This privacy policy (“Privacy Policy”) discloses the privacy practices for any ArbJournal-owned website (“Site”). When you submit information to or through the Site, you consent to the collection, use, disclosure and retention of your information as described in this Privacy Policy.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY.

This Privacy Policy applies solely to information collected through the Site. Please note that this Privacy Policy does not apply to information collected through third-party websites or services that you may access through the Site.

This Privacy Policy describes the following:

• What Personal Information is collected from you through the Site;
• How Personal Information is used;
• What choices are available to you regarding the use of your data;
• The security procedures in place to protect the misuse of your information;
• If and why Personal Information may be disclosed to third parties; and
• How you can correct any inaccuracies in the information.

The Effective Date of this Privacy Policy is set forth at the bottom of this Policy. Whenever possible, we will provide you with advance written notice of our changes to this Privacy Policy. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the Site after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

Information Collection, Use, and Sharing

We collect various kinds of information that you provide to us as well as information we obtain from your use of the Site. Some of the types of information that we collect include:

“Personal Information”—information associated with or used to identify or contact a specific person. Personal Information includes, but is not limited to, the following: (1) contact data (such as e-mail address, telephone number, payment information, investment habits and employer); (2) demographic data (such as gender, date of birth and zip code); and (3) certain Usage Data, such as IP address.

“Usage Data”—information about an individual’s online activity that, by itself, does not identify the individual, such as:

• technical information, including your browser type, service provider, IP address, operating system and webpages visited; and
• information about what you’ve searched for and looked at while using the Site.

“Location Data” —a category of Personal Information collected about the location of a mobile device or computer, including:

• the location of the mobile device or computer used to access the Site derived from GPS or WiFi use;
• the IP address of the mobile device or computer or internet service used to access the Site;
• other information made available by a user or others that indicates the current or prior location of the user.

We are the sole owners of the information collected on this Site. We only have access to/collect information that you voluntarily give us via email, through the Site, or other direct contact from you.

We also automatically collect Usage Data when you interact with the Site. We, along with the service providers that help us provide the Site, use small text files called “cookies,” which are small computer files sent to or accessed from your web browser or your computer’s or tablet’s hard drive that contain information about your computer, such as a user ID, user settings, browsing history and activities conducted while using the Site. Cookies are not themselves personally identifiable, but may be linked to Personal Information that you provide to us through your interaction with the Site. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly-generated unique number or similar identifier.

We also use other cookies and other data collection tools (such as web beacons and server logs), which we collectively refer to as “data collection tools,” to help improve your experience with the Site. This may include the use of data collection tools to collect information from the device used to access the Site, such as operating system type, browser type, domain and other system settings, as well as the operating system used and the country and time zone in which the computer or device is located.

We will use your information to respond to you, regarding the reason you contacted us. Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services, or changes to this Privacy Policy.

We may disclose Personal Information to third parties in order to perform services requested or functions initiated by users. In addition, we may disclose Personal Information in order to identify a user in connection with communications sent through the Site. We will not share your information with any third party outside of our organization, other than as necessary to fulfill your application, e.g., screening agencies, etc., or to operate other related services. We will not sell or rent this information to anyone.

We may also use the information we collect for any of the following purposes:

• to operate, improve and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
• to better understand how users access and use the Site, for the purposes of trying to improve the Site and to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users’ usage of the Site;
• to process, validate and verify subscriptions; and
• to provide users with advertising and direct marketing that is more relevant to you;

We also may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Information as required to pursue available remedies or limit damages we may sustain.

We may transfer information, including your Personal Information, in connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify users before your information is transferred or becomes subject to a different privacy policy.

Links to Third-Party Services

The Site may contain links to third-party websites and services (“Third-Party Services”) with which we have no affiliation. A link to any Third-Party Service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a Third-Party Service, you are subject to its privacy policy and practices and not this Privacy Policy. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit.

Your Access to and Control Over Information

We will retain information as long as it is necessary and relevant for our operations. We also retain Personal Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, collect any fees owed and other actions permitted by law. After it is no longer necessary for us to retain information, we dispose of it according to our data retention and deletion policies.

It is important to us that you are able to access and review the Personal Information we have about you and make corrections to it or delete it, as necessary. If you have any questions about how to access your Personal Information, or if you would prefer to opt out of any future contacts from us at any time, please contact us via email:

Security

We take precautions to protect your information. When you submit sensitive information via the Site, your information is protected both online and offline.

Wherever we collect sensitive information (such as payment information), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the webpage.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information.

The computers/servers in which we store personally identifiable information are kept in a secure environment.

Disclaimer: The Site is not intended for use by children. If you are under the age of majority in your place of residence, you may use the Site only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site and subsequently we will delete that information.

Registration and Payment

In order to apply via this website, a user must first complete the Subscription Agreement. During registration a user is required to give certain information (such as name and email address). This information is used to contact you about the products/services on the Site in which you have expressed interest.

We request information from you on our payment pages. To obtain the Subscription Services, you must provide contact information (like name and billing address) and payment information. This information is used for billing purposes. If we have trouble processing an order, we will use this information to contact you.

If you feel that we are not abiding by this Privacy Policy, you should contact us immediately via email at .

Effective Date/Last Modified: February 17, 2020