Privacy policy

Effective date: 17th August 2021

Arena Technologies, Inc. (“Arena ”) provides businesses with platforms that automate business processes using applied artificial intelligence (“AI ”) (collectively with this website, our “Services ”).

Personal Information We Collect

This Privacy Policy describes how we handle personal information in connection with providing and marketing our Services. Generally, we collect:

lIn connection with our marketing and sales (we are the “data controller ”for this information): information about our prospective and existing business customers and their employees (“business representatives ”).

In connection with the provision of our Services and the development of our algorithms (we are the “data controller ”for this information): information we collect from public sources.

In connection with operating our business and providing our platform (we are a “data processor ”for this information):

Information about our business customers ’authorized platform users (“authorized users ”)

Information that business customers upload to our platform

Here’s More Detail About Our Information Collection Practices:

Information we collect about business representatives (“Business Representative Data ”) (for which we are the “data controller ”), such as:

Contact and account data, such as your first and last name, email address, phone number and username and password.

Communications that we exchange with you, including when you contact us with questions, when you fill out our surveys, provide us with feedback, or otherwise.

Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them.

Data we, our third-party advertising partners, or our service providers collect automatically about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:

Device data, such as your computer ’s or mobile device ’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 4G), and general location information such as city, state or geographic area.

Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

Cookies, which are text files that websites store on a visitor ‘s device to uniquely identify the visitor ’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information we collect from public sources (“Arena-Collected Data ”) to train our AI algorithms and provide our Services (for which we are the “data controller ”). We may collect information that users make public on the Internet, including on social media platforms. This information is available to us because users have chosen to make it public. Generally, each platform from which we collect information has privacy settings that users can adjust to make their information non-public. We do no collect non-public information.

Data that our customers provide to us to train our AI algorithms and provide our Services (“Customer-Provided Data ”) (for which we are a “data processor ”).

Information we collect about authorized users (“Usage Data ”) (for which we are a “data processor ”) such as access logs, support tickets, and other information we collect about users ’interactions with our Services.

How We Use Personal Information

We use personal information for the following purposes or as otherwise described at the time of collection:

We use Busines Representative Data, Customer-Provided Data, Arena-Collected Data, and Usage Data for the following purposes:

Services delivery

Provide, operate and improve our Services and our business, including leveraging platform data and public data to train our AI;

Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages; and

Provide support for our Services, and respond to your requests, questions, and feedback.

Research and development. To continue to operate and improve our Services, and to create new features and capabilities for our users, we may create and use aggregated, de-identified or other anonymous data from personal information we process.

Compliance and protection

We may use personal information to:

Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

Protect our, your or others ’rights, privacy, safety or property (including by making and defending legal claims);

Audit our internal processes for compliance with legal and contractual requirements and internal policies;

Enforce the terms and conditions that govern our website and Services; and

Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

We use Business Representative Data for the following purposes:

Marketing and advertising. We may use contact and account data, marketing data, and data automatically collected from our website for marketing and advertising purposes, including:

Direct marketing. We may send you marketing communications about our Services as permitted by law, including but not limited to, notifying you of new features, special promotions, offers, and events via email, text message, and other means. You may opt out of our marketing communications as described in the Opt out of marketing communications section below; and

Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. We and our advertising partners may use cookies and similar technologies to collect information about your interactions over time across the web, our communications and our corporate website, and use that information to serve online advertisements. You can learn more about your choices for limiting interest-based advertising in the Online tracking opt out section below.

How We Share Personal Information

We may share personal information with:

Customers. We may share Arena-Collected Data and information we derive from that data with our customers.

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).

Advertising partners. When you visit our corporate website, third party advertising companies may use automated technologies to collect information for interest-based advertising purposes described above.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in Arena (including, in connection with a bankruptcy or similar proceedings).

Your Choices

Opt out of marketing communications. You may opt out of marketing-related communications by following instructions contained in the marketing communications we send you.

Online tracking opt-out. There are several ways to limit online tracking on our website, which we have summarized below:

Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based advertising by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available here.

Platform opt outs. The following advertising partners offer opt out features that let you opt out of use of your information for interest-based advertising:

Google

Facebook

LinkedIn

Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:

Digital Advertising Alliance for Websites: outout.aboutads.info

Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices

Network Advertising Initiative: optout.networkadvertising.org

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track

Some Internet browsers may be configured to send "Do Not Track "signals to the online services that you visit. We currently do not respond to "Do Not Track "or similar signals. To find out more about "Do Not Track,"please visit http://www.allaboutdnt.com.

Data rights. You have the following rights with respect to data for which we are the “data controller ”-- Business Representative Data and Arena-Collected Data:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.

Deletion. Delete the personal information that we maintain about you.

Correction. Update or correct inaccuracies in your personal information.

Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

Restriction. Restrict the processing (including the sale of information as defined in the California Consumer Privacy Act) of your personal information.

Objection. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

Applicable law may limit these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request. If we decline your request, we will tell you why, subject to legal restrictions.

You are entitled to exercise the rights described above free from discrimination.

Here is how you can submit requests:

To request access to or deletion of personal information collected via our Services, please email us at privacy@arena-ai.com or fill out this form. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request.

To learn how to limit tracking, please see the Online tracking opt-out section above.

To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.

Authorized agents. California residents can empower an “authorized agent ”to submit requests on their behalf.

You may submit a complaint about our use of your personal information or our response to your requests by contacting us. European residents may also submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Legal Bases for Processing

We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Processing Purpose

Legal Basis

Services delivery

Processing is necessary to perform the contract governing our provision of services in connection with the Services, or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request in connection with the Services.

Research and development

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Compliance and protection

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Processing is also necessary to comply with our legal obligations.

Marketing and advertising

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.

Use for New Purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Processing Personal Information in the US

We are headquartered in the United States. To provide our Services and operate our website, it is necessary for us to process personal information in the United States.

If we transfer your personal information to another country such that we are required to apply appropriate safeguards to your personal information under applicable data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Data Security

We employ several technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Children

The Services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through our Services from a child under 16 without the consent of the child ’s parent or guardian as required by law, we will delete it.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website or otherwise as required by law.

Contact Information

You can reach us by email at privacy@arena-ai.com or at the following mailing address:

Arena Technologies, Inc.33 Irving Place, 8th floor

New York, NY, 10011

Privacy policy

Effective date: 17th August 2021

Arena Technologies, Inc. (“Arena ”) provides businesses with platforms that automate business processes using applied artificial intelligence (“AI ”) (collectively with this website, our “Services ”).

Personal Information We Collect

This Privacy Policy describes how we handle personal information in connection with providing and marketing our Services. Generally, we collect:

lIn connection with our marketing and sales (we are the “data controller ”for this information): information about our prospective and existing business customers and their employees (“business representatives ”).

In connection with the provision of our Services and the development of our algorithms (we are the “data controller ”for this information): information we collect from public sources.

In connection with operating our business and providing our platform (we are a “data processor ”for this information):

Information about our business customers ’authorized platform users (“authorized users ”)

Information that business customers upload to our platform

Here’s More Detail About Our Information Collection Practices:

Information we collect about business representatives (“Business Representative Data ”) (for which we are the “data controller ”), such as:

Contact and account data, such as your first and last name, email address, phone number and username and password.

Communications that we exchange with you, including when you contact us with questions, when you fill out our surveys, provide us with feedback, or otherwise.

Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them.

Data we, our third-party advertising partners, or our service providers collect automatically about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:

Device data, such as your computer ’s or mobile device ’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 4G), and general location information such as city, state or geographic area.

Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

Cookies, which are text files that websites store on a visitor ‘s device to uniquely identify the visitor ’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information we collect from public sources (“Arena-Collected Data ”) to train our AI algorithms and provide our Services (for which we are the “data controller ”). We may collect information that users make public on the Internet, including on social media platforms. This information is available to us because users have chosen to make it public. Generally, each platform from which we collect information has privacy settings that users can adjust to make their information non-public. We do no collect non-public information.

Data that our customers provide to us to train our AI algorithms and provide our Services (“Customer-Provided Data ”) (for which we are a “data processor ”).

Information we collect about authorized users (“Usage Data ”) (for which we are a “data processor ”) such as access logs, support tickets, and other information we collect about users ’interactions with our Services.

How We Use Personal Information

We use personal information for the following purposes or as otherwise described at the time of collection:

We use Busines Representative Data, Customer-Provided Data, Arena-Collected Data, and Usage Data for the following purposes:

Services delivery

Provide, operate and improve our Services and our business, including leveraging platform data and public data to train our AI;

Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages; and

Provide support for our Services, and respond to your requests, questions, and feedback.

Research and development. To continue to operate and improve our Services, and to create new features and capabilities for our users, we may create and use aggregated, de-identified or other anonymous data from personal information we process.

Compliance and protection

We may use personal information to:

Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

Protect our, your or others ’rights, privacy, safety or property (including by making and defending legal claims);

Audit our internal processes for compliance with legal and contractual requirements and internal policies;

Enforce the terms and conditions that govern our website and Services; and

Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

We use Business Representative Data for the following purposes:

Marketing and advertising. We may use contact and account data, marketing data, and data automatically collected from our website for marketing and advertising purposes, including:

Direct marketing. We may send you marketing communications about our Services as permitted by law, including but not limited to, notifying you of new features, special promotions, offers, and events via email, text message, and other means. You may opt out of our marketing communications as described in the Opt out of marketing communications section below; and

Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. We and our advertising partners may use cookies and similar technologies to collect information about your interactions over time across the web, our communications and our corporate website, and use that information to serve online advertisements. You can learn more about your choices for limiting interest-based advertising in the Online tracking opt out section below.

How We Share Personal Information

We may share personal information with:

Customers. We may share Arena-Collected Data and information we derive from that data with our customers.

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).

Advertising partners. When you visit our corporate website, third party advertising companies may use automated technologies to collect information for interest-based advertising purposes described above.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in Arena (including, in connection with a bankruptcy or similar proceedings).

Your Choices

Opt out of marketing communications. You may opt out of marketing-related communications by following instructions contained in the marketing communications we send you.

Online tracking opt-out. There are several ways to limit online tracking on our website, which we have summarized below:

Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based advertising by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available here.

Platform opt outs. The following advertising partners offer opt out features that let you opt out of use of your information for interest-based advertising:

Google

Facebook

LinkedIn

Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:

Digital Advertising Alliance for Websites: outout.aboutads.info

Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices

Network Advertising Initiative: optout.networkadvertising.org

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track

Some Internet browsers may be configured to send "Do Not Track "signals to the online services that you visit. We currently do not respond to "Do Not Track "or similar signals. To find out more about "Do Not Track,"please visit http://www.allaboutdnt.com.

Data rights. You have the following rights with respect to data for which we are the “data controller ”-- Business Representative Data and Arena-Collected Data:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.

Deletion. Delete the personal information that we maintain about you.

Correction. Update or correct inaccuracies in your personal information.

Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

Restriction. Restrict the processing (including the sale of information as defined in the California Consumer Privacy Act) of your personal information.

Objection. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

Applicable law may limit these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request. If we decline your request, we will tell you why, subject to legal restrictions.

You are entitled to exercise the rights described above free from discrimination.

Here is how you can submit requests:

To request access to or deletion of personal information collected via our Services, please email us at privacy@arena-ai.com or fill out this form. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request.

To learn how to limit tracking, please see the Online tracking opt-out section above.

To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.

Authorized agents. California residents can empower an “authorized agent ”to submit requests on their behalf.

You may submit a complaint about our use of your personal information or our response to your requests by contacting us. European residents may also submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Legal Bases for Processing

We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Processing Purpose

Legal Basis

Services delivery

Processing is necessary to perform the contract governing our provision of services in connection with the Services, or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request in connection with the Services.

Research and development

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Compliance and protection

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Processing is also necessary to comply with our legal obligations.

Marketing and advertising

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.

Use for New Purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Processing Personal Information in the US

We are headquartered in the United States. To provide our Services and operate our website, it is necessary for us to process personal information in the United States.

If we transfer your personal information to another country such that we are required to apply appropriate safeguards to your personal information under applicable data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Data Security

We employ several technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Children

The Services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through our Services from a child under 16 without the consent of the child ’s parent or guardian as required by law, we will delete it.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website or otherwise as required by law.

Contact Information

You can reach us by email at privacy@arena-ai.com or at the following mailing address:

Arena Technologies, Inc.33 Irving Place, 8th floor

New York, NY, 10011

Privacy policy

Effective date: 17th August 2021

Arena Technologies, Inc. (“Arena ”) provides businesses with platforms that automate business processes using applied artificial intelligence (“AI ”) (collectively with this website, our “Services ”).

Personal Information We Collect

This Privacy Policy describes how we handle personal information in connection with providing and marketing our Services. Generally, we collect:

lIn connection with our marketing and sales (we are the “data controller ”for this information): information about our prospective and existing business customers and their employees (“business representatives ”).

In connection with the provision of our Services and the development of our algorithms (we are the “data controller ”for this information): information we collect from public sources.

In connection with operating our business and providing our platform (we are a “data processor ”for this information):

Information about our business customers ’authorized platform users (“authorized users ”)

Information that business customers upload to our platform

Here’s More Detail About Our Information Collection Practices:

Information we collect about business representatives (“Business Representative Data ”) (for which we are the “data controller ”), such as:

Contact and account data, such as your first and last name, email address, phone number and username and password.

Communications that we exchange with you, including when you contact us with questions, when you fill out our surveys, provide us with feedback, or otherwise.

Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them.

Data we, our third-party advertising partners, or our service providers collect automatically about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:

Device data, such as your computer ’s or mobile device ’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 4G), and general location information such as city, state or geographic area.

Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

Cookies, which are text files that websites store on a visitor ‘s device to uniquely identify the visitor ’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information we collect from public sources (“Arena-Collected Data ”) to train our AI algorithms and provide our Services (for which we are the “data controller ”). We may collect information that users make public on the Internet, including on social media platforms. This information is available to us because users have chosen to make it public. Generally, each platform from which we collect information has privacy settings that users can adjust to make their information non-public. We do no collect non-public information.

Data that our customers provide to us to train our AI algorithms and provide our Services (“Customer-Provided Data ”) (for which we are a “data processor ”).

Information we collect about authorized users (“Usage Data ”) (for which we are a “data processor ”) such as access logs, support tickets, and other information we collect about users ’interactions with our Services.

How We Use Personal Information

We use personal information for the following purposes or as otherwise described at the time of collection:

We use Busines Representative Data, Customer-Provided Data, Arena-Collected Data, and Usage Data for the following purposes:

Services delivery

Provide, operate and improve our Services and our business, including leveraging platform data and public data to train our AI;

Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages; and

Provide support for our Services, and respond to your requests, questions, and feedback.

Research and development. To continue to operate and improve our Services, and to create new features and capabilities for our users, we may create and use aggregated, de-identified or other anonymous data from personal information we process.

Compliance and protection

We may use personal information to:

Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

Protect our, your or others ’rights, privacy, safety or property (including by making and defending legal claims);

Audit our internal processes for compliance with legal and contractual requirements and internal policies;

Enforce the terms and conditions that govern our website and Services; and

Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

We use Business Representative Data for the following purposes:

Marketing and advertising. We may use contact and account data, marketing data, and data automatically collected from our website for marketing and advertising purposes, including:

Direct marketing. We may send you marketing communications about our Services as permitted by law, including but not limited to, notifying you of new features, special promotions, offers, and events via email, text message, and other means. You may opt out of our marketing communications as described in the Opt out of marketing communications section below; and

Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. We and our advertising partners may use cookies and similar technologies to collect information about your interactions over time across the web, our communications and our corporate website, and use that information to serve online advertisements. You can learn more about your choices for limiting interest-based advertising in the Online tracking opt out section below.

How We Share Personal Information

We may share personal information with:

Customers. We may share Arena-Collected Data and information we derive from that data with our customers.

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).

Advertising partners. When you visit our corporate website, third party advertising companies may use automated technologies to collect information for interest-based advertising purposes described above.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in Arena (including, in connection with a bankruptcy or similar proceedings).

Your Choices

Opt out of marketing communications. You may opt out of marketing-related communications by following instructions contained in the marketing communications we send you.

Online tracking opt-out. There are several ways to limit online tracking on our website, which we have summarized below:

Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based advertising by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available here.

Platform opt outs. The following advertising partners offer opt out features that let you opt out of use of your information for interest-based advertising:

Google

Facebook

LinkedIn

Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:

Digital Advertising Alliance for Websites: outout.aboutads.info

Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices

Network Advertising Initiative: optout.networkadvertising.org

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track

Some Internet browsers may be configured to send "Do Not Track "signals to the online services that you visit. We currently do not respond to "Do Not Track "or similar signals. To find out more about "Do Not Track,"please visit http://www.allaboutdnt.com.

Data rights. You have the following rights with respect to data for which we are the “data controller ”-- Business Representative Data and Arena-Collected Data:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.

Deletion. Delete the personal information that we maintain about you.

Correction. Update or correct inaccuracies in your personal information.

Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

Restriction. Restrict the processing (including the sale of information as defined in the California Consumer Privacy Act) of your personal information.

Objection. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

Applicable law may limit these rights by, for example, prohibiting businesses from providing certain sensitive information in response to an access request and limiting the circumstances in which they must comply with a deletion request. If we decline your request, we will tell you why, subject to legal restrictions.

You are entitled to exercise the rights described above free from discrimination.

Here is how you can submit requests:

To request access to or deletion of personal information collected via our Services, please email us at privacy@arena-ai.com or fill out this form. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request.

To learn how to limit tracking, please see the Online tracking opt-out section above.

To verify your identity prior to responding to your requests, we may ask you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.

Authorized agents. California residents can empower an “authorized agent ”to submit requests on their behalf.

You may submit a complaint about our use of your personal information or our response to your requests by contacting us. European residents may also submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Legal Bases for Processing

We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Processing Purpose

Legal Basis

Services delivery

Processing is necessary to perform the contract governing our provision of services in connection with the Services, or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request in connection with the Services.

Research and development

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Compliance and protection

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Processing is also necessary to comply with our legal obligations.

Marketing and advertising

These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

With your consent

Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Services.

Use for New Purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Processing Personal Information in the US

We are headquartered in the United States. To provide our Services and operate our website, it is necessary for us to process personal information in the United States.

If we transfer your personal information to another country such that we are required to apply appropriate safeguards to your personal information under applicable data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Data Security

We employ several technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Children

The Services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through our Services from a child under 16 without the consent of the child ’s parent or guardian as required by law, we will delete it.

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website or otherwise as required by law.

Contact Information

You can reach us by email at privacy@arena-ai.com or at the following mailing address:

Arena Technologies, Inc.33 Irving Place, 8th floor

New York, NY, 10011

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