ORO TECHNOLOGIES LLC

GLOBAL PUBLIC HEALTH DATA DISCLOSURE & RESPONSE POLICY

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1. PURPOSE, SCOPE, AND CORPORATE FRAMEWORK

This Global Public Health Data Disclosure & Response Policy (“Policy”) establishes the legal, operational, and compliance framework governing the processing, evaluation, preservation, restriction, and potential disclosure of information by ORO TECHNOLOGIES LLC (“ORO,” the “Company,” or the “Platform”) in connection with public health matters, communicable disease events, governmental requests, sanitary emergencies, epidemiological investigations, or legally authorized health-related risk mitigation measures.

This Policy applies globally across all jurisdictions in which the Platform operates, directly or indirectly, including through subsidiaries, affiliates, contractors, licensed operators, technology partners, or independent service providers.

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This Policy applies to all individuals and entities interacting with the Platform ecosystem, including, without limitation:

• drivers

• couriers

• passengers

• customers

• corporate users

• merchants

• business partners

• independent contractors

• affiliates

• vendors

• technology providers

• support personnel

• accessibility-dependent users

• older adults

• individuals with disabilities

• and any third party interacting with the Platform, related infrastructure, or associated services.

This Policy shall be interpreted in conjunction with the Platform’s:

• Terms and Conditions

• Privacy Policy

• Community Guidelines

• Safety Frameworks

• and all applicable compliance policies adopted by ORO.

In the event of conflict, the official English-language version of the Platform Terms and Conditions and applicable governing law shall prevail to the maximum extent permitted by law.

​ORO operates solely as a technology platform and digital intermediary connecting independent participants. Nothing in this Policy shall be interpreted as creating healthcare-provider status, medical-service-provider status, epidemiological authority status, public-health agency status, emergency-response responsibilities, transportation-provider obligations, or supervisory duties over independent third parties.

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2. MULTI-JURISDICTIONAL REGULATORY COMPLIANCE FRAMEWORK

ORO operates under a globally distributed and multi-jurisdictional compliance structure. Accordingly, public health obligations, data disclosure requirements, emergency procedures, and privacy protections may vary significantly depending on the applicable jurisdiction.

ORO evaluates all requests, disclosures, restrictions, preservation obligations, and compliance actions in accordance with applicable laws and regulatory frameworks, including but not limited to:

• public health laws

• epidemiological control regulations

• emergency management laws

• communicable disease regulations

• privacy and data protection laws

• cybersecurity laws

• consumer protection regulations

• lawful disclosure obligations

• judicial orders

• administrative mandates

• international cooperation frameworks

• and emergency governmental directives.

Applicable frameworks may include, without limitation:

• the Health Insurance Portability and Accountability Act (“HIPAA”), where applicable

• the Electronic Communications Privacy Act (“ECPA”)

• the Stored Communications Act (“SCA”)

• state privacy regulations

• GDPR-equivalent frameworks

• cross-border data transfer regulations

• and other applicable international, federal, state, provincial, or local laws.

References to HIPAA or similar healthcare regulations are included solely for legal-compliance purposes where applicable. Nothing in this Policy shall be interpreted as an admission, representation, or acknowledgment that ORO is a healthcare provider, covered entity, healthcare clearinghouse, medical institution, or healthcare business associate under applicable healthcare regulations unless expressly required by law.

Nothing in this Policy shall be interpreted as creating a general obligation to disclose information beyond what is legally required, reasonably necessary, operationally appropriate, or lawfully permitted.

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3. CORE COMPLIANCE PRINCIPLES

In responding to public health-related matters, ORO applies the following operational and legal principles:

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3.1 Legality

All disclosures, restrictions, preservation measures, and compliance actions must be supported by a valid legal basis.

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3.2 Necessity

Only information reasonably necessary for the legitimate public health purpose under review may be processed or disclosed.

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3.3 Proportionality

The scope of any disclosure or operational restriction shall remain proportionate to the identified risk, request, or emergency condition.

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3.4 Data Minimization

ORO seeks to limit disclosure to the minimum amount of information reasonably required under applicable law.

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3.5 Security and Confidentiality

ORO applies commercially reasonable administrative, organizational, operational, and technical safeguards designed to protect information against unauthorized access, misuse, alteration, disclosure, or destruction.

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3.6 Case-by-Case Assessment

All requests are evaluated individually based on applicable law, jurisdictional authority, operational feasibility, proportionality, and internal compliance standards.

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3.7 Accessibility, Inclusion and Technology Neutrality

ORO recognizes that portions of its user base may include elderly individuals, persons with disabilities, accessibility-dependent users, individuals utilizing assistive technologies, and users interacting with the Platform through voice-enabled functionalities.

The existence of accessibility-oriented features, voice-assisted technologies, simplified interaction systems, communication tools, inclusion-focused functionalities, or accessibility accommodations within the technological environment of the Platform shall not be interpreted as creating enhanced monitoring responsibilities, healthcare obligations, epidemiological supervision duties, caregiver functions, public health oversight responsibilities, or heightened legal duties toward any category of user.

All public-health-related evaluations, disclosures, restrictions, and compliance decisions are conducted using the same legal, operational, and regulatory standards applicable to all Platform users, subject only to requirements imposed by applicable law.

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4. REQUEST VALIDATION, AUTHORITY VERIFICATION, AND LEGAL REVIEW

Upon receiving a request from a governmental entity, regulatory authority, healthcare authority, epidemiological agency, or public health institution, ORO may:

• verify the authenticity of the requesting entity;

• validate legal authority and jurisdictional competence;

• confirm the existence of a sufficient legal basis;

• assess proportionality and necessity;

• evaluate operational and legal risk exposure;

• and determine whether disclosure is legally required or permitted.

ORO reserves the absolute right, at its sole discretion and to the maximum extent permitted by law, to:

• reject requests;

• narrow requests;

• seek clarification;

• require additional documentation;

• challenge overbroad demands;

• delay disclosure where legally permissible;

• or refuse cooperation where requests are unlawful, disproportionate, technically infeasible, jurisdictionally invalid, or inconsistent with applicable legal protections.

ORO may require requests to include:

• official institutional identification;

• legal process documentation;

• judicial authorization where required;

• factual support;

• emergency certifications;

• jurisdictional proof;

• and identity verification of requesting personnel.

Enhanced validation procedures may be implemented for high-risk jurisdictions or cross-border requests.

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5. PUBLIC HEALTH EMERGENCY DISCLOSURES

ORO may disclose limited user information without prior notice where legally authorized and where ORO determines, in good faith, that disclosure is reasonably necessary to address:

• imminent threats to life or physical safety;

• communicable disease outbreaks;

• epidemiological emergencies;

• government-declared health crises;

• or significant public health threats.

For purposes of this Policy, emergencies may include:

• infectious disease outbreaks;

• pandemic or epidemic events;

• biological exposure incidents;

• public health containment measures;

• emergency quarantine directives;

• or situations certified by competent authorities as involving serious risk to human life or physical integrity.

Any disclosure shall remain strictly limited to information reasonably necessary under the circumstances, which may include:

• user identification data;

• contact information;

• limited trip or interaction records;

• timestamps;

• approximate exposure windows;

• operational metadata;

• and other narrowly tailored information.

ORO shall not knowingly disclose excessive, unrelated, speculative, or operationally unnecessary information beyond the legally justified scope of the request.

ORO does not independently diagnose, identify, monitor, investigate, track, evaluate, predict, certify, or determine whether any individual has contracted, been exposed to, may develop, or may transmit any communicable disease, infection, medical condition, biological agent, or public health risk.

Any public-health-related determination remains exclusively within the authority of competent governmental authorities, healthcare providers, public-health institutions, epidemiological agencies, or other legally authorized entities.

Geolocation records, trip information, timestamps, communication metadata, routing information, and Platform activity records do not constitute medical evidence, epidemiological findings, infection determinations, health-status certifications, exposure confirmations, or public-health conclusions. Any interpretation of such information remains the sole responsibility of the requesting authority or legally authorized entity.

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6. REQUIREMENTS FOR REQUESTING AUTHORITIES

To be considered for processing, requests should, where legally applicable:

• identify the requesting authority;

• establish jurisdictional competence;

• specify the legal basis for the request;

• identify the relevant emergency or investigation;

• provide sufficient factual justification;

• define the requested scope with specificity;

• and certify that the request complies with applicable law.

Requests should be transmitted through verifiable institutional channels, including official governmental domains, legally recognized submission systems, or authorized correspondence mechanisms.

Official legal requests may be directed to:

legal@orotechnologiesllc.com

ORO reserves the right to establish additional verification requirements, secure transmission protocols, authentication measures, or operational review procedures before processing any request.

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7. USE, RETENTION, AND LIMITATION OF DISCLOSED INFORMATION

Any information disclosed by ORO pursuant to applicable law is intended solely for the lawful purpose identified in the request.

ORO does not control and assumes no responsibility for:

• governmental use of disclosed information;

• downstream processing activities;

• independent data retention practices;

• third-party disclosures by authorities;

• investigative decisions;

• public health determinations;

• or enforcement actions taken by governmental entities.

To the maximum extent permitted by law, requesting authorities are expected to:

• use information only for authorized purposes;

• comply with applicable privacy laws;

• apply appropriate safeguards;

• and avoid unnecessary secondary disclosure.

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8. USER NOTIFICATION POLICY

ORO may notify users regarding governmental or public health-related disclosures unless:

• notification is legally prohibited;

• an emergency circumstance exists;

• a non-disclosure order applies;

• notification could compromise safety;

• notification could interfere with investigations;

• or ORO determines, in its sole discretion, that delayed or withheld notification is reasonably necessary.

Where legally permitted, notification may occur before, during, or after disclosure.

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9. OPERATIONAL SAFETY MEASURES AND ACCOUNT RESTRICTIONS

To protect users, platform integrity, operational continuity, or public safety, ORO may implement temporary operational measures, including:

• account suspension;

• feature restrictions;

• communication limitations;

• service access restrictions;

• temporary deactivation;

• safety verification measures;

• or operational review procedures.

Such measures may be applied where:

• a competent authority identifies a public health risk;

• legally authorized directives are issued;

• significant safety concerns arise;

• platform misuse is suspected;

• or operational integrity may be compromised.

ORO retains sole discretion regarding the implementation, duration, modification, continuation, or removal of operational restrictions.

Nothing in this Policy guarantees uninterrupted access to the Platform during public health events, emergencies, governmental actions, or operational disruptions.

Any operational restriction, temporary limitation, communication control, account review, access suspension, or safety-related measure implemented by ORO pursuant to this Policy is intended solely for platform integrity, legal compliance, operational continuity, security, risk-management, or regulatory purposes and shall not be interpreted as a medical determination, healthcare assessment, infection finding, quarantine order, public-health certification, or clinical evaluation.

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10. COOPERATION WITH GOVERNMENTAL AND PUBLIC HEALTH AUTHORITIES

ORO may cooperate with governmental agencies, public health authorities, emergency management organizations, regulatory bodies, and legally authorized institutions within the limits of applicable law.

Such cooperation may include responses related to:

• infectious disease outbreaks;

• public health emergencies;

• epidemiological investigations;

• emergency response coordination;

• quarantine enforcement;

• lawful containment measures;

• and public safety initiatives.

All cooperation activities remain subject to:

• applicable privacy protections;

• operational feasibility;

• internal compliance review;

• legal limitations;

• and jurisdictional validation.

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11. LIMITATION OF LIABILITY

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

• communicable disease transmission;

• infections;

• public health incidents;

• governmental actions;

• operational interruptions;

• quarantine measures;

• emergency conditions;

• disclosure-related consequences;

• delays in response;

• technical failures;

• or any direct, indirect, incidental, consequential, punitive, special, or exemplary damages arising from or related to public health events or governmental requests.

Users expressly acknowledge that interaction with third parties through the Platform occurs at their own risk.

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11.1 NO MEDICAL, CLINICAL, OR PUBLIC HEALTH SERVICES

ORO TECHNOLOGIES LLC is not a:

• healthcare provider;

• medical institution;

• hospital;

• clinic;

• diagnostic entity;

• emergency response provider;

• telemedicine platform;

• epidemiological authority;

• disease control organization;

• or licensed medical advisory service.

The Platform does not provide:

• medical diagnosis;

• treatment;

• infection detection;

• health monitoring;

• emergency healthcare;

• clinical supervision;

• medical recommendations;

• pandemic response services;

• or disease prevention guarantees.

Any safety-related, accessibility-related, informational, voice-based, or emergency-related functionality provided through the Platform is supplementary, technological, and operational in nature only.

No Platform functionality shall be interpreted as:

• medical care;

• professional healthcare advice;

• guaranteed disease prevention;

• emergency response services;

• or public health supervision.

ORO does not operate emergency medical dispatch centers, public-health command centers, emergency call centers, epidemiological response centers, disease-control operations, or emergency healthcare coordination systems. Any S.O.S., emergency communication, or safety-related functionality available through the Platform operates solely as a technological communication mechanism and may involve independent third-party providers operating under separate legal and operational frameworks.

Users remain solely responsible for:

• seeking independent medical advice;

• obtaining professional healthcare services;

• following governmental recommendations;

• complying with applicable laws;

• and making personal health and safety decisions.

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11.2 NO EPIDEMIOLOGICAL MONITORING OR HEALTH STATUS DETERMINATION

ORO does not perform epidemiological surveillance, disease tracking, infection monitoring, health-status verification, medical screening, exposure assessments, biological risk analysis, health certification, medical investigations, contact tracing services, public-health supervision, or disease-control operations.

The Platform's technological systems, voice-enabled functionalities, communication tools, accessibility features, geolocation systems, safety-related mechanisms, emergency communication technologies, and automated processes are not designed, intended, certified, or operated as public-health monitoring systems.

Any governmental, regulatory, healthcare, epidemiological, or public-health authority utilizing information disclosed pursuant to applicable law remains solely responsible for its independent analysis, interpretation, conclusions, investigations, enforcement decisions, public-health determinations, and regulatory actions.

ORO does not operate contact-tracing programs, exposure-notification systems, epidemiological surveillance networks, infection-monitoring platforms, disease-detection systems, public-health databases, quarantine-management systems, or health-status verification programs unless expressly required by applicable law and implemented through separate legally authorized procedures.

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11.3 NO REQUIREMENT TO PROVIDE HEALTH INFORMATION

Except where expressly required by applicable law, ORO does not require Users, Drivers, Couriers, Providers, Merchants, Business Partners, or other Platform participants to disclose medical diagnoses, treatment information, health records, disability documentation, vaccination records, communicable disease status, laboratory results, medical histories, or other health-related information as a condition of accessing or using the Platform.

Any health-related information voluntarily disclosed by a user shall be processed in accordance with the Platform Privacy Policy, applicable law, operational necessity, and the minimum processing standards reasonably required for the legitimate purpose involved.

Nothing in this Policy shall be interpreted as requiring ORO to collect, verify, validate, monitor, investigate, maintain, update, certify, or continuously review health-related information regarding Platform users.

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12. DISCLAIMER OF WARRANTIES

THE PLATFORM, SERVICES, TECHNOLOGIES, COMMUNICATION SYSTEMS, ACCESSIBILITY FEATURES, VOICE TOOLS, SAFETY FUNCTIONS, AND ALL RELATED SERVICES ARE PROVIDED ON AN “AS IS,” “AS AVAILABLE,” AND “WITH ALL FAULTS” BASIS, WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE.

To the maximum extent permitted by law, ORO expressly disclaims all warranties, including:

• merchantability;

• fitness for a particular purpose;

• non-infringement;

• uninterrupted availability;

• operational accuracy;

• data reliability;

• accessibility performance;

• emergency responsiveness;

• and public health protection guarantees.

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13. INTERPRETATION, MODIFICATIONS, AND CORPORATE DISCRETION

ORO reserves the unrestricted right, at any time and without prior notice, to:

• interpret this Policy;

• update this Policy;

• modify this Policy;

• replace this Policy;

• suspend portions of this Policy;

• implement additional compliance standards;

• and adopt enhanced operational or safety measures.

Continued use of the Platform constitutes acknowledgment and acceptance of this Policy and any modifications thereto.

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14. NO CREATION OF RIGHTS

This Policy:

• is issued for compliance, operational, informational, and risk-management purposes only;

• does not create contractual guarantees;

• does not establish fiduciary duties;

• does not create enforceable rights;

• does not establish healthcare obligations;

• and does not waive any legal defense available to ORO.

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14.1 NO THIRD-PARTY BENEFICIARY RIGHTS

Nothing contained in this Policy shall be interpreted as creating:

• third-party beneficiary rights;

• private rights of action;

• governmental enforcement guarantees;

• healthcare obligations;

• mandatory operational duties;

• or legally enforceable expectations against ORO TECHNOLOGIES LLC or any affiliated entity.

This Policy forms an inseparable component of ORO's unified global legal, operational, compliance, privacy, cybersecurity, accessibility, safety, governance, and enterprise risk-management architecture and shall be interpreted consistently with all related Platform policies, legal frameworks, disclosures, standards, and contractual documents.

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15. EXTERNAL HEALTH INFORMATION DISCLAIMER

Any references to governmental agencies, healthcare organizations, public health resources, pandemic guidance, informational links, medical institutions, or external recommendations are provided solely for informational purposes.

ORO does not:

• endorse;

• verify;

• control;

• monitor;

• guarantee;

• or assume responsibility for third-party information, recommendations, publications, websites, or medical guidance.

Users remain solely responsible for:

• obtaining professional healthcare advice;

• evaluating medical information;

• consulting licensed professionals;

• and making independent health-related decisions.

ORO assumes no liability arising from reliance upon external information, governmental publications, medical resources, or third-party guidance.

Reference Resource:
https://www.cdc.gov/

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15A. NO SPECIAL DUTY TOWARD ELDERLY, DISABLED, OR ACCESSIBILITY-DEPENDENT USERS

The existence of accessibility-oriented technologies, voice-assisted functionalities, simplified interaction models, communication systems, inclusion-focused features, emergency communication tools, accessibility accommodations, or voice-first design principles shall not create any special legal relationship, heightened duty of care, fiduciary obligation, custodial responsibility, healthcare obligation, welfare-check duty, public-health monitoring responsibility, or protective obligation on the part of ORO.

Although the Platform seeks to promote digital accessibility and inclusion, all users remain responsible for making independent decisions regarding their health, safety, transportation arrangements, personal wellbeing, medical care, emergency response, and compliance with public-health recommendations.

To the maximum extent permitted by applicable law, ORO owes the same limited platform-related obligations to all users regardless of age, disability status, accessibility needs, health condition, technological literacy, or use of accessibility-related features.

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16. GLOBAL INTERPRETATION AND PREVALENCE CLAUSE

This Policy shall be interpreted broadly in favor of:

• legal compliance;

• operational scalability;

• platform integrity;

• risk mitigation;

• user safety;

• regulatory cooperation;

• corporate protection;

• and lawful operational continuity.

In the event of any inconsistency between:

• translations;

• summaries;

• localized versions;

• help center content;

• support materials;

• operational communications;

• marketing content;

• FAQs;

• or informational publications,

the official English-language version of this Policy, together with the Platform Terms and Conditions and governing legal frameworks, shall prevail to the maximum extent permitted by law.

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17. LEGAL STATUS OF THIS POLICY

This Policy constitutes an internal compliance framework, operational governance standard, and legal risk-management document of ORO TECHNOLOGIES LLC.

Except where expressly required by applicable law, nothing in this Policy shall be interpreted as:

• creating contractual obligations;

• guaranteeing disclosure practices;

• limiting lawful corporate discretion;

• or expanding liability beyond what is required under applicable law.

This Policy shall at all times be interpreted together with:

• the Platform Terms and Conditions;

• Privacy Policy;

• Community Standards;

• Safety Policies;

• and all applicable legal frameworks governing the Platform.

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GLOBAL LEGAL INTEGRATION NOTICE

These Terms, Policies, Annexes, Disclosures, and related legal frameworks form part of the unified global legal, operational, technological, accessibility, cybersecurity, compliance, and risk-management architecture governing the ORO Marketplace Platform operated by ORO Technologies LLC and its affiliated ecosystem.

Such integrated framework includes, without limitation:

• the Terms and Conditions;

• the Global Privacy, Security and Data Governance Policy;

• the Safety, S.O.S., Emergency Response & User Protection Framework;

• the Voice, Accessibility & Emergency Policy;

• Section 22-A Accessibility, Disability and Vulnerable Users Annex;👉 https://orosay.com/legal/accessibility-annex

• Community Standards;

• Refund and Payment Policies;

• AI, Voice, Security, Accessibility and Compliance disclosures;

• and all related policies, notices, operational standards, legal disclosures, and future amendments published by ORO Technologies LLC.

Continued access to, interaction with, registration on, or use of the Platform constitutes legally binding acknowledgment, acceptance, and incorporation of all applicable policies, limitations, disclaimers, technological conditions, liability restrictions, and future modifications to the maximum extent permitted under applicable law.