Arrows Privacy Policy

Last updated: December 21st, 2023

Arrows Software Inc., 8605 Santa Monica Blvd, PMB 62069, West Hollywood, California 90069-4109 US (“Arrows”, “Company”, “we”,“us” or “our”) provides an onboarding software-as-a-service product and service to help businesses create a seamless customer onboarding experience. This Privacy Policy explains how Arrows collects, uses, discloses, and otherwise processes personal information in connection with our website(the “Site”) and other websites we own and operate that link to this PrivacyPolicy, and the related content, platform, services, products, and other functionality offered on or through our services (each a “Service” and collectively, the “Services”).

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.

I. Our Collection and Use of Personal Information

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.

Personal Information Collected from You When You Use the Site and Services

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.

Category of Personal Information	How we use the Personal Information	Legal Basis for Processing
Contact Information, including first and last name, personal email address, business email address, business postal address, employer, job title, your area of responsibility, company name, business phone number and your country or region. (personal email address, business email address, first name and last name are mandatory, all other ‘Contact Information’ is optional)	We use this information to operate, maintain, and provide to you the features and functionality of the Service.	The processing is necessary for our legitimate interests, namely to respond to comments and queries that you send to us via the Site.
	We use this information to handle your customer service requests, including: · directing your questions to the appropriate team members; and · investigating and addressing any concerns.	The processing is necessary for our legitimate interests, namely to respond to and appropriately investigate specific information requests made by you via the Site or via phone.
	We use this information to provide notifications and send news alerts to users that have signed up to receive our newsletter or other marketing emails, information about virtual webinars and in-person events, surveys and/or information about promotions.	If you are in the European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein) (“EEA”), United Kingdom (“UK”) or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so.
	We use this information to organize and manage virtual webinars and in-person events.	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so.
	Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the Service, including identifying and preventing unlawful, fraudulent, or malicious use of the Service.	The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Site, Arrows and users.
Account Information, (mandatory)	We use this information to authenticate you when using the Service and to allow you to log into your account on the Site.	The processing is necessary for our legitimate interests namely to provide the Service and respond to specific information requests regarding your account.
Inquiry and Communication Information, including information provided messages sent to Arrows, for example to one of our email addresses, or via phone. (optional)	We use this information to handle your customer service requests, including: · directing your questions to the appropriate team members; and · investigating and addressing any concerns.	The processing is necessary for our legitimate interests namely to respond to and appropriately investigate specific information requests made by you via the Site or via phone.
Your preferences, such as preferences set for notifications marketing communications and your user settings. (Arrows must give you option to set certain preferences by law and therefore the provision of some of this information is mandatory)	We use this information to provide notifications and send news alerts to users that have signed up to receive our newsletter or other marketing emails, information about virtual webinars and in-person events, surveys and/or information about promotions.	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so.
	We use this information to enable you to control how your profile information appears on the Site.	The processing is necessary for the performance of a contract with you.
Information Collected Through the Use of the Service, including any files, documents, videos, images, data, or information you choose to upload or transmit through your communications with us or your use of the Services (collectively, “User Content”). (optional)	We use this information to operate, maintain, and provide to you the features and functionality of the Service.	The processing is necessary for the performance of a contract with you.
	We use this information to handle your customer service requests, including: · directing your questions to the appropriate team members; and · investigating and addressing any concerns.	The processing is necessary for our legitimate interests namely to respond to and appropriately investigate specific information requests made by you via the Site or via phone.

Personal Information Automatically Collected

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.

Category of Personal Information	How we use the Personal Information	Legal Basis for Processing
Log files and information about your device. We collect information about the tablet, smartphone or other electronic device you use to connect to the Site. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Site through the device, your mobile network, your IP address and your device’s telephone number (if it has one). We use third-party analytics tools to collect this information.	We use information about how you use and connect to the Site to present the Site to you on your device.	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.
	We use this information to monitor and improve the Site.	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.
	Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the Service, including identifying and preventing unlawful, fraudulent, or malicious use of the Service.	The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Site, Arrows and users.
Information about how you access and use the Site. For example, how frequently you access the Site, the time you access the Site and how long you use it for, the approximate location that you access the Site from, the site from which you came and the site to which you are going when you leave the Site, the pages you visit, the links you click, and other actions you take on the Site. We use third-party analytics tools to collect this information.	We use information about how you use the Site to present the Site to you on your device.	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.
	We use this information to monitor and improve the Site and to resolve any issues.	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.
	Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the Service, including identifying and preventing unlawful, fraudulent, or malicious use of the Service.	The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Site, Arrows and users.
Location information, such as general geographic location that we or our third-party providers may derive from your IP address.	Where relevant and where permitted under applicable law, we use this information to identify potential risk or unlawful behavior including fraud detection, theft prevention, emergency response purposes and legal compliance.	The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Site, Arrows and users.
User Content (as defined in the 'Personal Information Collected from You When You Use the Site and Services' section above).	We use this information to operate, maintain, and provide to you the features and functionality of the Service.	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.
	We use this information to handle your customer service requests, including: directing your questions to the appropriate team members; and investigating and addressing any concerns.	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.
Analytics information.	We may collect analytics data or use third-party analytics tools to help us measure traffic and usage trends for the services and to understand more about the demographics of our users.	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner.

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For more information about how we collect personal information about you automatically, please refer to our Cookie Policy.

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.

Personal Information from Other Sources

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.

Sources and Category of Personal Information	How we use the Personal Information	Legal Basis for Processing
Your Employer / Company.	We use this information to operate, maintain, and provide to you the features and functionality of the Service.	The processing is necessary for our legitimate interests, namely to provide the Service and respond to comments and queries that you send to us via the Site.
Service Providers. Our service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal information and may share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your orders.	We use this information to operate, maintain, and provide to you the features and functionality of the Service.	The processing is necessary for our legitimate interests, namely to provide the Services.
	We use this information to process payments. Please note that we use a third-party payment processor, Stripe, to payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy policy. To view Stripe’s privacy policy, please click here.	The processing is necessary for our legitimate interests, namely to provide the Services.
	We use this information to provide notifications and send news alerts to users that have signed up to receive our newsletter or other marketing emails, information about virtual webinars and in-person events, surveys and/or information about promotions.	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so.
	Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the Service, including identifying and preventing unlawful, fraudulent, or malicious use of the Service.	The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Site, Arrows and users.
Information we receive from authentication services you connect to our Service. Some parts of our Service may allow you to login through a third-party service such as HubSpot, Google or Microsoft. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, or other information. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site.	We use this information to operate, maintain, and provide to you the features and functionality of the Service.	The processing is necessary for our legitimate interests, namely to provide the Arrows Services.
	We use this information to send you service-related and/or usage-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Site, technical and security notices).	If you are in the EEA, UK or Switzerland, we will only process your personal information in this way to the extent that you have given us your consent to do so.
	Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the Service, including identifying and preventing unlawful, fraudulent, or malicious use of the Service.	The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Site, Arrows and users.

Additional Uses of Personal Information

We may use personal information we collect to:

fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested and to process transactions, including providing you with a white paper you have requested or an online product demonstration;
manage Arrows and its day-to-day operations;
verify your identity and entitlement to products or Services, when you contact us or access our Services;
communicate with individuals, including via email, social media and/or Zoom calls;
for marketing and advertising purposes, including to market to you or offer you through email or social media, information and updates on products or services we think that you may be interested in(where applicable, we may send you marketing messages if you have given us your consent to do so or where we send you marketing messages about similar products or services if you have recently contracted with us and have not opted out of receiving such marketing messages);
administer, improve and personalize ourServices, including by recognizing an individual and remembering their information when they return to our Services;
process payment for our Services;
facilitate customer benefits and services, including customer support through our command center services;
identify and analyze how individuals use our Services;
conduct research and analytics on our customer and user base and our Services;
improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
test, enhance, update and monitor theServices, or diagnose or fix technology problems;
help maintain the safety, security and integrity of our property and Services, technology assets and business;
to enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
prevent, investigate or provide notice of fraud or unlawful or criminal activity;
comply with contractual and legal obligations and requirements;
to fulfill any other purpose for which you provide personal information; and
for any other lawful purpose, or other purpose that you consent to.

II. Our Disclosure of Personal Information

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.

Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership. These recipients will use your personal information to assess the potential transaction with us and otherwise only as disclosed in this Privacy Policy. The lawful basis we rely on for transferring this personal information is that the processing is necessary for ours and the third party’s legitimate interests, namely assessing and executing a potential transaction with us.

Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:

in connection with the establishment, exercise, or defense of legal claims;
to comply with laws or to respond to lawful requests and legal process;
to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
to detect, suppress, or prevent fraud;
to protect the health and safety of us and others; or
as otherwise required by applicable law.

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.

III. Control Over Your Information

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 help@arrows.to. We may not be able to modify or delete your information in all circumstances.

IV. Data Retention

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.

V. Children's Personal Information

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.

VI. Links to Third-Party Websites or Services

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective Privacy Policies.

VII. Updates to this Privacy Policy

We may update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

VIII. Contact Us

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please send an email to help@arrows.to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Policy. In that case, the additional Privacy Policy will govern how we may process the information provided at that time.

IX. Region-Specific Disclosures

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.

Additional European Economic Area, United Kingdom and Switzerland Privacy Disclosure

These Privacy Disclosures set out additional information for individuals accessing our Service from the European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein) (“EEA”), United Kingdom (“UK”), and Switzerland. Please ensure that you have read and understood these additional privacy disclosures alongside our Privacy Policy and Terms of Service before you access or use the Service.

‍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.

	EEA Legal Representative	UK Legal Representative
Company	Instant EU GDPR Representative Ltd.	GDPR Local Ltd
Name	Adam Brogden	Adam Brogden
Email address	contact@gdprlocal.com	contact@gdprlocal.com
Telephone number	+353 01 554 9700	+44 1772 217800
Postal Address	Instant EU GDPR Representative Ltd. Office 2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland	GDPR Local Ltd 1st Floor Front Suite 27-29 North Street Brighton BN1 1EB England

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Please contact our EU or UK representative if you have any queries in relation to your rights, these Privacy Disclosures and our Privacy Policy, or general privacy matters. Please ensure you reference our entity name, Arrows, in any correspondence you send our representative.

International Transfers of Your Personal Information.

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:

Country

Appropriate safeguard

USA

For Swiss and EEA individuals: either:

the Standard Contractual Clauses annexed to Commission Implementing Decision (EU) 2021/914; or
the recipient is certified to the EU-U.S. Data Privacy Framework (“DPF”) set forth by the U.S. Department of Commerce and approved by the European Commission.

For UK individuals: either:

agreements that incorporate terms approved under s119A of the Data Protection Act 2018 for transfers of personal data to recipients in third countries; or
the recipient is certified to the UK Extension to the DPF as set forth by the U.S. Department of Commerce and as is approved by the European Commission (for the DPF) and the UK Secretary of State (for the UK Extension to the DPF).

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We will take appropriate technical and organisational measures to ensure that your personal data is protected and secured in accordance with applicable law and this privacy policy regardless of where it is processed.

Your Privacy Rights

You have the following rights in relation to your personal information (subject to certain limitations);

Access	You have the right to obtain: confirmation of whether, and where, we are processing your personal data; information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods; information about the categories of recipients with whom we may share your personal data; and a copy of the personal data we hold about you.
Rectification	You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
Restriction of Processing	You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
Erasure	You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
Portability	You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
Objection to Processing	You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
Right to Withdraw Consent	Where we rely on your consent for processing of your personal information, you also have the right to withdraw your consent to such processing, subject to certain limitations at law. Withdrawing consent shall not affect the lawfulness of processing carried out on the basis of that consent before it was withdrawn.
Right to Lodge a Complaint	You may also have the right to lodge a complaint to your local data protection authority. If you are based in the EEA, information about how to contact your local data protection authority is available here. If you are based in the UK, information about how to contact your data protection authority is available here. If you are based in Switzerland, information about how to contact your data protection authority is available here.

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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.

To exercise any of your privacy rights, please contact us as set out in the Contact Us section of the Privacy Policy. We may need to verify your identity before processing your request, which may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the rights described above if we are unable to identify you.