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Remember that your use of Arkose Labs’s Services is at all times also subject to the customer agreement and/or other end user agreement between you and Arkose Labs.
List of Contents
- What Does This Privacy Policy cover?
- Transfers of Personal Data
- EU Personal Data
- Notice of What Information We Collect and How We Use It
- Types of Personal Data We Collect
- Information We Collect Directly From You
- Information We Receive From Third Party Sources
- Information We Automatically Collect When You Use Our Service
- Cookies
- Web Beacons
- Information Collected From Other Websites and Do Not Track Policy
- Use of Personal Data
- Processing Grounds
- How, And With Whom, Is Your Information Shared?
- Security
- Data Retention
- Your Privacy Rights
- Rights Under GDPR
- Access, Rectification, Erasure, Withdrawal of Consent, Portability, Objection, Restriction of Processing and Right to File Complaint
- Resolving Privacy Complaints, Generally
- California
- Rights Under GDPR
- What Choices Do You have?
- Do Not Track Policy
- Changes to the Privacy Policy
- Children
- Contact us
- Types of Personal Data We Collect
- Transfers of Personal Data
1. WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy covers our treatment of Personal Data that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage. We gather various types of Personal Data from our users, as explained in more detail below, and we use this Personal Data internally in connection with our Services, including to personalize, provide, and improve our services, to allow you to set up a user account for our services, to contact you and, in some cases, allow others to contact you, to fulfill your requests for certain products and services, to assist with any operational difficulties or support issues, and to analyze how you use the Services. In certain cases, we may also share some Personal Data with third parties, but only as described below.
2. TRANSFERS OF PERSONAL DATA
The Services are hosted and operated in the United States (“U.S.”) through Arkose Labs and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you are located. By using the Services, you acknowledge that Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Arkose Labs in the U.S. and will be hosted on U.S. servers, and you authorize Arkose Labs to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. as set forth herein.
3. EU PERSONAL DATA
If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the E.U. General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Arkose Labs is the controller of your Personal Data except where we process Personal Data of our customers’ end users and employees in connection with our provision of services to these customers, in which case we are the processor of Personal Data, and those customers are the controllers of the Personal Data.
For questions about cases where we are the controller of your Personal Data, or to inquire about your rights in such cases where applicable, please contact us at GDPR@arkoselabs.com. For more information about your potential rights under the GDPR in cases where we are the processor, and to exercise such rights where applicable, please contact the controller party in the first instance.
If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at GDPR@arkoselabs.com.
4. NOTICE OF WHAT INFORMATION WE COLLECT AND HOW WE USE IT
a. Types of Personal Data We Collect
We collect and maintain Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
b. Information We Collect Directly From You: We receive Personal Data directly from you when you provide us with such Personal Data (for example, when you create an account, fill out a survey or send us feedback), including without limitation the following:
● Name
● Postal, residential and/or company addresses
● Email address
● Phone number(s)
● Username and password
● Bank account and credit or debit card details
● Age
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g. Other Uses: In the event we propose to use any Personal Data for purposes not set forth in this Privacy Policy, at or around the time we collect such Personal Data from you, we will endeavor to provide you with a notice which details how we will use and disclose that specific information or seek your consent prior to such disclosure or use.
8. SECURITY
We endeavor to protect the privacy of your account and other Personal Data we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We will take reasonable steps to (i) make sure that the Personal Data we collect, use or disclose is accurate, complete and up to date, (ii) protect your Personal Data from misuse, loss, unauthorized access, modification or disclosure both physically and through computer security methods; and (iii) destroy or permanently de-identify Personal Data if it is no longer needed for its purpose of collection.
Furthermore, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
9. DATA RETENTION
We retain Personal Data about you for as long as it remains relevant. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
We reserve the right to access, read, preserve and disclose any information we retain that we reasonably believe is necessary to comply with law or court order, to enforce or apply our Arkose Labs Terms and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others.
10. YOUR PRIVACY RIGHTS
a. Rights Under GDPR
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights where we are the controller of your personal data, or to submit a request, please email GDPR@arkoselabs.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
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You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
b. RESOLVING PRIVACY COMPLAINTS, GENERALLY
We have put in place a mechanism and procedure to resolve privacy complaints. We will endeavor to deal with all complaints in a reasonably appropriate timeframe.
In order to resolve a complaint, we: (a) will liaise with you to identify and define the nature and cause of the complaint; (b) may request that you provide the details of the complaint in writing; (c) will keep you informed of the likely time within which we will respond to your complaint; and (d) will inform you of the legislative basis (if any) of our decision in resolving such complaint.
We will keep a record of the complaint and any action taken in a Register of Complaints.
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