1. Introduction

Arc10 Technologies Inc., (referred to as “Arc10” “we” or “us”) respects all individuals’ preferences concerning the collection and use of their personal information (“data”). This policy statement is here to let you know how we collect data, why we collect it, and what choices you have concerning its use.  
Please note that Arc10 maintains the same privacy practices described in this policy for data we collect offline; accordingly, references below to online subscribers also apply to individuals from whom we collect data offline (for example, on mailing list sign-up forms circulated at conferences or local meetup events or through research for organizations who share our interests).  
Arc10’s office is located at: 65 Forest Manor Road, Toronto, Ontario M2J 1M5 Canada.  

2. Data Collection, Usage and Storage

2.1 Data Collection Methods

Arc10 collects data related to users of this website and individuals that have contracted with us regarding our services (“Customers”), through the following methods:  

  • The registration form for our online opt-in mailing through our main site, online job application form, a landing page, or contest entry page, that we host. We may also have distinct media, contests and other event-specific sign-up forms.
  • Through the provisioning of our services which you have contracted with us.
  • Website analytics tools, including cookies.
  • Sign-up sheets which are circulated at events.

2.2 Types of Information Collected and the Legal Basis for its Collection

The data collected may include the following information for the purpose of providing services to, and communicating with, Customers, subscribers and job applicants:  

  • Subscribers’ and job applicants’ contact information (name, address, company, title, phone, fax, email, website, social media handles). The legal basis for the collection and processing of this information is your express consent and also to provide services to you such as to contact you regarding your account or application.
  • A selection of your interests for future communications which is generally collected through online forms or forms we provide you at industry events and conferences. The legal basis for collection and processing of this information is your express consent and our legitimate interests, which in this case are to enable us to properly administer our website and our business and to improve customer service.
  • Subscribers’ or job applicants’ work title, company, and industry they work in. The legal basis for collection and processing of this information is your express consent and to provide services to you such as processing your account or application.
  • The subscribers’ or job applicants’ technical data such as cookies, user’s IP address and geographic location. The legal basis for the collection and processing of this information is our legitimate interests, which in this case are to enable us to properly administer our website and our business and to improve customer service.
  • With respect to services we provide to you through a written contract, we generally collect business contact information such as name, title, business address, business email and business phone number. The legal basis for this collection and processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

2.3 How we use the Data we Collect

Arc10 collects data from users for the following purposes:  

  • Providing Customers and users with Arc10 services including administration and account management, as well as access to Arc10 website(s).
  • Notifying users of information relevant to a particular webinar, blog post, or campaign is the primary purpose of our network.
  • Sending segmented e-newsletters to different lists for users interested in a particular offering from Arc10. This is another purpose of our sign-up forms.
  • Answering user inquiries. We will use subscribers’ contact information to facilitate our handling of their registrations for newsletters and specific requests for further information.
  • Processing job applications and communicating with job applicants. We may use the contact information collected to inform applicants of their application status and with respect to communication to other engagement opportunities with Arc10.
  • Providing information on related resources. We may provide users with information on educational events, training, or relevant online content.
  • Cookies on the site, and the associated data will be used only for the purposes stated above.
  • We currently do not use automated decision making on personal information for our websites or applications.

2.4 How long we keep your Personal Information

We will hold all the data only for a period that is required for the purposes of the consent for which it was collected and will be no longer than as required by applicable privacy laws.
If you have any questions or concerns, you may reach out to our Privacy Officer through one of the methods set out in Section 14 (Questions and Contact Information).

3. Consent

When you provide us with personal information to sign-up for our e-newsletter list, or to enter your personal information to sign-up for one of our contests at an event, or when you enter your personal information to apply for a job, you are providing consent for us to collect such personal information and using it for that specific reason only. 
If we ask for your personal information for a secondary reason, we will either ask you directly for your expressed consent or provide you with an opportunity to say no. 
Users who opt in via a website’s mailing list sign-up form will immediately be able to view a ‘Thank You’ page or inline ‘Thank You’ text, which indicates that their submission has been received. 
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by clicking the unsubscribe link at the bottom of our emails, or contacting our Privacy Officer through one of the methods set out in Section 14 (Questions and Contact Information).

4. Disclosure

We may disclose your personal information only if consent is given by the relevant individual or:  

  • (a) when permitted or required by law, such as in response to a subpoena or other legal process;
  • (b) to a transferee of all or part of Arc10;
  • (c) to Arc10’s third party service providers in accordance with this Policy; or
  • (d) to meet legal obligations, including but not limited to regulatory reporting obligations.

6. Third-Party Links

Arc10 and our portal websites includes links to non-Arc10 sites we believe may be of interest to our visitors. These links are provided as a convenience, and the sites they point to are beyond our control. You are advised to check the privacy policies and terms of use of those sites before providing any personal information to them.

7. Cookies

A “cookie” is a small piece of information sent by a web server to store on a web browser so it can later be read back from that browser.  
We may set cookies for the following purposes:  

  • To facilitate login or other site navigation procedures.
  • To improve the functionality of the website by avoiding duplicate data entry, facilitating navigation, and increasing the relevance of content.
  • To store user preferences and profile information used to personalize the content that is shown.

You can view the cookie statement here so that you can choose if you want to opt-in or opt-out of cookies.

7.1 Control Over Cookies

Upon arriving on our website, you will be presented with a banner that will give you the option to accept our website’s cookies. Unless you click “accept” on such banner, we will not use cookies to track your activities. 
Web browsers also provide you with information and control over cookies. You can set your web browser to alert you when a cookie is being used. You can also get information on the duration of the cookie and what server your data is being returned to. You then have the opportunity to accept or reject the cookie. Additionally, you can set your browser to refuse all cookies or accept only cookies returned to the originating servers. Users can generally disable the cookie feature on their browser without affecting their ability to use the site, except in some cases where cookies are used as an essential security feature necessary for transaction completion.

8. Preferences and Unsubscribing

All emails sent by Arc10 to our mailing lists will include a single-click “Unsubscribe” link, which will unsubscribe you from all communications. Emails will also have a single-click link to your email preferences for your account which will direct you to a web page where you may update your email preferences. 
Please contact us at privacy@arc10.io if you believe you have mistakenly received information after unsubscribing or if you would like to unsubscribe and have been unable to use the unsubscribe mechanisms provided.

9. Information Sharing

Personal information submitted to Arc10, including through the website or a prescribed form is kept strictly confidential and will not be sold or rented to outside organizations unless in accordance with your consent. 
Arc10 uses third party service providers with respect to its website and services. To the extent that any personal information is provided to these third parties, Arc10 requires that the providers be bound by obligations consistent with this Policy and that such providers only collect, use or disclose the personal information of Arc10 users for the purposes of providing Arc10 services. 
For more information, please contact our Privacy Officer through one of the methods set out in Section 14 (Questions and Contact Information).

10. Security

Arc10 is concerned with the security of the personal information we have collected and has in place reasonable measures to prevent unauthorized access to that information. These measures include policies, procedures, and technical elements relating to data access controls. In addition, Arc10 uses standard online security protocols and mechanisms to exchange the transmission of sensitive data such as personal information, as well as requiring all staff and contractors to sign confidentiality and non-disclosure agreements if they will be in contact or have access to data. 
It is important to remember that no method of transmitting or storing data is completely secure. Mail, voice communications, faxes and data transmissions over the Internet are all susceptible to possible loss, misrouting, interception and misuse of the information being communicated or transmitted. 
For further information, please contact our Security Officer through one of the methods set out in Section 14 (Questions and Contact Information).

10.1 Data Transfer

Our servers are located in North America and data processing occurs primarily in Toronto, Ontario, Canada. Backup servers, in case of data outages, may be located outside North America. 
Arc10 and its affiliates, and other third parties to whom we disclose personal information under this Privacy Policy, may perform activities such as data retention outside of Canada. As a result, your personal information may be securely used, stored or accessed in other countries and may be subject to the laws of those countries. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries. 
With respect to users in the European Economic Area (EEA), we do our best to ensure a similar degree of security of personal information as the EEA by ensuring at least one of the following safeguards is in place: 

  • We will only transfer personal data to countries that the European Commission have approved as providing an adequate level of protection for personal information; or
  • Where we use certain service providers, we may use specific contracts, codes of conduct, or certification mechanisms approved by the European Commission which give personal information the same protection it has in Europe; or
  • For US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

10.2 Security Breach Policy

In the event that individual personal information is acquired or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, Arc10 will notify the applicable regulatory authority and the affected individual of the breach. Affected individuals will be contacted by email or, if Arc10 is unable to contact the individual by email, then by mail. Notice will be given promptly, consistent with the legitimate needs of law enforcement and any measures necessary for Arc10 or law enforcement to determine the scope of the breach and to assure or restore the integrity of the data system. Arc10 may delay notification if Arc10 or a law enforcement agency determines that the notification will impede a criminal investigation, unless and until Arc10 or the agency determines that the notification will not compromise the investigation.  
For further information, please contact our Security Officer through one of the methods set out in Section 14 (Questions and Contact Information).

11. Right to Be Forgotten/Deletion Request Right

If at any time you wish to remove your account or permanently erase your historical data stored by us, you may do so by submitting a Data Subject Access Request at privacy@arc10.io. We will remove all data that we are not required to maintain for taxation, audit, and/or legal reasons. If you have any questions about this process, please contact us through one of the methods set out in Section 14 (Questions and Contact Information).

12. Legal Rights of Users and Compliance Issues

12.1 Legal Rights of Users

Under some personal information laws, you may have specific rights in relation to personal information that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. 
Some of these options may be exercised directly as outlined in the “Opt-Out or Withdrawal” section.  Alternatively, and to exercise any of the other rights set out above, please email our Privacy Officer (see Section 14 “Questions and Contact Information” section below). 
If you are not happy with any aspect of how we collect and use your personal information, you also have the right to complain to the applicable privacy commission such as the Office of the Privacy Commissioner of Canada, Information Commissioner’s Office (ICO), the UK Supervisory Authority for data protection issues, the European Data Protection Supervisor, or the State of California Department of Justice, as appropriate. Please contact us first if you do have a complaint so that we can try to resolve it for you.

12.2 General Data Protection Regulation (GDPR)

The GDPR is a new European data protection law that became effective on May 25th, 2018. It sets out various requirements for data protection and applies to virtually all organizations that process personal data of EU residents as a result of services offered to them, regardless of whether the organization physically resides in the EU. 
The GDPR distinguishes between organizations that are “data controllers” and those that are “data processors”. Under EU law, EU citizens have the right to: 

  • View, edit, and request deletion of any Personal Information that has been collected by Arc10 for any reason (some limitations do apply)
  • Have personal data transmitted to another controller in a commonly used machine-readable format (data portability)
  • Receive more information about Arc10 data processing through a “Request form”
  • Request Arc10 to provide detailed information about our personal data handling practices
  • Request Arc10 to stop using their personal data for direct marketing purposes

To request access to, correction, or deletion of Personal Information or withdrawal of consent to the processing described in this Privacy Policy, please contact our Privacy Officer through one of the methods set out in Section 14 (Questions and Contact Information).

12.3 California Consumer Privacy Act (CCPA)

The CCPA went into effect on January 1 2020. If you are a California resident, California law may provide you with additional rights regarding how we may use your personal information.This section describes your rights as a California resident and explains how to exercise those rights.

  • Access to Specific Information and Data Portability Rights

You have the right to request that Arc10 disclose information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your request, we will disclose to you:  

  • Categories of personal information we collected about you and the sources of such personal information as well as the categories of third parties with whom we share that personal information.  
  • Our purpose for collecting or selling that personal information and if we sold or disclosed your personal information for a business purpose.  
  • Deletion Request Rights  
      You have the right to request that Arc10 delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request, we will delete and/or direct our service providers to delete your personal information from our records, unless an exception applies.  
    To request access to, correction, or deletion of Personal Information or withdrawal of consent to the processing described in this Privacy Policy, please contact our Privacy Officer through one of the methods set out in Section 14 (Questions and Contact Information).

13. Changes to this Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. 
If Arc10 is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to provide our services to you.

14. Questions and Contact Information

Privacy Officer  
For privacy related inquiries such as requesting access to, correcting, amending or deleting any personal information we have about you, or to register a complaint with us please contact our Privacy Officer at: 
email: privacy@arc10.io        
mail: Attn – Privacy Officer Arc10.io Inc. 65 Forest Manor Road, Toronto, ON, M2J 1M5 Canada 
Security Officer  
For inquiries relating to a security breach, please contact our Security Officer at:  
email: security@arc10.io mail: Attn – Security Officer Arc10.io Inc. 65 Forest Manor Road, Toronto, Ontario M2J 1M5 Canada