Last updated: December 21st, 2023
Arrows is the controller of the personal information we hold about you in connection with your use of the Site and, in some instances, the Services. This means that we determine and are responsible for how your personal information is used.
We collect personal information in a variety of ways. For example, you may provide us your personal information when you register for an account, interact with us via our Site or email, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of our Service.
We may link or combine your activities and information collected from you on the Site with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.
The table below sets out in further detail the categories of personal information we collect about you and how we use that information when you use theService, as well as the legal basis which we rely on to process the personal information.
We indicate below if the provision of certain personal information is mandatory or optional. If you choose not to provide personal information marked as mandatory, we may not be able to provide those aspects of the Service to you, or to respond to your queries and other requests.
We, and our third-party partners, automatically collect information you provide to us and information about how you access and use theServices when you visit our Site, use our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”)to automatically collect this personal information. We may also use this information to distinguish you from other users of our Service. This helps us monitor and analyze how you use and interact with our Services.
If you are in the EEA, UK or Switzerland: other than cookies and similar technologies that are required to operate the Site, we will only place cookies on your device or otherwise use these technologies to collect data from your device with your consent. You have the ability to opt out by disabling cookies in your browser or mobile settings. These settings will typically be found in the "options" or "preferences" menu of your browser.
We may link or combine the personal information we collect about you and the information we collect automatically. We may also anonymize and aggregate any of the personal information we collect (so that it is no longer linked to you and does not identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Service and for marketing campaigns (for example sharing industry trends and best practices based on the information we collect). We may also share such anonymized and aggregated information with others. For more information about these practices and your choices regarding cookies, please see our Cookie Notice.
The table below sets out in detail the categories of personal information we collect about you automatically and how we use that information.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
We also collect personal information about you from other sources, which we often combine with personal information we collect either automatically or directly from an individual.
The table below sets out in further detail the categories of personal information we collect about you from third parties and how we use that information when you use the Service, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.
We may use personal information we collect to:
We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to the following:
Service providers: We may disclose your personal information to service providers who perform services for us or on our behalf, such as providers of web hosting, marketing and analytics services. A full list of Arrows service providers can be found here. We may share the information set out in the ‘Personal Information Collected from You When You Use the Site and Services’, ‘Personal Information Automatically Collected’ and ‘Personal Information from Other Sources’ sections above. These service providers will process your personal information as processors and will only process your personal information on our instructions.
Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
These recipients will use your personal information in the performance of their regulatory or law enforcement role, or to advise us in connection with a potential claim or regulatory enforcement action. The lawful basis we rely on for sharing personal information with these recipients is that that the processing is either necessary to comply with a legal obligation to which we are a subject or is necessary for our legitimate interests, namely enforcing our rights or complying with requests from regulatory authorities. We may also share your personal information in this way where it is necessary for our legitimate interests, namely receiving professional legal, financial and accountancy advice.
With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.
You may control your information in the following ways:
Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the“unsubscribe” link provided in such communications. You may be able to opt-out of some service-related communications (e.g., recurring reminder emails and notifications such as task due reminders, weekly digest emails, data reports and comment notifications). Where this option is available, you may opt-out of such service-related communications by clicking on the “unsubscribe” link provided in such communications. You will not be able to opt-out of service-related communications that are necessary to use the Service, for example login verification emails, billing reminders, and other emails necessary to use the Service.
Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at firstname.lastname@example.org. We may not be able to modify or delete your information in all circumstances.
The criteria used to determine the period for which personal information about you will be retained varies depending on the legal basis under which we process the personal information:
Contract. Where we are processing personal information based on a contract, we generally will retain your personal information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from our contractual relationship.
Legitimate Interests. Where we are processing personal information based on our legitimate interests, we generally will retain such information for a reasonable period of time in order to fulfill the legitimate interests, taking into account your fundamental interests and your rights and freedoms.
Consent. Where we are processing personal information based on your consent, we generally will retain your personal information until you withdraw your consent, or otherwise for the period of time necessary to fulfill the underlying agreement with you or provide you with the applicable service for which we process that personal information.With regards to any erasure requests, your account will be removed from the Service and it may take up to one week for your data to be deleted.
Legal Obligation. Where we are processing personal information based on a legal obligation, we generally will retain your personal information for the period of time necessary to fulfill the legal obligation.
Legal Claim. We may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim or intent to establish a claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.
EEA, UK and Switzerland: if you are located in EEA, UK, or Switzerland, please see the Additional European Economic Area, United Kingdom, and Switzerland Privacy Disclosures section for additional European-specific privacy disclosures.
Personal Data: When we use the term “personal data” in these Privacy Disclosures, we mean information relating to an identified or identifiable natural person.
EEA and UK Legal Representative: we have appointed EEA and UK Representatives under Article 27 of the EU GDPR and UK GDPR respectively.
The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the EEA, UK or Switzerland your personal data may be processed outside of the country in which you reside. These international transfers of your personal data will be made pursuant to appropriate safeguards, including: (i) ensuring that the personal data is transferred to countries recognised as offering an equivalent level of protection; or (ii) ensuring that such transfer is to a third-party who uses appropriate safeguards in respect of the processing in question, including but not limited to the standard contractual clauses, which are recognised as offering adequate protection for the rights and freedoms of data subjects.
We may transfer your personal data to, or store your personal data in, the following countries:
You have the following rights in relation to your personal information (subject to certain limitations);
Please note that if the exercise of these rights limits our ability to process personal information, we may not be able to provide our products or services to you, or otherwise engage with you going forward.