Last Updated: February 24, 2023
Aurora is committed to protecting the privacy of your Personal Information. By installing the Apps and creating an Account, or by accessing and continuing to use the Websites, Apps or Services, you acknowledge and agree with the notices in this Policy and you consent to Aurora’s collection, use, disclosure, and retention of your Personal Information in accordance with this Policy and as otherwise permitted by applicable provincial and federal privacy laws including the Personal Information Protection and Electronic Documents Act (Canada) and the Personal Information Protection Act (British Columbia).
All capitalized terms used herein, but not defined in this Section 1 shall have the meanings ascribed to them within this Policy.
“Account” means the user account that you create through the Websites or Apps to access and use the Services.
“Apps” means the mobile applications created, managed and owned by Aurora, including but not limited to any Aurora applications that include Aurora Clients’ branding.
“Aurora Clients” means the third parties whose branding is used on the Websites and/or Apps.
“Aurora Products” means Aurora’s proprietary LED lighting systems for indoor rock climbing walls and controller boxes that communicate via Bluetooth or other means with the Apps, and any other products supplied by Aurora from time to time, whether supplied by Aurora directly or distributed or sold through a third party.
“Our Content” means all content that is not your Personal Information, including but not limited to: (A) any features or content that Aurora makes accessible to you through the Websites, Apps or Services; and (B) any content, data or information that you submit, create or upload by your use of the Services, including but not limited to your feedback on the Websites, Apps or Services, climbing boulders and routes, preferences and ascents, type and angle of the climbing board that you use, images, screen shots, videos or audio recordings.
“Personal Information” means information about an identifiable individual.
“Services” means the Websites, Apps, Our Content and all services made available to you by us through the Websites and/or Apps, including but not limited to, the ability to create and customize climbing routes using the Aurora Products and our proprietary software, but excluding the Linked Sites.
“Websites” means our websites at the following URL addresses and all affiliated subdomains: https://auroraclimbing.com/ and https://auroraboardapp.com/, and any websites owned and managed by Aurora that include Aurora Clients’ branding, including, without limitation, the website at the following URL addresses and all affiliated subdomains: https://touchstoneboardapp.com/.
The Website, Apps and Services are intended for use by individuals who have reached the age of majority in the jurisdiction in which they reside. We do not knowingly collect Personal Information from individuals under the age of majority. If you are under the age of majority in your jurisdiction, please do not submit any Personal Information through the Websites, Apps or Services. If you believe we have inadvertently collected such Personal Information, please contact our Privacy Officer at the contact information listed in this Policy immediately so we can remove the information.
Contact information: we collect your Personal Information when you: (i) interact with us to inquire about the Websites, Apps or Services; or (ii) use the Websites, Apps or Services. This may include your first and last name, email address, phone number, and other information that you choose to provide to us.
Account and profile information: we collect your Personal Information when you register for an Account with us, typically after downloading the Apps, and when you create or modify your Account or user profile. This includes information such as your first and last name, your email address, phone number, username and password.
If you permit the Websites, Apps or Services to access location services through the privacy settings on your browser or mobile device, we may also collect the location of your browser or mobile device when the Websites or Apps are running in the foreground or background of your browser or mobile device.
If you have enabled location services in your browser or mobile device, we may track your geolocation on a real time basis when you are using the Websites or Apps. You can choose whether to enable the location tracking feature through the settings on your browser or mobile device. If you choose to disable access to location services through your browser or mobile device, this means that the Websites, Apps and/or Services will not receive location information from your browser or mobile device, which may affect the functionality available to you.
We may also automatically collect the following technical information about your usage of the Websites, Apps and Services usage:
the Internet Protocol (IP) address, web browser, device and operating system that you are using;
the sections of the Websites and/or Apps that you use;
the date and time of your use of the Websites, Apps and/or Services and your in-media time; and
if you were using another website before using the Websites or Apps and if that previous website referred you to our Websites or Apps, the URL of that previous website.
We may choose to link any of the above information with information that is personally identifiable to you. We collect this data for a number of reasons, including to understand the traffic of our Websites and Apps, how it is used, and how we can improve it. We also collect this data to ensure that our Websites and Apps are compatible with your device. We do not share this aggregate data with third parties except for the possible use of third party analytic companies as described below.
We may use “cookies” to track user activity on the Websites and to modify the Websites for a particular user. Cookies enable our Websites to save and retrieve information. For example, cookies allow us to recognize a returning user. Cookies may remain on your device after you leave the Websites (until the cookie expires or is deleted by you). You can disable cookies by adjusting the settings on your internet browser; however, disabling cookies may affect the functionality of the Websites and your ability to access some pages on the Websites.
Aurora will only use your Personal Information to fulfill the purpose for which it was originally collected, or for a use consistent with that purpose, unless you expressly consent otherwise or it is permitted or required by law. We will not use or disclose your Personal Information for any new purpose without first identifying the new purpose and providing notice to or obtaining your consent, unless permitted by law. You can always choose not to provide us with the Personal Information we request, however you may not be able to access or utilize all or part of your Account, the Websites, Apps or Services.
You may withdraw your consent at any time by giving Aurora reasonable notice, but consent may not be withdrawn where doing so would frustrate performance of a legal obligation. In the event you withdraw your consent, certain Personal Information of yours may be retained by Aurora for legal and business purposes, in accordance with the law. Withdrawal of your consent may result in you not being able to access or utilize all or part of your Account, the Websites, Apps or Services.
We may use the Personal Information that we collect for the following purposes:
To provide services to you: we use your Personal Information to provide you with access to the Websites, Apps and/or Services, including to set up your Account and to administer your use of the Websites, Apps and/or Services. For example, we may use your climbing route preferences to generate recommendations for you.
To communicate with you: we use your Personal Information to contact and correspond with you directly about our relationship and your use of the Websites, Apps and/or Services. For example, we may use your Personal Information to respond to specific requests and inquiries from you, including to provide you with information and services that you request. We may use your email address, mail or telephone to communicate with you regarding our Services or other important matters, such as information about your Account. You may not opt-out of receiving communications required by law, or necessary to provide you with requested Services. Aurora or its third party service providers (such as Mailchimp) may also send you information about Services, including general updates and other marketing purposes. You can opt-out of receiving marketing communications from us sent through third party email service provider’s by utilizing the unsubscribe option in the email sent through the third party provider or by contacting our Privacy Officer via the email address below.
To personalize the Websites, Apps and Services: we use your Personal Information to identify what may be of interest to you, and what Services, information and/or offers may be more relevant to you. For example, we may use your contact information to send you information and updates about recommended Aurora Products or Services, including special offers from Aurora Clients.
To generate aggregated statistics: we may use your information to conduct data analysis, testing, research and monitor and analyze Websites, Apps or Services usage and activity trends.
To improve our Websites, Apps and Services: we may use your Personal Information to improve the Websites, Apps and/or Services. For example, we may use the comments and suggestions that you provide to improve our Apps.
Troubleshooting and user support: we may use your Personal Information to respond to customer service requests regarding your Account, the Websites, Apps or Services, and to administer and resolve technical issues on our Websites, Apps or Services.
Legal: we may use your Personal Information to meet legal and regulatory requirements.
Other: we may use your Personal Information to facilitate such other services and activities, as we may identify to you at the time.
Except as described in this Policy or in other situations where we have provided you with prior notice, have obtained your consent, or are obligated or permitted by law, we will not share your Personal Information with third parties.
Any Aurora Client, such as climbing holds producers and distributors, may be able to download reports from the Websites that are drawn from the statistics of the users of Aurora Websites or Apps that contain such Aurora Clients’ branding. These reports may include your Personal Information and any content you have submitted through the Websites, Apps or Services. If an individual user wants to provide feedback to an Aurora Client confidentially, the user should arrange that directly with such Aurora Client outside of our Website or Services.
Aurora may disclose certain Personal Information to third party service providers, to carry out work on our behalf. Currently, we use third party service providers set out below:
Electronic communications: we use third party email service providers, such as Mailchimp and Sendinblue, to send electronic communications to users. These third party email service providers may save a history of whether you open emails, whether you access the link(s) provided in emails, and if you do, when you opened emails or accessed the link(s) provided.
Hosting and Our Content delivery network services: we use third party hosting companies to host our Websites, Apps and Services. Such third party hosting companies’ servers are resident in the Unites States.
We may also partner with additional third party advertisers, ad server companies, and ad networks (“Third Party Advertising Companies”) to promote our Services or Aurora Products. If you respond to one of our advertisements and visit or register to use our Services, we or our third party service providers may provide these Third party Advertising Companies with identifiers from your device or computer, such as an IP address or device ID, to help us analyze our user acquisition efforts.
The third party service providers will have access to Personal Information needed to perform their services, but are only provided the limited amount of information required to perform their services. When we use third party service providers, we require the providers to protect your Personal Information in accordance with the law and with no less than the same or more stringent security and privacy standards than we apply. Any such disclosure of your Personal Information by us to a third party service provider will be conditional upon the information being used solely for the purpose for which it has been disclosed.
The third party service providers identified in this Policy are located across multiple jurisdictions, and your Personal Information may be stored, accessed or used in Canada, the United States or other countries where the Websites, Apps and/or Services are made available and may be subject to the laws and access by government or regulatory organizations in those jurisdictions. If you have any questions about our policies and practices with respect to such service providers, including the collection, use, disclosure, and storage of Personal Information, you can contact our Privacy Officer at the contact information listed in this Policy.
In the event we go through a business transaction such as a merger, acquisition by another company, or a sale of all or a portion of our assets, your Personal Information may be among the assets transferred and any such acquirer of us or our assets may continue to collect, use and disclose your Personal Information as set forth in this Policy.
We may also disclose your Personal Information where authorized or required by law. For example, we may disclose your Personal Information to comply with a subpoena, in response to a law enforcement body with the lawful authority to obtain the information, pursuant to an investigation into the breach of a law, or to our legal counsel.
Aurora takes reasonable steps to protect your Personal Information. We have implemented reasonable physical, technical and organizational measures to protect against unauthorized access, collection, use, disclosure, and disposal, in a manner appropriate to the sensitivity of the information. As well, we will use care when destroying or disposing of Personal Information to prevent unauthorized access, use or disclosure of any Personal Information. Our employees and independent contractors with access to Personal Information are required to respect the confidentiality of such information.
The Websites and Apps include links to external websites (the “Linked Sites”). Once you leave the Websites or Apps, this Policy does not apply. We are not responsible for the privacy practices or collection of Personal Information on external websites. We are not responsible for any lost, stolen, or compromised user IDs, passwords or for any activity on your Account via unauthorized password activity. You should take steps to protect against authorized access to your Account by, for example, choosing a robust password and keeping your password private. We are not responsible for any failure by you to secure your own devices and their access to the Internet or your use of public, unsecured networks.
Personal information collected by us is maintained in accordance with applicable privacy legislation and our retention policies and practices. Generally, Aurora stores your Personal Information for as long as it is reasonably necessary to fulfill the purposes we collected it for, except as otherwise permitted or required by applicable law or regulation. You may request the removal of your Account, and the deletion of your Personal Information associated with your Account, by sending us an email at firstname.lastname@example.org.
Once you deactivate and remove your Account or stop using your Account for a period of twenty-four (24) months, we may choose to delete any Personal Information on your Account after such period as may be required for retention by applicable laws. We may also retain some Personal Information in backup archived copies for a certain period after you remove or stop using your Account.
All Personal Information in your Account is accessible by you. Certain minimum Personal Information must be input in your Account in order to use the App’s services. For example, you must share your email address with us.
You can obtain access to, verify or correct the accuracy and completeness of your Personal Information in our possession and control. In appropriate circumstances, we will amend the information. It is your responsibility to provide any updates to your Personal Information to us in writing.
You may request access to your Personal Information and/or correction of that information by contacting Aurora in writing at the contact information noted below, with sufficient detail to enable us to identify the Personal Information being sought. When you contact us, we may ask for further information to confirm your identity and the nature of the information being sought.
After we receive your request for access to Personal Information, we will provide you with an estimate of when you can expect a response. In some cases, we may need additional time to respond to a request, in which case we will provide you with written notice of the extension. Please note that we may deny your access to Personal Information where such denial of access is authorized by law. There are also cases where we may be legally required to refuse access to Personal Information. If we deny your request for access to Personal Information, we will advise you of the reason for the refusal, and will provide the name, title, and contact information of the designated person who can address the refusal.
We may charge a reasonable fee according to the cost required to retrieve and provide access to the requested information. We may provide an estimate of the fee in advance and in some cases, will require a deposit for all or part of the fee.
Those who choose to use or access the Websites, Apps or Services from outside Canada do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. Notwithstanding the foregoing, and recognizing the global nature of the Internet, each user shall comply with all local rules regarding online conduct and submission of acceptable materials. This Policy shall be governed and and construed in accordance with the laws of the Province of British Columbia and the federal laws of Canada applicable therein, without regard to its conflict of laws principles.
Aurora may update this Policy from time to time by posting a new version of the Policy on the Websites. Our collection, use, disclosure, and retention of your Personal Information will be governed by the version of the Policy in effect at that time. We suggest that you review this Policy periodically.
Questions or concerns regarding this Policy, including the collection of your Personal Information, can be directed to the Aurora Privacy Officer, who is responsible for ensuring our compliance with this Policy. You can contact the Privacy Officer at email@example.com.
Aurora takes any complaint about our privacy practices seriously. We will investigate all complaints. If we find a complaint justified, we will take the necessary steps to resolve it. The complainant will be informed of the outcome of the investigation regarding any complaint.
If you are not satisfied with our response to a complaint, you may have options to exercise various complaint procedures, including with the relevant Privacy Commissioner (if you are based in Canada) or regulatory authority (if you are based outside of Canada).