Last updated: April 2, 2026 · Effective: April 2, 2026
Here is a plain-language summary of our key data practices. Please read the full policy below for complete details.
| What we collect | Account info, style preferences, wardrobe data, photos you upload, feature usage data, and mailing list email addresses |
|---|---|
| Why we collect it | To provide and improve the Oro service, generate personalized recommendations, and communicate with you |
| Who we share it with | AI and cloud service providers (all in the US) who help us operate the Service. We do not sell your data. |
| Where it's stored | AWS servers in the United States (US-East-1, Northern Virginia) |
| How long we keep it | Photos: deleted within 30 days of your request. Account data: deleted within 30 days of account closure. Mailing list: until you unsubscribe. |
| Your rights | Access, correct, and delete your data. Withdraw consent at any time. Where technically feasible, request a portable copy of your data. |
| Contact | admin@buildingoro.ca |
Oro Digital Inc. (Corporation No. 1780273-1) is a corporation incorporated under the Canada Business Corporations Act, with its registered office in Ontario, Canada. Oro is the controller of your personal information collected through the Service.
Our designated Privacy Officer is responsible for overseeing our compliance with applicable privacy legislation and can be reached at:
Privacy Officer: Sunny Wu
Email: admin@buildingoro.ca
We collect personal information in the following categories:
When you create an account, we collect your name, email address, and a hashed (encrypted) version of your password. We do not store your password in plain text.
To provide personalized recommendations, we collect information about your style preferences, clothing items in your wardrobe (including descriptions, categories, and attributes), and outfit choices you make within the app.
You may upload photographs of yourself or your clothing items. Before processing any photographs of you personally, we will request your explicit consent within the app. Once consent is given, we collect, store, and process those images using image recognition technology solely to assist with wardrobe organization and outfit recommendations. See Section 5 for details on how photos are shared with our AI service providers.
Our AI systems generate mathematical representations of your style preferences (called "embeddings") based on your wardrobe data and interactions. These embeddings are stored in our database and are used to power your personalized recommendations. They are derived from your personal information and constitute personal information under applicable privacy legislation.
We collect information about how you use the Service, including which features you access, how long you spend on different parts of the app, and interactions you make within the app. This data helps us understand how the Service is being used and improve the user experience.
If you signed up for our waitlist or mailing list, we hold your email address for the purpose of sending you updates about Oro. You may unsubscribe at any time. See Section 6 for details on our communications practices.
We automatically collect certain technical information when you use the Service, including your device type and operating system, app version, general location (country/region level only, inferred from your IP address — not precise GPS location), and error and performance logs necessary to maintain and debug the Service.
We do not collect precise GPS location, payment card information, government-issued identification, or any biometric data beyond photographs you explicitly choose to upload.
We use your personal information only for the purposes for which it was collected, or for compatible purposes you would reasonably expect. Specifically:
We use your account information, wardrobe data, photos, and style embeddings to operate the Oro application and generate personalized outfit recommendations for you.
We use feature usage data and aggregated, anonymized information to understand how the Service is being used, identify bugs, and improve the user experience. Any use of your personal information to train or improve our AI systems requires your separate explicit consent, which we will request within the app.
We use your email address to send transactional messages (account confirmations, security alerts, and service notifications) and, with your express consent, marketing and promotional communications about Oro.
We use technical and usage data to detect and prevent fraud, abuse, and security incidents, and to enforce our Terms of Service.
We may use or disclose your personal information where required to do so by applicable law, regulation, or court order.
We are committed to obtaining meaningful consent for the collection and use of your personal information, as required by the Personal Information Protection and Electronic Documents Act (PIPEDA). Under PIPEDA, we are required to obtain your knowledge and consent before or at the time of collecting your personal information. We collect, use, and disclose your personal information only for the purposes described in this Policy. If we wish to use your personal information for a new purpose not identified in this Policy, we will identify that new purpose and obtain your consent before doing so.
We obtain your consent in the following ways:
You may withdraw your consent to any non-essential data processing at any time by contacting us at admin@buildingoro.ca or through the settings within the app. Withdrawal of consent may affect our ability to provide certain features of the Service. Withdrawal of consent does not apply retroactively to personal information already collected and used in accordance with this Policy prior to withdrawal.
We do not sell your personal information. We share your information only in the following circumstances:
To operate the Service, we share personal information with the following categories of third-party service providers, all of which are located in the United States:
All third-party service providers with whom we share personal information are required to maintain appropriate safeguards and to use your information only for the specific purposes for which it was shared.
In future versions of the Service, we may share aggregated and anonymized analytics data with brand partners (such as the number of users who viewed a particular category of clothing). We will never share your personally identifiable information with brand partners without your explicit consent. We will update this Privacy Policy and provide appropriate notice before any such data sharing begins.
We may disclose your personal information if required to do so by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Oro, our users, or others.
If Oro is involved in a merger, acquisition, financing, or sale of all or substantially all of its assets, your personal information may be transferred as part of that transaction. We will notify you via email or a prominent notice within the app before your information is transferred and becomes subject to a different privacy policy.
We send transactional messages that are necessary to provide the Service, including account confirmations, password resets, security alerts, and notifications about actions you take within the app. You cannot opt out of transactional messages while your account is active.
We send marketing and promotional communications only with your express consent, as required by Canada's Anti-Spam Legislation (CASL). Every marketing message includes a clear and easy way to unsubscribe. You may withdraw your consent at any time by clicking "unsubscribe" in any marketing email or by contacting us at admin@buildingoro.ca.
If you provided your email address to join our waitlist or mailing list, we hold your email address for the purpose of sending you updates about Oro's launch and features. You may unsubscribe at any time by clicking the unsubscribe link in any email we send you or by contacting us at admin@buildingoro.ca.
Oro is a Canadian company, but we use service providers located in the United States to operate our Service. This means your personal information is transferred to and processed in the United States, which has different privacy laws than Canada.
Specifically, your data is stored on servers located in the United States (AWS US-East-1, Northern Virginia), and is processed by AI service providers and email service providers also located in the United States.
While we take steps to ensure that our service providers maintain appropriate safeguards for your personal information, please be aware that your information may be subject to access by US government authorities under US law, including the USA PATRIOT Act and other national security legislation.
We inform you of these transfers through this Privacy Policy and through our in-app consent flows. By providing your personal information to us, you are acknowledging that it will be transferred to and processed in the United States as described in this Policy.
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our retention practices are as follows:
After the applicable retention period, your personal information is securely deleted or anonymized so that it can no longer be associated with you.
We rely on you to provide accurate personal information and to update it when necessary. You may correct your account information at any time through the app settings or by contacting us at admin@buildingoro.ca. We take reasonable steps to keep the personal information we hold as accurate and up-to-date as necessary for its stated purposes.
We implement technical and organizational measures designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include:
No method of data transmission or storage is 100% secure. While we take reasonable steps to protect your information, we cannot guarantee absolute security. If you believe your account has been compromised, please contact us immediately at admin@buildingoro.ca.
In the event of a data breach that poses a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as required by PIPEDA's breach notification rules.
Under PIPEDA and applicable privacy legislation, you have the following rights with respect to your personal information:
Request a copy of the personal information we hold about you.
Request that we correct inaccurate or incomplete information about you.
Request that we delete your personal information, subject to certain legal exceptions.
Withdraw your consent to non-essential data processing at any time.
Where technically feasible, request a copy of your data in a structured, machine-readable format.
Lodge a complaint with the Office of the Privacy Commissioner of Canada.
Note: data portability is not currently a formal right under PIPEDA, though we will make reasonable efforts to provide your data in a usable format upon request. All other rights above are recognized under PIPEDA.
To exercise any of these rights, please contact our Privacy Officer at admin@buildingoro.ca. We will respond to your request within 30 days. In some cases, we may need to verify your identity before processing your request.
If you are not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or by calling 1-800-282-1376.
The Service is not directed to individuals under the age of 16. We do not knowingly collect personal information from anyone under 16. If we become aware that we have collected personal information from a person under 16 without appropriate consent, we will take steps to delete that information promptly.
If you believe we may have collected personal information from or about a person under 16, please contact us at admin@buildingoro.ca.
The Service may contain links to or integrations with third-party websites and services. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access through or in connection with Oro.
We may update this Privacy Policy from time to time. For material changes — including any changes to how we collect, use, or share your personal information — we will notify you via the app or email at least 14 days before the changes take effect and will ask you to actively acknowledge the updated Policy within the app. For non-material changes, we will post the updated Policy with a revised "Last updated" date.
If you do not agree to the updated Policy, you may delete your account at any time by contacting us at admin@buildingoro.ca.
If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Privacy Officer:
We will acknowledge your inquiry within 5 business days and aim to resolve all privacy complaints within 30 days. If you are not satisfied with our response, you may escalate your complaint to:
Office of the Privacy Commissioner of Canada
30 Victoria Street, Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
www.priv.gc.ca
Our Privacy Officer is here to help.
Email: admin@buildingoro.ca
Response time: Within 5 business days
Oro Digital Inc. — Corporation No. 1780273-1 — Incorporated under the Canada Business Corporations Act