Privacy Policy

Effective October 1, 2026
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Aura Sub, LLC and its affiliates (collectively referred to as “Aura”, “We”, or “Us”) is a leading provider of digital security products for consumers. This General Privacy Policy describes how we collect and process Personal Data provided to Aura in connection with your use of our products, software, services, apps, and websites (including when you are a prospective customer, customer, or former customer (“Customer”)) that link to this policy (collectively as our “Services”). The term “Personal Data” refers to information that is related to an identified or identifiable natural person (aka ‘Personal Information’ or ‘personally identifiable information’).

Product Privacy Notices. This policy describes Aura’s general approach to ensuring privacy considerations across all our Services. Some of the features within our Services, however, may require us to collect and process different Personal Data from what is described in this policy. The following links provide further information on product-specific features:

1. Aura Identity Theft Protection Services
2. Aura Antivirus
3. Aura VPN
4. Aura Call Protection
5. Aura Parental Controls
6. Thrive
7. Aura for Business Program

1. What Personal Data Do We Collect About You?

This section describes the various categories and types of Personal Data we collect from and about you when you use our website, apps, and when you interact with us in relation to our Services. The personal data we may collect may differ depending on which product you use. Please see our Products Privacy Notices for more information.

The information we collect includes:

1.1 Personal Data You Provide to Us

We and our service providers may collect personal data about you to provide our Services, respond to your requests, and manage your account with us. We collect this data via forms on our websites and apps, when you contact us or register an account, and in our communications with you. Where service components go beyond the base service, we provide you with clear choices to decide if you want these additional functions.

1. Registration Data. When you create or update your account, we may collect your name, username, email address, phone number, password, your government ID numbers (when you use our Identity Protection Products) and certain other data from you, including if applicable, your account and login information with our affiliate Circle. For our Identity Protection Products, we may also request your Social Security number.

2. Billing and Payment Information. To purchase a Service, we may collect billing name, billing contact details (street addresses, email addresses), and payment instrument details.

3. Identity Verification Information. To verify your identity, we may collect your full legal name, email addresses, your date of birth, social security number, home address, or phone numbers.

4. Communications and Submissions. We collect details when you communicate with us (e.g. via email, phone, or chat for support or to inquire about our services), including when you fill out an online form, respond to surveys, provide feedback, post comments to our website, participate in promotions, participate in forums, websites and related information services to share your experiences or discuss technical issues, or submit information through our Services.

5. Photos and Documents. You may choose to upload and provide us with images and files that are stored on your device in relation to your use of our Services.

6. Marketing and Advertising Data. We collect details on your participation in promotions, survey responses, your marketing choices, data regarding your preferences based on your use of our Services, your interactions with advertising and marketing communications, and information regarding your customer profile, such as age and gender. 

7. Emails. If you activate our email protection services and connect your email service provider inbox to Aura, we will collect the emails in your inbox and emails that you receive on an ongoing basis. We will collect all data associated with the emails except for any files attached to your emails. This includes, but is not limited to, the sender’s email address, the content of the email, and the subject line.

8. Product-Specific Information. Some of our products, such as Aura Parental Controls, may have additional requirements. Please see the specific Product Privacy Notices (at the top of this policy) for more information on the specific categories, identities, purposes, and data retention of third parties that we share data with.

1.2 Data Collected Automatically when You Use Our Services

We automatically collect personal data about your use of our Services to monitor for problems and look for opportunities to make improvements. Some of this personal data is collected using cookies and similar technologies (see below for more information).

1. Usage Data. We collect details about how you interact with our Services, such as how often you use our Services, how much bandwidth you use, and when and for how long you use our Services.

2. Device Data. We collect details such as device identifiers (such as IP address or mobile device identifiers), browser types, device types and settings, device manufacturer and model, operating system versions, mobile, wireless, and other network data (such as internet service provider name, carrier name and signal strength), and application version numbers.

3. Diagnostic Data. We may collect details about the nature of the requests that you make to our servers (such as what is being requested, information about the device and app used to make the request, timestamps, and referring URLs).

4. Location Data. Unless otherwise expressly stated in product-specific materials, we do not automatically collect your precise geo-location data based on your device’s GPS or other device sensor data. However, we may collect your approximate geolocation by calculating an imprecise latitude and longitude based on your IP address to provide you with better service (e.g. to connect you to the nearest and fastest VPN server).

1.3 Data Provided to Us by Third Parties

As part of our Services, with your consent or where authorized by law, we can receive personal data about you from third parties. We take the same level of precautions and transparency of use that we provide for personal data you provide us directly.

1. Referrals. If you are invited to use an Aura service, the person who invited you may submit data about you, such as your email address or other contact details.

2. Threat Data. We receive data from reputable members of the security industry who provide information to help us to provide, develop, test, and improve our services (for example, lists of malicious URLs, spam blacklists, phone number blacklists, and sample malware). Some of this data may contain personal data on an incidental basis.

3. Business Customers. Organizations that use our business and enterprise products may submit personal data to facilitate account management and invite individuals to use those products. We process such personal data at the direction of such business customers.

4. Monitoring Services. For some of our products and Services that we provide to you, we will collect publicly available data from third parties to provide the extent of disclosures to you. For example, court records, home title, auto title, and dark web scanning.

2. How Do We Use Your Personal Data?

Aura uses your personal data for the purposes described below. We employ internal risk management functions to ensure we continue to only use your personal data for the purposes we disclose to you and are taking appropriate steps to protect that Personal Data from exposure. Notwithstanding any other legal bases for the processing of personal data outlined in this Privacy Policy, namely our legitimate interest, we will only process personal data of residents of Canada with their consent, or where authorized by law.

1. To Provide, Maintain, Troubleshoot, and Support Our Services. We use your personal data for this purpose on the basis that it is required to fulfill our contractual obligations to you. Examples: using information about how much bandwidth you use and how long you use our Services in order to provide the services in accordance with a plan to which you have subscribed; using threat and device data to determine whether certain items pose a potential security threat; and using usage data to troubleshoot a problem you report with our Services and to ensure the proper functioning of our Services.

The delivery of our Services may rely on AI Features, our AI-powered analytics, detection, and insights capability. For a full description of how AI Features works, what it can and can not do, see Section 3 (AI Features) below.

2. For Billing and Payment Purposes. We use your personal data in order to perform billing administration activities and process payments, which are required to fulfill our contractual obligations.

3. To Communicate With Users and Prospective Users. We use your personal data to communicate with you via email, SMS, push notifications or other messaging about the services or relevant updates, including by responding to your requests, and sending you data and updates about our Services. We may do this in order to fulfill our contract with you, because you consented to the communication, or because we have a legitimate interest in providing you with information about our Services.

4. To Promote, Operate or Improve Our Services and Advance Our or a Third Party’s Legitimate Interests. We want to offer you the best Services and user experiences we can. Where applicable, we have a legitimate interest in continually improving and optimizing our Services. To do so, we use your personal data to help ensure the effective delivery of our Services and communications to you as well as to our other customers and partners. Examples include:

• to notify you about changes to our terms or this Privacy Policy;
• to promote and administer co-branded offers with trusted partners;
• enable participation in interactive features of our Services;
• communicate commercial promotions or inform you about additional Services or features that we think you may be interested in;
• confirm sales conversions and conduct lead generation activities;
• analyze certain usage, device, and diagnostic data to understand aggregated usage trends and user engagement with our Services (and, for example, invest in technical infrastructure to better serve regions with increasing user demand);
• use device and threat data or data to conduct spam, scam, threat, fraud and other scientific research to improve our detection capabilities;
• improve our machine-learning algorithms to enhance our Services;
• review customer feedback to understand what we could be doing better;
• use data such as who or what referred you to our services to understand how effective our advertising is;
• use data to administer promotional activities such as sweepstakes, contests, offers, promotions and referral programs.

5. For Measurement, Research and Analytics, including Product Development of New Services. Where applicable, we have a legitimate interest to develop and improve our Services, measurement, research, and analytics, including to plan for and develop new Services. For example, we may analyze certain usage data to understand how users interact with our Services and make improvements; we may use customer feedback to understand what new Services users may want.

6. For Advertising And Marketing Our Services, Including Targeted Advertising, Through The Use Of Cookies. For more information on targeted advertising and cookies, please see Section 4 (Tracking Technologies & Cookies) and our Cookie Policy. Our app is not ad supported, and we do not share personal data collected from our app with third party advertising services.

7. Aggregate or De-identify Personal Data for Any Purpose. We may take steps to aggregate or de-identify personal data we collect, and may use such data for any purposes, which includes but is not limited to regulatory compliance; research and analysis; product development, improving our Services; marketing and advertising activities; improving our AI Features, and any other legitimate business purposes.

8. To Prevent Harm or Liability. We may do this to comply with our legal obligations, to protect an individual’s vital interests, or because we have a legitimate interest in investigating security issues and preventing harm or liability to Aura and our users. For example, we may use account, usage, and device information to determine if an entity is engaging in abusive or unauthorized activity in connection with our Services.

9. For Legal Compliance. We internally use your Personal Data as required by applicable law, legal process, or regulation, to enforce our legal rights, and resolve disputes and complaints. To learn about our practices regarding sharing your Personal Data with third parties for legal compliance purposes, see Section 4.10 below.

REMOTE SUPPORT

If applicable for the Parental Control Services, Aura or its duly authorized support representatives, which may include its affiliate Circle (defined below), may need to access your account information in order to troubleshoot, debug, and otherwise offer support and solutions to users. Remote access may be enabled by the user via the App. If you make a support request and wish to limit the level of access for the Parental Control Services in your App or account, you must state those limitations at the time of your support request.

3. Aura AI Features

Aura uses Artificial Intelligence (AI), Machine Learning (ML), and related technologies, including generative and agentic systems (collectively, "AI Features") as core components of many of its Services. This section explains how AI Features works, what personal data it uses, and what it does and does not do.

1. What are Aura’s AI Features?

AI Features is the AI system that powers monitoring, detection, analytics, and insights features integrated throughout our suite of Services. It works by analyzing and correlating data from your from our Services, including, but not limited to, VPN connection metadata, credit activity, antivirus signals, dark web monitoring, device security, data broker information, derived signals or attributes from SMS, Call, and Email Protection, and Aura Parental Controls (where active), to identify potential risks, generates alerts and insights, power a conversational assistant, and recommend actions you can take. 

The use of AI is a material aspect of how Aura delivers its services and is a key mechanism by which Aura detects identity threats, monitors credit activity, filters calls and email, and surfaces digital safety insights. Without AI Features, Aura's core Services could not function as described.

2. What AI Features Does Not Do

AI Features Does Not Make Decisions About You

AI Features are designed to empower your decision-making, not replace it. AI Features generates alerts, flags, and insights based on patterns in your data across the suite of Aura Services. These outputs are informational tools delivered to you for your review. Aura does not take autonomous action affecting your financial accounts, credit records, identity documents, or legal status. Certain protective features, such as automated threat quarantine and call filtering, may act automatically on your device to deliver the Services you have subscribed to, as described in our Terms of Service. You decide how and whether to act on any information Aura surfaces. 

Aura Does Not Make Automated Decisions with Significant Effects on You

Aura does not use AI to determine your eligibility, approval, or denial, for financial services, credit, insurance, housing, employment, or healthcare. All outputs from AI Features are informational alerts and insights delivered to you for your evaluation. Any actions based on data Aura surfaces are made by you.

3. How We Use Your Data for AI Features

AI Inference for Service Delivery

To power the AI Features outlined here, Aura utilizes your personal data from across the suite of Aura Services. Our Service delivery depends on this processing. Aura may be unable to provide the Services you have subscribed to without utilizing AI Features to process your personal data.

Product Development 

To continuously improve our Services, Aura may use aggregated or de-identified data, as described in Section 2.7 of this Privacy Policy, for product development. This includes developing and improving AI Features and our other Services.

4. Who Do We Share Your Data With and Why?

In some situations, Aura may share your personal data with third parties who may collect, store, use, process and transfer the data for Aura. Aura employs oversight processes and controls to the secure sharing of personal data with only trusted parties. Neither Aura, nor any of the companies that comprise Aura, “sell” your personal data. Some of our uses of cookies and/or pixels, however, may be considered a “sale” or “share” under applicable laws and regulations.

4.1. In General

We may disclose your Personal Data in the following circumstances:

1. In Accordance with Your Consent. For example, some services may allow you to register an account using a third-party account (such as a Google or Microsoft account). If you choose to do so, we will share information with the third-party account provider.

2. To Your Business Organization (For our Business Services). If a business customer is providing you with access to our Services through a business account, others in that organization may be able to see and manage your basic account details and the data associated with your account (such as an administrator). For clarity, we do not share the data inside your account such as bank account information, credit scores, etc.

3. For Collaborating with Others. Some Services may provide ways for different Aura users to interact or collaborate with each other (e.g. family plans). Your information will be shared in connection with those activities if you choose to engage in them.

4. Affiliates. We may share your name, email address, and other contact information with our subsidiaries and affiliates including Circle Media Labs, Inc. (“Circle”) to better market our collective products and Services to you. We and our affiliated entities may also share data with third-party data controllers where such sharing is legally required, such as with the use of certain cookies and related tracking technologies for compliance with specific geographic laws.

5. With our Partners. We may provide your personal data to partners to confirm your eligibility for joint or co-branded offers or to communicate and administer such offers (e.g. verify eligibility, assess effectiveness of joint offer, etc.). Our partners are not allowed to use any data including personal data that they receive from us for any purpose except for communicating, evaluating, improving, and administering the offer in question. This will not affect the partner’s ability to use personal data that it may already have obtained from you or other sources. If you do not wish to receive promotional emails from our partners, you can unsubscribe directly using the unsubscribe link or tool provided in the partner’s email or other communication to you.

6. Third-Party Service Providers. With the exception of any data collected through your use of our virtual private network where our VPN Product Privacy Notice applies, we may disclose the data we collect to service providers to help us operate some aspects of our Services. We work with trusted third parties and partners (including our affiliate companies such as Circle when they act as our service providers). In cases where we may share your personal data, we enter into appropriate confidentiality and data processing agreements with these third parties, review their security practices, and limit data sharing to the scope of what they are helping us with. Examples of activities that third parties help us with include:

• processing customer payments;
• providing analytics about our Services to help us understand how the Services are being used;
• providing sales and customer support;
• maintaining the infrastructure required to provide our Services;
• delivering our marketing and advertising content;
• Powering Aura AI Features, which include, without limitation, Aura's unified intelligence layer, conversational or "ask-an-expert" assistants, and AI-generated insights, summaries, narratives, scores, classifications, alerts, and recommendations, as well as any feature we identify as AI-powered now or in the future

Please see the specific Product Privacy Notices, such as Aura Parental Controls, for more information on the specific categories, identities, purposes, and data retention of third parties that we share data with.

7. For Security Research Purposes. A de-identified subset of our threat intelligence data may be shared with selected reputable members of the cybersecurity industry for the purpose of security threat research and facilitating community efforts to improve online security.

8. In Connection with a Business Transaction. If a corporate transaction occurs, for example changes to ownership or control of all or part of our Services, assets, or business, sale of a website, initial public offering, or an investment entity is conducting due diligence in connection with an acquisition or investment, then we may share personal data necessary to that corporate transaction.

9. Aggregated or De-Identified Data. We may aggregate or de-identify data we collect, and may use and share such data for purposes that include regulatory compliance; research and analysis; product development, improving our Services; our marketing and advertising activities; and other legitimate business purposes.

10. To Comply with Legal Process and The Law. If you use our VPN product, we help protect your privacy by ensuring that we do not log or record online activities that you conduct over a VPN connection in any way that can be tied back to you, meaning that we do not have any data to share with law enforcement and government agencies who make requests for data about what you were doing through a VPN connection. Subject to the foregoing, we may share your data if we are required to do so by applicable law; to comply with our legal obligations; to comply with legal process; and to respond to valid law enforcement requests relating to a criminal investigation, or alleged or suspected illegal activity that may expose Aura, you, or any of our other users to legal liability. If we share your information for these purposes, we limit the data shared to what is legally necessary, and challenge information requests that we believe are unlawful, overbroad, or otherwise invalid.

11. To Enforce Our Rights and Prevent Fraud and Abuse. We may share limited amounts of your data to enforce and administer our agreements with customers and users, and to respond to claims asserted against Aura. We may also share your data in order to protect against fraud and abuse against Aura, our affiliates, users and others.

5. Tracking Technologies & Cookies

For more information on Tracking Technologies and Cookies and how we use Tracking Technologies and Cookies please see our Cookie Policy.

6. Security

Securing personal data is an important aspect of protecting privacy. Aura employs a range of administrative, organizational, technical, and physical safeguards designed to help protect your data against unauthorized access, use, disclosure, loss, or modification. We endeavor to use reasonably available state-of-the-art network and information security standards, protocols and technologies, including encryption, intrusion detection and data loss prevention, and we monitor our systems to ensure that they comply with our security policies.

We implement physical, technical and organizational safeguards to protect your personal data under our control, both at rest and in transit, and should these measures fail to prevent a data breach, we will promptly take the necessary remedial measures, and we will provide notices as required by applicable law.

If you have any questions about the security of your personal data or the security of our products, or wish to report a potential security issue, please contact Security@Aura.com. When reporting a potential security issue, please describe the matter in as much detail as possible and include any information that might be helpful.

7. Cross-Border Data Transfers

Aura Sub, LLC, including Aura Consolidated Group, Inc., Aura Holdco, LLC, Circle Media Labs, Inc., Get Aura, LLC, Family Zone, Inc., Qustodio LLC, and Smoothwall, Inc. (collectively, ”Aura”) adheres to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (collectively, “DPF”), as set forth by the U.S. Department of Commerce.

Aura has certified to the U.S. Department of Commerce that it adheres to the DPF Principles regarding the processing of all personal data that is transferred from the European Union, United Kingdom (and Gibraltar), and Switzerland in reliance on the DPF. If there is any conflict between the terms in our Privacy Policy and the DPF Principles, the DPF Principles shall govern. Additionally, Aura may protect your personal data through other legally valid methods, including international data transfer agreements based on the Standard Contractual Clauses. To learn more about the DPF program and to view our certification, please visit https://www.dataprivacyframework.gov/ and search for ”Aura” within the ‘Data Privacy Framework List’ page.

Aura collects the categories of personal data described in Section 1, and uses and discloses personal data covered by the DPF for the purposes described in Sections 2 and 3 of this privacy policy. Aura may disclose personal data covered by the DPF to the third parties described in Section 4. If your personal data was transferred to Aura from the EEA, the UK, or Switzerland in reliance on the DPF, you may exercise certain choices under the DPF regarding how some of your personal data is used and disclosed, and may access, correct, limit the use or disclosure of, or delete certain personal data by following the instructions in Section 10 (Your Global Privacy Rights) of this privacy policy. Please note that we may be required to disclose your personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Aura is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. As required under the DPF Principles, when we receive personal data under the DPF and then transfer it to a third-party service provider / sub-processor acting as an agent on our behalf, we remain liable under the DPF if our agent processes such personal data in a manner inconsistent with the DPF, unless we prove that we are not responsible for the event giving rise to the damage.

We encourage you to contact us as provided below should you have a DPF related concern or complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our alternative dispute resolution provider based in the U.S., the International Centre for Dispute Resolution, the international division of the American Arbitration Association (ICDR-AAA) to seek resolution, free of charge, by calling 888-855-9575 or visiting https://go.adr.org/dpf_irm.html. You may also contact your local data protection authority within the European Economic Area, U.K., or Switzerland (as applicable) for unresolved complaints. Under certain conditions, more fully described on the Data Privacy Framework website, including when other dispute resolution procedures have been exhausted, you may invoke binding arbitration.

Aura is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) or any other U.S. authorized statutory body.

Contact Us: If you have any questions or concerns, please contact our US Aura establishment at Privacy@Aura.com or Customer Service, P.O. Box 52330, Boston, MA 02205, or our EU establishment at DPO@Qustodio.com.

8. Data Retention

Aura retains your personal data for as long as is needed to provide the Services to you, as specified with any product-specific privacy notice, or for as long as you have an account with us. We may also retain personal data if required by law, or, where applicable, for our legitimate interests, such as abuse detection and prevention, and defending ourselves from legal claims. Residual copies of personal data may be stored in backup systems for a limited period as a security measure to protect against data loss.

9. Your Privacy Choices (US Only)

Aura is compliant with all applicable U.S. privacy rights related to our processing of your personal data. Where acceptable by law, we may require you to verify your identity using the processes we describe in the dashboard or the Your Privacy Choices page before we fulfill your request, even if you utilize an Authorized Agent to complete such a request on your behalf. For Personal Data we have about you, you can:

• Delete: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
  
  
• Right to Access and/or Take: You can ask us for a copy of your personal data in machine readable form.
  
  
• Object to, or Limit or Restrict the Use: You may have additional rights to limit the use of your ‘Sensitive Personal Data’, which may include government-issued identifiers, precise geo-location information, or financial account data.
  
  • For any Sensitive Personal Data that we collect, we will only use or disclose it to deliver the Services you subscribed to, either with your specific consent when required, or as otherwise permitted by law.
  • As we do not use or disclose Sensitive Personal Data for any other purposes, we do not offer you an option to limit the use of Sensitive Personal Data other than through the settings and controls available to you through our Services, or your browser or mobile device operating system. 
  • You may also choose to discontinue the use of these Services.
    
    
• Opt out Sale or Sharing: You may also have the right to opt-out of the ‘sale’ of your personal data, or the ‘sharing’ of your personal data for targeted or cross-contextual behavioral advertising purposes.
  
  • Aura does not ‘sell’ personal data as that term is commonly understood, but we enable third party advertising services to utilize pixel tags and cookies on our website or through other tracking technologies in order for Aura to advertise our products and services on other websites or mobile applications. These third party advertising services are considered to be categorized as a ‘sale’ or ‘share’ for targeted or cross-contextual behavioral advertising. You can learn more about this in our Cookie Policy. 
  • You can opt out of these ‘sale’ and ‘sharing’ activities by accessing our Your Privacy Choices page located from the footer of our website. 
  • This page also describes how we honor opt-out preference signals (aka; ‘Global Privacy Control’) which you may configure through your browser. We do not respond to what is formerly known as ‘Do Not Track’ signals. 
  • Some of our Services enable parents or guardians to register or otherwise enable Aura to process the personal data associated with children under the age of 16. We do not knowingly sell or share personal data related to children under 16 years of age.
    
    
• Opt out of Automated Decision-Making: Applicable frameworks may require opt-out rights, or in some cases human review mechanisms, when AI is used to make "significant decisions" producing legal or similarly significant effects on a user.
  
  • Aura does not make significant decisions within the meaning of these frameworks, and accordingly these automated decision opt-out obligations do not apply to AI Features. AI Features produce informational outputs such as alerts, flags, and insights that are reviewed and controlled exclusively by you, the user. Aura does not determine your eligibility, approval, or denial, to any financial service, credit product, insurance, housing, employment, or healthcare. 
  • Aura does not use your personal data to create profiles about you that we use to inform decisions that have legal or similarly significant effects. However, some of our Services such as our financial alerts or Parental Controls software may provide you with information which you may use to make your own decisions.
    
    
• Change or Correct: You can edit some of your personal data through your account and settings. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
  
  
• Unsubscribe from Marketing:
  
  • Email: Click the link at the bottom of our marketing emails or by contacting our Support Team directly at (833) 552-2123, available 24/7;
  • SMS: Reply with the word ‘Stop’.
• Appeal: Some states allow you to appeal a denial of your request.
  
  • Residents of Colorado, Connecticut, Delaware, Florida, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oklahoma, Oregon, Rhode Island, Tennessee, Texas, or Virginia: If we deny your original request, you can appeal the denial by following the instructions listed in the denial communication, or by submitting an Appeal Request through the Privacy Portal. ‍
    
    
• Lodge a Complaint: To lodge a complaint directly to Aura, you can contact us by telephone at +1 (844) 914-2991 or via email at privacy@aura.com.

You have the right to not be discriminated against. Aura will not penalize or discriminate against you for exercising your privacy rights. Aura may, however, be unable to provide certain core AI-powered features of the Services if the processing necessary for those features is restricted, because, as described in Section 3.1, AI Features is a core component of the Services rather than an optional add-on.

10. Your Global Privacy Rights

If you live in the United Kingdom, Australia, Switzerland, or European Economic Area (“EEA”), you may have certain legal rights in relation to your Personal Data that we maintain. Subject to exceptions and limitations provided by applicable law, you may be able to exercise some of these rights by submitting your request at our Privacy Portal, or by dialing +1 (844) 914-2991. Please note your rights and choices vary depending upon your location, and some information may be exempt from certain requests under applicable law.

Anonymity Note: We are unable to directly assist with your inquiry or complaint anonymously or pseudonymously. In order to identify you as a current or former customer of Aura and to verify the Services, we require certain key pieces of personal data, such as first name, last name, and email address. As permitted by law, we may ask you to verify your identity before taking further action on your request. 

These rights may include the right to:

1. Be informed of the source(s) from which we obtained your personal data;

2. Access a copy of your personal data that we hold;

3. Access the categories of personal data we collect, disclose or sell about you (including the categories of sources of such data, the business or commercial purpose for collecting or selling your personal data, and the categories of third parties with whom we share your personal data;

4. Update or correct your personal data if it changes or if you believe that any data that we have collected about you is inaccurate or out-of-date;

5. Object to or restrict our use or processing of your personal data;

6. Be informed of and submit observations regarding automated decision-making;

7. Unsubscribe from SMS marketing by replying with the word ‘Stop’ or unsubscribe from our email list by clicking the link at the bottom of our marketing emails or by contacting our support team directly at (833) 552-2123, available 24/7;

8. Reject or delete cookies through your browser settings or tailor advertising through third party cookies (refer to our list of advertising services using cookies here for company-specific choices, or visit https://optout.aboutads.info/ to exercise an industry-wide opt-out);;

9. Delete or erase your personal data;

10. Port your personal data to another service provider / processor;

12. Withdraw your consent in circumstances we rely upon your consent to process your personal data (please note that withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted upon other lawful processing grounds); or

13. Lodge a complaint with a data protection authority. To lodge a complaint directly to Aura or for other inquiries, including access and rectification requests, you can contact us by telephone at +1 (844) 914-2991, via email at privacy@aura.com, or contact our Data Protection Officer (DPO). Aura has appointed Dentons Europe (Germany) GmbH & Co.KG as our DPO. You can reach Dentons by:

1. emailing DPO.Aura.Europe@dentons.com; or
2. mail at the following address: Dentons Europe (Germany) GmbH & Co.KG, Markgrafenstraße 33, 10117 Berlin, Germany

14. Not be penalized or discriminated against for exercising your privacy rights. We may, however, be unable to provide certain core AI-powered features of the Services if the processing necessary for those features is restricted, because, as described in Section 3.3(a), AI Features is a core component of the Services rather than an optional add-on.

11. Legal Basis for Our Processing of Your Personal Data

We may only process personal data where we have a sufficient legal basis, such as your consent or where authorized by law.

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*You expressly authorize and consent to the collection, processing, and sharing of your child’s personal data by adding them to your Family Plan, setting up and by registering their devices with the Parental Control Services and/or creating their profile for the Parental Control Services with us under your account or the Family Plan.

12. Technology Licensing

Aura occasionally licenses its technology to third party partners who may integrate it with applications developed and offered by those partners. Our partners, and not Aura, are responsible for those applications and for determining what data is collected by those applications and how it is processed. Please contact the relevant partner and refer to their Privacy Policy to learn more about how those applications process your personal data.

13. Age Restrictions

The administration, configuration and management of Aura accounts are not intended for and may not be used by minors. In this context, minors are individuals under the age of 18 or as defined by applicable law. Aura does not knowingly collect personal data from minors when creating or administering our accounts or allow them to be an administrator of our Services except in certain cases. Minors may use certain of our Services but only with the consent and administration of their parent or legal guardian.

In the case of Aura Parental Controls offered as part of the Aura subscription, it is expressly designed for parents to monitor the Internet and mobile activity of their children. As a result, certain personal data related to a minor child may be accessible by the parent-administrators of the Aura Parental Controls, as well as Aura in our administration of the Services. For more information please see the Supplemental Parental Controls Privacy Notice.

If we discover that we have collected personal data from a minor without appropriate consents, we will delete such data without notice. For certain regions, parental consent may be required for processing the personal data of children under the age of 16. In such cases, those under the age of 16 may not use the services without the consent or authorization of their parent or legal guardian. If you believe your minor child has provided personal data without parental or guardian consent, you, as the parent or guardian may contact us by emailing us at privacy@aura.com.

13. Privacy Policy Updates

We may revise this policy from time to time and we will notify you of any changes. Review it occasionally so that you keep up-to-date on our most current practices. We will put the “Last Updated” date at the top of each policy. For material changes, particularly to how we process children’s data, we will give active notice (email or in-app), and where a change requires consent, we will ask for it. If you disagree with such an update to this policy, you may cancel your account and exercise your Privacy Rights.

14. Contact Us

If you have any questions or complaints, including questions about AI Features, you can contact us by telephone at +1 (844) 914-2991, via email at Privacy@Aura.com, or by mail to the following address:

Aura Sub LLC dba Aura
250 Northern Ave.
3rd Floor
Boston, MA 02210

Archived Versions

Current version, September 17, 2026: Added details about AI Features; supplemental details about global privacy rights, including US State privacy rights; updated regions; revised for readability.

• March 4, 2026: Added supplemental details about global privacy rights, including US State privacy rights; updated regions; revised for readability.
• October 3, 2024: Added supplemental details about Aura Parental Controls and US State privacy rights; revised for readability.
• April 8, 2024: Updated to reflect new capabilities of the Aura service‍
• January 31, 2024: Updates to Terms of Service and Privacy Policy to reflect new regions of the Aura services‍
• September 1, 2023: Reflected new capabilities of the Aura services‍
• August 22, 2023: Reorganized provisions for better readability‍
• April 28, 2023: Correcting the description of our products‍
• March 4, 2023: Added new features such as Call Assistant‍
• July 10, 2022: Clarifying our brands and affiliates, adding in Parental Controls‍
• April 1, 2022: Updated what information we collect and how we share it‍
• November 1, 2021: Rebranding FigLeaf to Aura Privacy‍
• June 8, 2021‍
• September 8, 2020