain Platform functionalities may require device permissions including, but not limited to:

microphone access;

location access;

notification permissions;

camera permissions where applicable;

accessibility-related permissions;

communication-related permissions;

device-level functionality permissions.

Users may manage such permissions through their device settings.

However, disabling certain permissions may limit, impair, restrict, or prevent the operation of specific Platform functionalities, including accessibility features, voice-assisted interactions, safety-related services, navigation tools, communication mechanisms, and S.O.S.-related functionalities.

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4.3 Voice Interaction and Accessibility Data

Because ORO operates under a voice-first accessibility architecture, the Platform may process:

• voice commands;

• speech inputs;

• temporary speech transcriptions;

• accessibility interaction data;

• contextual command interpretation.

ORO expressly declares that, to the maximum extent technically feasible:

• voice recordings are not intentionally retained by ORO beyond the period reasonably necessary for operational processing, unless required by applicable law, security obligations, troubleshooting procedures, user requests, or authorized third-party infrastructure operations.

• biometric voiceprints are not intentionally created;

• voice data is not processed for biometric identification purposes;

• voice processing is minimized to temporary operational functionality.

Voice interaction processing may involve transient processing through authorized infrastructure providers solely for command execution, accessibility functionality, system integrity, or operational delivery.

Users expressly acknowledge that voice systems are probabilistic technologies and may be affected by:

• background noise;

• speech variations;

• accents;

• disabilities;

• environmental interference;

• connectivity limitations;

• hardware performance;

• latency;

• system limitations.

ORO does not guarantee uninterrupted or error-free voice processing performance.

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4.3.1 Safety, Emergency Assistance and S.O.S. Functionality

The Platform may provide optional safety-related functionalities, including S.O.S. activation mechanisms, emergency assistance features, accessibility-triggered alerts, safety notifications, emergency contact tools, location-sharing functionalities, and communication mechanisms intended to facilitate assistance during situations perceived by a user as involving potential safety concerns.

When activated, such functionalities may process limited categories of information including:

• user identification information;

• location information;

• device information;

• trip-related information;

• communication metadata;

• emergency contact information where provided by the user.

Depending on the jurisdiction and operational configuration, safety-related information may be transmitted to authorized third-party safety providers, emergency coordination partners, telecommunications providers, infrastructure providers, or other entities involved in facilitating emergency communications.

ORO does not operate emergency-response agencies, law-enforcement organizations, medical-response services, rescue services, dispatch centers, or public-safety authorities.

The availability, responsiveness, effectiveness, transmission speed, intervention outcome, and operational performance of any emergency-related functionality may depend upon third-party infrastructure, telecommunications networks, device functionality, internet connectivity, geographic conditions, governmental authorities, and external service providers.

Emergency-related features are provided solely as assistive technological tools and do not constitute emergency-response services, security services, rescue services, medical services, or guarantees of assistance.

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4.3.1(a) Technology Intermediary Status for Emergency Communications

ORO acts solely as a technology intermediary with respect to safety-related communications and emergency-assistance functionalities.

Where available, emergency alerts, S.O.S. notifications, accessibility-triggered safety communications, or related safety signals may be transmitted through independent third-party providers operating under their own legal, technical, and operational frameworks.

ORO does not control, supervise, direct, manage, or guarantee the actions, decisions, response times, operational capabilities, availability, or effectiveness of any third-party emergency provider, security provider, governmental authority, telecommunications operator, law-enforcement agency, rescue organization, or medical-response entity.

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4.3.2 No Biometric Authentication Services

Unless expressly disclosed through a separate legally binding service description, ORO does not provide biometric authentication services, voiceprint identification services, biometric verification services, or identity-certification technologies.

Voice-enabled functionalities are designed primarily for accessibility, communication, navigation, and operational interaction purposes.

Users acknowledge that voice-processing technologies may be affected by environmental conditions, speech variations, accents, disabilities, device limitations, connectivity issues, artificial voice generation technologies, and other operational factors.

Accordingly, voice-enabled functionalities should not be relied upon as legally reliable identity-verification mechanisms.

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4.3.3 No Biometric Profiling or Voiceprint Databases

ORO does not intentionally create, maintain, commercialize, sell, license, share, distribute, or operate biometric voiceprint databases for the purpose of uniquely identifying individuals across unrelated interactions.

Except where expressly required by applicable law, ORO does not utilize voice interactions for biometric profiling, biometric categorization, behavioral identification, surveillance activities, law-enforcement purposes, or identity-tracking activities.

Any temporary voice processing performed through the Platform is intended exclusively for accessibility functionality, command interpretation, communication facilitation, operational execution, safety-related features, or service delivery purposes.

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4.4 Usage, Operational and Diagnostic Information

The Platform may process:

• application interaction data;

• navigation behavior;

• session activity;

• crash reports;

• diagnostic logs;

• device identifiers;

• operating system information;

• IP addresses;

• connectivity information;

• technical performance data.

Such processing is necessary for:

• cybersecurity;

• fraud prevention;

• infrastructure maintenance;

• system optimization;

• accessibility improvements;

• operational analytics;

• troubleshooting;

• regulatory compliance.

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4.5 Transactional and Financial Information

Transactions facilitated through the Platform may involve processing of limited transactional information necessary to complete authorized payment operations.

ORO does not directly store full payment card numbers or sensitive banking credentials.

Payment operations are processed through authorized and regulated third-party payment processors, gateways, and financial infrastructure providers legally permitted to operate within the applicable jurisdiction.

Users acknowledge that payment services are independently operated by third parties subject to their own legal terms, compliance obligations, security frameworks, and regulatory requirements.

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5. LEGAL BASIS FOR PROCESSING

Depending on jurisdiction and applicable law, ORO processes personal data under one or more lawful bases including:

• performance of contractual obligations;

• legitimate business interests;

• accessibility functionality;

• fraud prevention;

• security protection;

• legal and regulatory compliance;

• emergency protection purposes;

• explicit user consent where legally required.

Users acknowledge that processing activities may rely simultaneously upon multiple lawful bases across multiple jurisdictions within ORO’s globally distributed technological infrastructure.

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6. PURPOSES OF DATA PROCESSING

Personal data may be processed exclusively for legitimate operational purposes including:

• operation of the Platform;

• facilitating interactions between independent users and providers;

• accessibility optimization;

• voice functionality;

• payment facilitation through authorized processors;

• fraud detection and prevention;

• cybersecurity and risk management;

• system analytics and maintenance;

• customer support;

• legal compliance;

• regulatory cooperation;

• emergency-related functionalities;

• accessibility enhancement;

• service quality improvement.

ORO does not sell personal data.

ORO does not engage in unauthorized biometric profiling.

ORO does not use personal data for cross-app behavioral advertising tracking.

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6.1 Artificial Intelligence and Automated Processing

Certain Platform functionalities may utilize artificial intelligence systems, machine-learning technologies, speech-recognition tools, natural-language processing systems, accessibility automation, safety-related algorithms, fraud-prevention mechanisms, and automated decision-support technologies.

Such systems may assist in generating recommendations, interpreting commands, facilitating accessibility features, improving usability, detecting fraud, supporting operational integrity, optimizing platform functionality, and enhancing user experience.

Users acknowledge that artificial intelligence systems may generate inaccurate, incomplete, delayed, or unintended outputs due to technological limitations, data quality issues, environmental factors, system constraints, or third-party dependencies.

Except where expressly required by applicable law, ORO does not guarantee the accuracy, completeness, reliability, or suitability of AI-generated outputs and users remain responsible for exercising independent judgment when relying upon automated recommendations or system-generated responses.

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7. NO CROSS-APP TRACKING AND LIMITED ADVERTISING POSITIONING

ORO expressly declares that it does not track users across third-party applications, websites, or unrelated digital properties for targeted advertising purposes as defined under Apple App Store policies.

The Platform is not designed around advertising monetization models dependent on invasive third-party tracking systems.

To the extent analytics or operational measurement tools are utilized, such tools are implemented exclusively for legitimate operational, performance, accessibility, security, fraud prevention, or compliance purposes.

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8. DATA SHARING, DISCLOSURE AND INTERNATIONAL CORPORATE STRUCTURE

Personal data may be disclosed, transferred, or processed under strict necessity and proportionality principles with:

• infrastructure providers;

• cloud service providers;

• payment processors;

• fraud prevention partners;

• accessibility support providers;

• customer support systems;

• affiliated entities within the ORO Corporate Group;

• competent legal authorities;

• emergency response intermediaries where legally appropriate.

All authorized recipients are subject to contractual confidentiality, security, and compliance obligations.

ORO does not authorize third parties to process personal data beyond legitimate operational purposes associated with Platform functionality.

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9. INTERNATIONAL DATA TRANSFERS

Due to the multinational nature of the Platform, personal data may be transferred, stored, processed, or accessed across multiple jurisdictions, including the United States.

ORO implements commercially reasonable legal and organizational safeguards intended to protect international data transfers, including:

• Standard Contractual Clauses (SCCs);

• contractual confidentiality frameworks;

• access control measures;

• encryption protocols;

• internationally recognized transfer safeguards where applicable.

Users acknowledge that international digital infrastructure may involve distributed processing environments.

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10. INFORMATION SECURITY, CYBERSECURITY AND PLATFORM INTEGRITY

ORO maintains enterprise-oriented technical, organizational, and administrative safeguards designed to protect Platform integrity and personal data security, including:

• encryption technologies;

• access controls;

• monitoring systems;

• anomaly detection mechanisms;

• authentication protections;

• internal compliance measures;

• cybersecurity protocols;

• incident response procedures.

However, users acknowledge that no digital infrastructure, network environment, or internet-based technology can be guaranteed completely secure.

To the maximum extent permitted by law, ORO disclaims liability arising from unauthorized third-party attacks, force majeure cyber incidents, telecommunications failures, or external infrastructure compromises beyond ORO’s reasonable control.

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11. USER RIGHTS

Subject to applicable law and jurisdictional limitations, users may exercise rights relating to their personal data including:

• access;

• rectification;

• deletion;

• restriction;

• objection;

• portability;

• withdrawal of consent where applicable.

Certain rights may be restricted where necessary to:

• comply with legal obligations;

• preserve cybersecurity;

• prevent fraud;

• maintain operational integrity;

• protect third-party rights;

• comply with regulatory obligations.

Identity verification may be required before processing requests.

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12. CHILDREN, VULNERABLE USERS AND ACCESSIBILITY CONSIDERATIONS

The Platform is designed with accessibility-oriented principles intended to facilitate digital inclusion for elderly individuals and users with disabilities.

However, accessibility functionality does not eliminate risks associated with real-world interactions, technological limitations, or independent provider conduct.

The Platform is not intended for unauthorized use by minors without legally valid authorization where required by applicable law.

Users remain responsible for supervising vulnerable individuals under their care.

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13. THIRD-PARTY SERVICES AND EXTERNAL INFRASTRUCTURE DISCLAIMER

The Platform may rely upon independent third-party infrastructure providers including:

• cloud infrastructure services;

• telecommunications services;

• mapping services;

• payment gateways;

• device operating systems;

• app distribution platforms;

• artificial intelligence processing services.

ORO does not control third-party systems and shall not be liable for failures, interruptions, inaccuracies, breaches, outages, or limitations originating from third-party infrastructure outside ORO’s reasonable control.

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14. DISCLAIMER OF WARRANTIES

To the fullest extent permitted by law, the Platform and all related services are provided on an “AS IS” and “AS AVAILABLE” basis without warranties of any kind.

ORO expressly disclaims all warranties including, without limitation:

• uninterrupted availability;

• merchantability;

• fitness for a particular purpose;

• accessibility performance;

• technological compatibility;

• voice recognition accuracy;

• real-time operational reliability;

• uninterrupted data transmission.

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15. LIMITATION OF LIABILITY

To the maximum extent permitted by applicable law, ORO, its affiliates, subsidiaries, licensors, contractors, technology providers, officers, directors, employees, shareholders, and authorized partners shall not be liable for:

• indirect damages;

• incidental damages;

• consequential damages;

• punitive damages;

• data loss;

• business interruption;

• accessibility failures;

• voice system inaccuracies;

• third-party misconduct;

• cybersecurity incidents;

• operational interruptions;

• independent provider actions;

• external infrastructure failures.

Where limitation of liability is restricted by law, liability shall be limited to the minimum amount legally permitted.

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16. MODIFICATIONS AND CONTINUOUS COMPLIANCE

ORO reserves the unrestricted right to amend, modify, replace, or update this Disclosure at any time in response to:

• regulatory developments;

• Apple App Store policy updates;

• legal requirements;

• technological evolution;

• operational restructuring;

• accessibility improvements;

• cybersecurity considerations.

Continued use of the Platform after publication of modifications constitutes legally binding acceptance of the updated Disclosure.

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17. OFFICIAL LEGAL CONTACT CHANNELS

Privacy, accessibility, legal compliance, and data protection inquiries may be directed to:

legal@orotechnologiesllc.com
privacy@orosay.com

​accessibility@orosay.com

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18. GLOBAL LEGAL INTEGRATION NOTICE

This Disclosure forms part of ORO's unified global legal, privacy, accessibility, cybersecurity, voice-technology, artificial-intelligence, safety, emergency-assistance, marketplace-governance, and compliance framework.

This Disclosure shall be interpreted together with:

• the Terms and Conditions;

• the Privacy Policy;

• the International Data Transfers Addendum;

• the Accessibility, Disability & Vulnerable Users Policy;

• the Voice Technology & AI Framework;

• the Safety, S.O.S. & Emergency Assistance Framework;

• the Community Guidelines;

• the Acceptable Use Policy;

• and all related legal documents published by ORO Technologies LLC.

To the maximum extent permitted by applicable law, the official English-language version of ORO's governing legal framework shall prevail in the event of any inconsistency.