Privacy Policy

Who Ario is and what Ario does

Ario is a consumer data infrastructure company. With explicit consumer consent, Ario moves purchase data from a source the consumer authorizes — for example, the consumer's Amazon account — to a recipient the consumer designates, typically an Ario business customer (an "Enterprise") such as a retailer or loyalty operator with whom the consumer already has a relationship.

This policy describes Ario's practices in detail and explains the rights consumers have and how to exercise them.

Information Ario collects

2.1 Information consumers provide directly

When a consumer uses the Ario service to connect an account, Ario collects information the consumer provides as part of that flow, including the email address associated with the consumer's Enterprise relationship and any communications the consumer sends to Ario. When a visitor accesses Ario's websites, Ario may also collect information submitted through contact forms, demo requests, or similar channels.

2.2 Information collected from authenticated accounts

When a consumer authenticates at a source platform (for example, Amazon) through the Ario flow, the source platform issues Ario a revocable access token scoped to specific data access. Ario does not collect or store the consumer's username or password for any source platform. Authentication occurs at the source itself.

Using the token, Ario retrieves the transaction data necessary to fulfill the request the consumer authorized. This typically includes:

• Order date
• Product name and SKU
• Quantity
• Price, including original price, discounts applied, and final amount paid
• Payment method type (for example, credit card, Amazon Pay, gift card) — but not the underlying card number, account number, or other instrument details
• Coupons or promotional codes used
• Return and refund status
• Shipping address
• Other transaction metadata such as the order identifier and shipping method

The full field-level inventory of what Ario retrieves, with definitions for each field, is documented in Ario's data flow diagram, available on request.

Ario does not retrieve or transmit:

• Usernames, passwords, or any credentials
• Payment instrument details such as credit card numbers, debit card numbers, or bank account numbers
• Billing addresses
• Data about other consumers
• Data outside the consumer's own purchase history

2.3 Information about consumer interaction with Ario

Ario maintains an audit log recording each consent event a consumer makes through Ario — granting consent, renewing it, revoking it. The log includes timestamps, source IP addresses for integrity verification, and a cryptographic signature.

2.4 Information collected automatically on Ario's websites

When a visitor accesses Ario's websites (including ariodata.com), Ario collects standard log information such as IP address, browser type, pages visited, and referring URLs through cookies and similar technologies. Ario uses this information to operate, secure, and improve the websites. Visitors can manage cookie preferences through browser settings.

2.5 Information from third parties

The Enterprise with whom a consumer has a relationship may share with Ario the identifier the Enterprise uses to reference that consumer in the Enterprise's system, so that Ario can route the data the consumer authorized to the correct account on the Enterprise side.

How Ario uses information

Ario uses the information collected to:

• Provide the service the consumer requested. Specifically, to authenticate the consumer with the source platform, retrieve the purchase data the consumer authorized, deliver it to the Enterprise the consumer designated, and confirm successful delivery.
• Maintain a record of consent. So that Ario, the consumer, and the Enterprise can verify what was authorized and when.
• Operate, secure, and improve Ario. Including detecting and preventing fraud, abuse, and security incidents.
• Communicate with consumers about the service, including transactional notifications such as connection confirmations, expiry reminders, and revocation receipts.
• Comply with legal obligations and respond to lawful requests from government authorities.

Ario does not:

• Sell personal information to data brokers or any third party
• Use personal data to train artificial-intelligence models, public or private
• Score, profile, segment, or build predictive models about consumers
• Use consumer data for purposes other than fulfilling the request the consumer authorized and the operational and legal purposes listed above

How Ario shares information

4.1 With the Enterprise the consumer designated

The core function of Ario is to deliver the data the consumer authorized to the designated Enterprise. The Enterprise becomes the controller of the received data and handles it under the Enterprise's own privacy policy, which the consumer may review through the existing relationship with the Enterprise.

4.2 With service providers acting on Ario's behalf

Ario shares information with sub-processors who perform services on Ario's behalf, such as cloud hosting and infrastructure providers. These sub-processors are contractually bound to use information only for the purposes Ario directs and to maintain confidentiality and security standards consistent with this policy. Ario's current sub-processor list is available on request.

4.3 For legal compliance and protection

Ario may disclose information when required by applicable law, valid legal process, or governmental request; to enforce Ario's terms; to protect Ario's rights, property, and safety; or to detect and prevent fraud, security, or technical issues.

4.4 With further consumer consent

Ario may share information for purposes other than those listed above only with the consumer's explicit consent.

4.5 In the event of a corporate transaction

If Ario is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to the protections of this policy.

Consumer rights and choices

Consumers have the following rights with respect to personal information. These rights apply regardless of where the consumer resides; some jurisdictions provide additional rights, described in Section 6.

• Right to access. A consumer may request a copy of the personal information Ario holds about that consumer.
• Right to delete. A consumer may request that Ario delete the consumer's personal information.
• Right to correct. A consumer may request correction of inaccurate information.
• Right to portability. A consumer may request the consumer's information in a portable, machine-readable format and direct it to a recipient of the consumer's choosing.
• Right to revoke consent. A consumer may revoke any active consent at any time. Upon revocation, Ario invalidates the source-issued access token, purges any retained data, and notifies the Enterprise that received the data so that the Enterprise's own deletion process is triggered. These actions are taken without undue delay.
• Right to non-discrimination. Ario will not discriminate against any consumer for exercising any of these rights under this policy.

Connections a consumer authorizes through Ario expire by default. The exact duration is configurable by the Enterprise engagement; one year is typical. After expiry, no further data is retrieved without a fresh consent action by the consumer.

Jurisdiction-specific rights

The rights enumerated in Section 5 apply to all consumers, regardless of jurisdiction. The following provisions describe additional rights or procedural requirements that apply to consumers in specific jurisdictions.

6.1 California (CCPA / CPRA)

California residents have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, including the right to know what personal information has been collected, used, or disclosed; the right to deletion; the right to correction; the right to opt out of sale or sharing of personal information (Ario does not sell or share for cross-context behavioral advertising); the right to limit use of sensitive personal information; and the right to non-discrimination for exercising these rights. A California resident may exercise these rights directly or through an authorized agent.

Ario does not collect "Sensitive Personal Information" as defined under California Civil Code §1798.140(ae), so the right to limit its use does not arise in the context of Ario's service. Ario honors recognized opt-out preference signals, including the Global Privacy Control (GPC).

6.2 Virginia, Colorado, Connecticut, Utah, Texas, and other states with comprehensive privacy laws

Residents of states that have enacted comprehensive consumer privacy laws have rights similar to those described in Section 5, including access, deletion, correction, portability, and the right to opt out of targeted advertising, sale, and certain profiling. Where state law provides an appeal mechanism for denied requests, Ario honors that mechanism.

6.3 Canada (PIPEDA, Quebec Law 25)

Residents of Canada have rights under the Personal Information Protection and Electronic Documents Act and, in Quebec, the Act Respecting the Protection of Personal Information in the Private Sector (Law 25). These include the right to access, correct, delete, and (in Quebec) port personal information, and the right to withdraw consent. Ario obtains consent in a manner consistent with the Office of the Privacy Commissioner of Canada's Meaningful Consent guidelines.

6.4 European Union and United Kingdom

Residents of the European Union or the United Kingdom have rights under the General Data Protection Regulation and the UK GDPR including access, rectification, erasure, restriction of processing, data portability, objection to processing, and rights regarding automated decision-making. The legal basis for Ario's processing of personal data is the consumer's consent (Article 6(1)(a)). A consumer may withdraw consent at any time.

How to exercise these rights

To exercise any right described in this policy, contact privacy@ariodata.com. Include the right to be exercised and enough information for Ario to verify the requester's identity.

Ario will respond within forty-five days of receiving a verifiable request, with the possibility of one forty-five-day extension where reasonably necessary, consistent with applicable law. If Ario denies a request, Ario will explain the reason and (where applicable) describe the appeal mechanism available to the consumer.

A consumer may designate an authorized agent to make a request on the consumer's behalf. Ario may require the agent to provide proof of authorization and may require the consumer to verify identity directly.

Ario does not charge a fee for responding to most requests. Ario may charge a reasonable fee for manifestly unfounded or excessive requests, as permitted by applicable law.

Additional privacy controls

Beyond the formal rights described in Sections 5 and 6, consumers have several practical tools for managing data sharing through Ario.

Revoke at the source. Every source platform Ario connects to — including Amazon, Walmart, and others — provides an account interface where a consumer can revoke Ario's access token directly. Doing so immediately terminates Ario's ability to retrieve any further data for that connection, independent of any action taken through Ario.

Browser controls. Ario honors recognized opt-out preference signals, including the Global Privacy Control (GPC). Cookie behavior on Ario's websites can be managed through standard browser settings.

Consumer portal (planned). Ario plans to offer a consumer-facing portal where a consumer may view active connections, see consent history, and revoke any connection in a single action. Until that portal is available, consumers may use the source-platform mechanisms above or contact privacy@ariodata.com.

Data retention

In specific Enterprise engagements where the Enterprise requires retention to power a feature offered to the consumer — for example, a dashboard that lets a consumer view transactions over time — Ario may retain data per the terms of that engagement, governed by contract. In all such cases, the retention serves the Enterprise's product, not Ario's own purposes, and is disclosed to the consumer as part of that feature's consent flow.

Other categories of information Ario holds are retained as follows:

• Source-issued access tokens are retained for the duration of the active connection and invalidated on revocation or expiry.
• The consent audit log is retained in append-only form for a period sufficient to support audit, legal, and dispute-resolution requirements.
• Account-related information about Enterprise relationships is retained for the duration of the underlying contract and for a reasonable period thereafter for legal and compliance purposes.

After applicable retention periods elapse, information is deleted or de-identified.

Data security

Ario implements technical and organizational safeguards designed to protect personal information against unauthorized access, alteration, disclosure, and destruction. All data in transit is protected with Transport Layer Security (TLS 1.2 or higher). All persisted data is encrypted at rest using AES-256. Access to production systems is restricted on a need-to-know basis under role-based access controls, requires multi-factor authentication, and is logged for audit. Ario does not store consumer credentials at any time.

No security program is impenetrable, but Ario's architecture is designed to minimize the impact of any potential incident — for example, by holding no credentials and minimal personal data.

International data transfers

Ario currently serves Enterprises based in the United States, and personal information processed by Ario is stored and processed in the United States. Consumers accessing Ario from outside the United States should understand that information will be transferred to and processed within the United States.

If Ario expands to serve consumers or Enterprises in other jurisdictions, Ario will comply with the applicable international laws governing data storage and cross-border transfers, including any required transfer mechanisms.

Children's privacy

Ario's service is not directed to children under thirteen, and source platforms accessible through Ario require account holders to meet their own age minimums (typically eighteen or older for primary purchase accounts). Ario does not knowingly collect personal information from children. Anyone who believes Ario has inadvertently collected information from a child should contact privacy@ariodata.com and Ario will delete it.

Changes to this policy

Ario may update this Privacy Policy from time to time. Ario will post the updated policy at this URL with a new effective date. Material changes will be communicated to active consumers and Enterprises through reasonable means consistent with the relationship.

Contact

For questions about this policy, to exercise privacy rights, or for any other privacy-related inquiry:

California residents wishing to designate an authorized agent or appeal a denied request should use the same email and indicate the nature of the request.