Privacy Policy
Arlene, Inc. and its subsidiaries and affiliates (“Arlene,” “Company”, “we”, or “our”) are committed to respecting and protecting your privacy and personal information. We recognize the need for appropriate protection and management of the personal information you provide us. This Privacy Notice (the “Notice”) explains our practices with respect to the data we collect or learn about you regardless of the format (“Personal Information”). This includes Personal Information collected:
- When you purchase Arlene products or services;
- When you interact with us directly or through our websites, mobile applications, or social media;
- Through business relationships you or your organization maintain with us; or
- When you request marketing or promotional materials from us.
We encourage you to review this Notice to understand how we collect, process, use, share, and safeguard your Personal Information. If you are an employee, temporary employee, contractor, or employment candidate for Arlene, please refer to the Arlene Employee Privacy Notice for more information on how we collect, process, share, and retain your personal information.
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What is Personal Information
Personal Information is any information that enables us to identify you and that is related to an identified or identifiable natural person, such as a name, email address, telephone number, an identification number, location data, or an online identifier. If you would like to learn more about what constitutes Personal Information, please click here.
Personal Information We Collect
We may collect Personal Information from and about you from a variety of sources, including when you provide it to us directly; automatically when visit our websites or use our mobile applications; interact with us on social media; or register an account with us or use our products or services. Examples of Personal Information that we collect include name and address, email address, telephone number, product or service purchase history, device identifiers, and IP address. If you would like to learn more about how we collect your Personal Information, please click here.
How We Use Your Personal Information
We use your Personal Information to provide or administer our products or services to you, to respond to your inquiries or requests for information, and to support our internal processes, such as marketing or product improvements. If you would like to learn more about how we use your Personal Information, please click here.
Disclosure of Your Personal Information to Third Parties
We share your Personal Information among our affiliates and with our service providers that help us manage and maintain our relationship with you, such as to facilitate payment. If you would like to learn more about how we share or disclose your Personal Information, please click here.
Cross-Border Transfer of Your Personal Information
Arlene transfers Personal Information it collects to the United States and other countries where Arlene or its service providers conduct business. If you would like to learn more about how we transfer your Personal Information, please click here.
Legal Basis for Processing Your Personal Information
We only collect and process your Personal Information based on certain legal bases, including with your consent, to perform a contract, for our own legitimate interests, or in compliance with our legal obligations. If you would like to learn more about the reason we process your Personal Information, please click here.
How We Protect Your Personal Information
We use reasonable and appropriate physical, technical, and organizational security measures to protect your Personal Information against manipulation, risks of interception, data loss or corruption, destruction, access by unauthorized persons, viruses, or other harmful programs. If you would like to learn more about how we safeguard your Personal Information, please click here.
How Long We Retain Your Personal Information
Your Rights and Choices
Depending on applicable data protection and privacy laws, you may be entitled to a variety of legal rights regarding the collection and processing of your Personal Information, including but limited to the right to know the Personal Information we collect and process about you, the right to access or correct such Personal Information, and the right to erasure of such Personal Information. If you would like to learn more about your rights, where applicable, and how to exercise them, please click here.
What is Personal Information
Personal Information is any information that enables us to identify you and that is related to an identified or identifiable natural person, such as a name, email address, telephone number, an identification number, location data, or an online identifier. If you would like to learn more about what constitutes Personal Information, please click here.
Personal Information is any data element that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.
General examples of Personal Information can include the following:
Category | Examples |
|---|---|
| Identifiers | Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers |
| Demographic Information | Name, signature, Social Security number, physical characteristics or description, address, telephone number, age, date of birth, passport number, driver’s license or state identification number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories. |
| Sensitive Data Classifications | Race, national origin, citizenship, religion or creed, marital status, medical condition or information, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), or health insurance information. |
| Commercial Information | Information about products or services purchased, obtained, or considered, or other purchasing or consuming histories related to our products and services. |
| Internet or Mobile Application Activity | Browsing history, search history, information on an interaction with our website, application, or advertisement. |
| Geolocation Data | Physical location associated with certain products. |
| Device Data | Data obtained from devices regarding usage, service needs and device performance. |
Personal Information We Collect
We may collect Personal Information from and about you from a variety of sources, including when you provide it to us directly; automatically when visit our websites or use our mobile applications; interact with us on social media; or register an account with us or use our products or services. Examples of Personal Information that we collect include name and address, email address, telephone number, product or service purchase history, device identifiers, and IP address. If you would like to learn more about how we collect your Personal Information, please click here.
We strive to only collect Personal Information that is adequate, relevant, and limited to achieve the purpose(s) for which it was collected, and to keep all Personal Information accurate, complete, and reliable for its intended need.
Types of Personal Information We May Collect
When you research, purchase, or use our products or services, we may collect the following types of Personal Information, either directly or indirectly, through our websites, mobile applications, or other means to provide you with products, services, support, and related information:
- Full Name
- Address
- Telephone number
- Email address
- Device data (e.g., IP address, operating system)
- Account credentials
Ways We Collect Personal Information
- Personal Information You Share with Us: we collect Personal Information when you provide it to us directly, such as through our interactions with you; when you subscribe to our services; when you create or register an online account with us; when you contact us with questions, requests, or complaints; or when you interact with us on our websites, our mobile applications, or through social media. For example, if you visit our websites and fill out the contact forms, we ask that you provide us with information, such as your name and contact information, or if you subscribe to our newsletter or other marketing material, we ask for your email address.
- Personal Information We Collect Automatically we collect Personal Information automatically when you visit our websites or use our mobile application through logging and analytics tools, including the use of cookies. We use cookies and other analytics tools to collect data about your visit to our websites or your use of our mobile applications, to help diagnose problems with our servers or software, to administer and improve our websites and our other online services, and to permit analytics providers to gather information about your visit or use of our services. We use the data collected through cookies and other analytical tools to store information; provide custom, personalized content; monitor the traffic, use, and effectiveness of our websites and mobile application; diagnose or fix problems; and improve user access.
- Information Obtained from Third Parties: we may collect Personal Information from third-party sources, including our service providers, such as Google Analytics, through your interactions with us on social media, through industry, marketing, or trade associations, and through public agencies or credit bureaus.
You have choices about certain Personal Information we collect. When you are asked to provide your Personal Information, you may decline to do so; but if you choose not to provide your Personal Information that is necessary for us to provide any aspect of our products or services, you may not be able to use those products or services. Where we collect Personal Information from you indirectly from third parties, we will endeavor to inform you as soon as practicable of the identity of the third-party information source and what we intend to do with the Personal Information.
Finally, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, or data associated with your business or organization, and is not, therefore, Personal Information. To the extent this data is stored or associated with your Personal Information, we will treat it as Personal Information; otherwise, it is not subject to this Notice.
How We Use Your Personal Information
We use your Personal Information to provide or administer our products or services to you, to respond to your inquiries or requests for information, and to support our internal processes, such as marketing or product improvements. If you would like to learn more about how we use your Personal Information, please click here.
We may use your Personal Information for one or more of the following business purposes:
- to provide and support requested products or services;
- to support our internal activities, such as marketing, and product and service development;
- to enable Arlene to comply with laws, regulations, or legal requests, including to enforce this Notice;
- to support certain internal processes to ensure protection of property and interests, including fraud detection, internal auditing, supporting internal and external investigations, and conducting security assessments;
- to enable you to contact Arlene, and for us to respond to you; and
- to operate and improve services, websites, mobile applications, and our support of such products and services.
Disclosure of Your Personal Information to Third Parties
We share your Personal Information among our affiliates and with our service providers that help us manage and maintain our relationship with you, such as to facilitate payment. If you would like to learn more about how we share or disclose your Personal Information, please click here.
When we share your Personal Information, we require the receiving party to have appropriate security measures in place and prohibit them from using the Personal Information for their own purposes or outside what is necessary to provide the service.
We share Personal Information as follows:
- Among affiliates and business partners that share infrastructure, systems, and technology to process your Personal Information, as permitted by applicable law, and in accordance with this Notice;
- With third-party service providers, contractors, and subcontractors to help us establish, maintain, and manage our relationship with you and, as necessary, for the operation of our business;
- With third-party technology service providers who help us operate our websites and mobile application, maintain our customer and marketing databases, engage in promotions, and deliver communications, among other legitimate business purposes;
- With public authorities, such as law enforcement, as legally required or necessary to protect our rights or the rights of others;
- With involved entities in the event of a sale, merger, acquisition, or other transfer of all or any portion of our business or assets; or
- With other third parties when you request us to do so.
Cross-Border Transfer of Your Personal Information
Arlene transfers Personal Information it collects to the United States and other countries where Arlene or its service providers conduct business. If you would like to learn more about how we transfer your Personal Information, please click here.
Personal Information will be processed or stored in these countries for the purposes described in this Notice. These countries may have data protection and data privacy laws that differ from those of your country of residence. We have safeguards in place to protect your Personal Information when it is transferred to other countries, including, where required by law, the use of standard contractual clauses approved by the EU Commission. If you have any questions or would like to review the standard contractual clauses, reference the Contact Us section.
Legal Basis for Processing Your Personal Information
We only collect and process your Personal Information based on certain legal bases, including with your consent, to perform a contract, for our own legitimate interests, or in compliance with our legal obligations. If you would like to learn more about the reason we process your Personal Information, please click here.
We process your Personal Information for, or based on, one or more of the following legal bases:
- Your Consent: when you opt-in to receive our materials, including marketing and promotional materials, we process your Personal Information to send messages or materials to you about us and the products and services we offer. You can withdraw you consent at any time.
- Performance of a Contract: we may use your Personal Information to enter into, or perform under, the agreement between us and you or the business with which you are associated.
- Legitimate Interests: we may use your Personal Information for our legitimate interests, including improving our services; providing information about our products and/or services; preventing and detecting fraud; ensuring network and information security; and for administrative purposes.
- Compliance with Legal Obligations and Protection of Individuals: we may use your Personal Information to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.
How We Protect Your Personal Information
We use reasonable and appropriate physical, technical, and organizational security measures to protect your Personal Information against manipulation, risks of interception, data loss or corruption, destruction, access by unauthorized persons, viruses, or other harmful programs. If you would like to learn more about how we safeguard your Personal Information, please click here.
Although we make diligent effort to ensure the protection, confidentiality, integrity, availability, resilience, and security of our network and systems, no method of safeguarding information is completely secure, and we cannot guarantee or warrant the security measures will protect all Personal Information. The security of your data also depends on you. You accept and assume the inherent risks of online communication, including information you transmit to us online.
How Long We Retain Your Personal Information
We retain your Personal Information for only as long as necessary to provide our products and services to you, for the purposes set out in this Notice, to protect the rights, property, or safety of Arlene and our customers, users, personnel, and other third parties, or to meet legal requirements.
After this period, we will securely dispose of Personal Information or take appropriate measures to anonymize it in the event it must be retained.
Your Rights and Choices
Depending on applicable data protection and privacy laws, you may be entitled to a variety of legal rights regarding the collection and processing of your Personal Information, including but limited to the right to know the Personal Information we collect and process about you, the right to access or correct such Personal Information, and the right to erasure of such Personal Information. If you would like to learn more about your rights, where applicable, and how to exercise them, please click here.
You may exercise these rights, to the extent they apply to you, by contacting us as outlined at the end of this Privacy Notice by following instructions provided in communications sent to you. Note, however, that we may request certain reasonable additional information (that may include Personal Information) to help us authenticate your identity, your request(s), and/or to clarify or understand the scope of such requests. We will respond to a valid request relating to your rights within one month of receipt, or within three months where a request is complex or challenging.
Individual rights vary depending on the laws of the jurisdiction applicable to you, but may include:
- The right to know whether, and for what purposes and from what source, we collect and/or process your Personal Information.
- The right to access, modify, or correct your Personal Information.
- The right to know with whom we have shared your Personal Information, for what purpose, and what Personal Information we have shared.
- Where processing of Personal Information about you is based on consent, the right to withdraw your consent to such processing.
- The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you.
- The right to request restriction of processing of your Personal Information or object to processing of your Personal Information carried out pursuant to (i) our legitimate interest or (ii) performance of a task in the public interest (including, but not limited to, processing for direct marketing purposes).
- In certain circumstances, the right to data portability, which means that you can request that we provide certain Personal Information about you in a machine-readable format.
- In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain Personal Information we process about you.
- The right to lodge a complaint with a regulator, including relevant supervisory authorities, located in the jurisdiction of your residence, place of work, or where an alleged violation of law occurred.
You have choices about how we communicate with you and how we process certain Personal Information about you. You may opt-out of receiving marketing or other communications from us at any time by unsubscribing using the link in the communication or by contacting us directly as provided at the end of this Notice. If you opt-out of receiving emails from us or otherwise modify the nature or frequency of marketing or promotional communications, it may take a short time for us to process your request and you may continue to receive marketing or promotional communications from us during that period. You will continue to receive administrative messages regarding our services, or transactions you have entered into with us, even after opting-out of such marketing or promotional communications.
You also have the right to opt out of cookie collection. Most web browsers automatically accept cookies, but you can usually modify this in your browser’s settings. This may prevent you from taking full advantage of our websites or applications. Note our websites do not take any action in response to “do not track” signals that may be transmitted by some web browsers. Third-party advertising networks are not permitted to collect information about our users. For more information about the cookies that we utilize, please review our Cookie Notice.
Changes to this Notice
We reserve the right to change the terms of this Notice at any time. If we do make changes, though, we will take steps to indicate that the Notice has been updated on our websites.
Non-Discrimination and Non-Retaliation
We respect your rights, and we will never discriminate or retaliate against you or the business with which you are associated as a result of you exercising any right outlined in this Notice or afforded to you under applicable law.
Other Important Information about Our Services
Collection of Personal Information from Minors: Our products and services are not directed to children, nor do we knowingly collect Personal Information from minors under the age of 18. If you are a parent or guardian of a child under the age of 18 and believe he or she has disclosed Personal Information to us and wish to access this Personal Information, please contact us. By using our services, you represent that you are 18 years of age or older.
Third-Party Websites and Services: As a convenience, we may, from time to time, reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business. When you access these third-party services, you leave our websites, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. This Notice does not apply to any third-party services; please refer to the privacy notices or policies for such third parties for information about how they collect, use, and process your Personal Information.
How to Contact Us or Submit a Request
If you have any query or complaint about this Notice or our privacy practices, or if you wish to exercise any of your rights, you may contact us any time using the following contact information:
By mail:
Arlene, Inc.
249 Smith Street #129
Brooklyn, NY, 11231
By email:
sales@arlene.io
If you are located in the European Union or European Economic Area, and you wish to raise a concern regarding our privacy practices, you have the right to do so with your local supervisory authority or with our lead supervisory authority, the Garante per la Protezione dei Dati Personali (the Italian Data Protection Authority).
Likewise, if you are located in United Kingdom, and you wish to raise a concern regarding our privacy practices, you have the right to do so with the Information Commissioner’s Office.