LAST UPDATED: January 1, 2020
If you are a California resident, please see our Notice To California Residents to learn more about your rights under the California Consumer Privacy Act (the “CCPA”).
Information We Collect for Our Database
Information We Collect
ARSENAL develops and maintains a database (the “Database”) of company and individual profiles (“Profiles”).
Information collected for the development of an individual Profile and/or published in an individual Profile on the ARSENAL Service may include: name, title, company, current position, prior position, salary, publications, articles by, about, or quoting an individual, links to social media postings by or about the individual, professional contact information and similar information relating to the professional sphere of an individual.
Information collected for the development of a company Profile and/or published in a company Profile on ARSENAL may include: the name and title of the company’s officers and certain company employees, information obtained from the company or published by third parties.
Our Sources of Information
ARSENAL collects information about individuals and companies from a variety of publicly available and other sources, such as company websites, company blogs, non-confidential corporate records or reports (for example SEC filings, commercial registers), press releases, news articles, magazines, social media sites, and other content published by or on behalf of a company or published by data brokers or third parties in accordance with their terms and conditions for the collection, disclosure and sharing of information.
ARSENAL also collects information about individuals and companies from government publications in accordance with their terms and conditions for the disclosure and sharing of information.
Finally, ARSENAL may also receive some information directly from the individual or company whose Profile is featured in our Database. Subscribers who know facts about a particular individual or company may contribute some information to our Database about that individual (name, title, email, phone, social profile link (Facebook and Twitter)) or company (name, URL, address, phone, industry, revenue, employee count) if they desire. This information provided is only used for the sole purpose of completing your request or for whatever reason it may have been provided. ARSENAL confirms where possible accuracy of information provided as described above by individuals, companies, subscribers and other third parties before it is added to the Database and Profiles.
How We Use the Information We Collect
This information collected as described above is then compiled, edited and organized through ARSENAL’s unique proprietary sales and marketing intelligence application in order to create a Profile for each individual or company.
Each individual or company Profile is integrated into the Database, which is part of the ARSENAL Service. Subscribers of the ARSENAL Service have access to the Database and the Profiles and, as such, might conduct searches and save the identified Profiles meeting their search criteria for their own internal purposes. Subscribers might also contact individuals or companies using the contact information contained in Profiles. For example, an ARSENAL subscriber might use the Database in order to identify the specific individual who may be a decision maker in a company, and then contact the individual in order to offer goods or services for sale to the company.
Limited access to the Database is provided at no cost, whereas full access to the Database is subject to the payment of a subscription fee.
Information We Collect From Our Subscribers
Information Our Subscribers Provide About Themselves or Their Business
Our primary goal in collecting personal information from subscribers of the Foundation Service is to provide them with a smooth and efficient experience while communicating with us and using ARSENAL Foundation. This allows us to provide customized services and features that are most likely to meet subscribers’ needs and that make their experience easier and quicker.
When an individual expresses an interest in obtaining information about ARSENAL or registering to use the Service, ARSENAL requires the individual to provide us with contact information such as name, company name, address, phone number, and email address. ARSENAL may then use the contact information provided to reach the individual via email or phone.
When a subscriber purchases services, ARSENAL may require the subscriber to provide financial qualification and billing information, such as billing name and address, payment/credit card number, and the number of employees within the organization that will be using the Service. ARSENAL may also ask for additional information, such as company annual revenues, number of employees, or industry.
Payment Card Information
ARSENAL does not retain payment or credit card numbers. This information is passed on immediately to our payment card processing service, which is required to use this information only for the processing of each specific transaction.
Usage Data We Gather
We also receive and store certain types of information whenever an individual (subscriber or visitor) interacts with our Site. ARSENAL automatically receives and records information on its server logs from the individual’s browser including the individual’s IP address, browser type, date/time stamp, ARSENAL cookie information, the page(s) that the individual requested, internet service provider, operating system, clickstream data and the referring/exit pages. We may combine this automatically collected log information with other information We collect about you. We do this to improve services We offer you and site functionality.
Cookies and Other Tracking Technologies
Technologies such as cookies, beacons, tags and scripts or similar technologies are used by ARSENAL and our analytics/service providers. These technologies are used in analyzing trends, administering the Site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
If an individual corresponds with ARSENAL via email, or other method regarding his or her activities or postings on the Site, ARSENAL will treat that email or other correspondence as ordinary business correspondence and will retain it according to its standard corporate information retention policies.
Our Use and Disclosure of Subscriber Information
When subscribers provide us with personal information to include in a published individual Profile about the subscriber or any information to include in a published company Profile, the subscriber gives us permission to use and disclose that information for the purpose of providing the ARSENAL Service as described above.
ARSENAL uses IP addresses to help diagnose problems with our servers and to administer the Site. Generally, IP addresses tell us the location from which a person is connecting to us, what service provider the person is using, and which parts of the Site the User is visiting. We reserve the right to track IP addresses for the purposes of fraud prevention, and we reserve the right to release IP addresses to legal authorities.
To whom we may Disclose Information
Disclosure to Service Providers
ARSENAL may engage third parties to perform necessary business functions on its behalf, such as outside contractors or service providers (e.g. hosting company, consultants) for example, in connection with communications to users, payment processing and other aspects of Site operations. If it is necessary to perform their functions, these third parties may have access to Individual or company information or Profiles. These third parties are required not to use any information or Profile for any purpose other than to provide services to ARSENAL. They are also required to protect the information and Profiles with adequate reasonable security measures. Transfers to subsequent third parties are covered by the service agreements with our customers.
Transfer to Acquirer or Successor Entity
Some of our pages utilize framing techniques to serve content from our partners while preserving the look and feel of our Site. Please be aware that you are providing your personal information to these third parties and not to ARSENAL or ARSENAL.com.
ARSENAL contains links for subscribers to access other (third party) sites. ARSENAL is not responsible for the privacy practices or the content of such websites. We encourage subscribers to review the terms, conditions and policies of such third party websites.
Social Media Features
Opting Out, Accessing, Correcting, Updating, and Removing Information
Additions, Corrections – Profiles
Additions, Corrections – Individuals
ARSENAL has no direct relationship with the individuals whose personal data it processes on behalf of its customers. Individuals seeking to access, correct or delete their data should direct their query to the relevant ARSENAL customer (acting as data controller). ARSENAL will pass requests on to the relevant data controller within a reasonable timeframe.
Additions, Corrections – Subscribers
Subscribers may update or change their registration information (and their Profile) by editing their user or organization record. To update a user Profile, please click on “My Profile” within the Service or email us at support@ARSENAL.com if you require any assistance.
Opting Out – Individuals
An individual has the right to request that ARSENAL unpublish, remove, or make unavailable to third parties any information about him or her from the Databases or disconnect a link to another site. We will respond promptly in accordance with our internal policies on access to Profiles.
Please note ARSENAL often collects information based on its customers’ instructions and has no control over how they use your data. If you would like to opt out of communications from our customers that use the service, please contact those entities directly.
Opting Out – Subscribers
Subscribers may opt-out of receiving promotional communications by following the unsubscribe instructions included in such emails or by contacting us at unsubscribe@ARSENAL.com. Subscribers of our cost-free services agree to receive our promotional communications while continuing to use such services at no cost. Cost-free Service subscribers electing to unsubscribe from receiving our promotional communications may no longer be entitled to access the cost-free Service.
Individual subscribers designated as “administrators” may not opt out of receiving administrative notices that are not promotional in nature.
The authorized representative of a corporation or other business or entity (other than a natural person) (any, a “Company”) may obtain access to the Company’s Profile and be informed about the source of the information used to create that Profile.
If an authorized Company representative determines that the Profile of the Company is incomplete or factual information about the Company is incorrect, he/she may propose an addition or correction or deletion. We will accept and implement the proposed addition or correction or deletion upon receiving adequate proof of the authority of the individual to request a correction or deletion on behalf of the Company and proof of the authenticity and accuracy of the supplied information and given the supplied information meets our selection criteria and internal policies regarding information collected for the creation of Profiles.
ARSENAL uses industry standard security measures in an effort to protect against the loss, misuse, and unauthorized access, disclosure, alteration and destruction of the information under our control. We undertake measures designed to protect personal information once it is received by or available through the site, including but not limited to the following: limited and controlled access by employees, servers and data stored in a secured location, security software and hardware (such as firewalls, encryption, Secure Socket Layers) where appropriate and cost effective.
User passwords are used to secure access to the ARSENAL Service and subscriber information. We encrypt the transmission of user IDs and passwords using Secure Socket Layers (SSL).
As a subscriber, you may choose to have ARSENAL remember you on your computer; ARSENAL will automatically log you in by storing your user ID (but not your password) in a cookie in your browser. Our login page provides a service for subscribers to obtain a new password in case they forget their password.
When subscribers enter sensitive information (such as payment/credit card number) on Our registration or order forms, We encrypt that information using secure socket layer technology (SSL).
While We do our best to implement reasonable security measures, We do not guarantee that our safeguards will always work. ARSENAL will not be liable for unauthorized disclosure of Profile or other information that occurs through no fault of ARSENAL, including, but not limited to, error in transmission, misuse of a subscriber’s password and login credentials, a subscriber’s failure to comply with its security obligations, the unauthorized acts of ARSENAL’s employees or third parties. Transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. If you have any questions about security on our Site you can contact Us at privacy@ARSENAL.com.
Personal information held in the database may be transferred, stored, maintained, and processed in the United States or in other countries where we have facilities or where we have engaged a service provider. This storage, maintenance or processing will be performed under privacy and security laws and standards that may not be as protective as those in your jurisdiction. If you have any concern about the above, you can have your Profile removed or unpublished from our databases as explained above.
With respect to personal data received or transferred pursuant to the Privacy policies, ARSENAL is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, ARSENAL may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We will retain personal data we process on behalf of our customers for as long as needed to provide the Service, as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements.
If you have questions or concerns regarding this statement, you should first contact ARSENAL by sending email to firstname.lastname@example.org, or by mail to:
Special Terms Applying to Profiles
ARSENAL IS NOT RESPONSIBLE OR LIABLE TO ANY INDIVIDUAL OR COMPANY FOR THE ACCURACY, CONTENT, COMPLETENESS, LEGALITY, RELIABILITY, OR AVAILABILITY OF THE PROFILE INFORMATION OF THAT INDIVIDUAL OR COMPANY.
PROFILE INFORMATION IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT WARRANTIES OF ANY KIND WHATSOEVER, EXPRESS, IMPLIED, STATUTORY OR OTHERWISE, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW.
IN NO EVENT SHALL ARSENAL OR ITS LICENSORS HAVE ANY LIABILITY TO ANY INDIVIDUAL OR COMPANY FOR ANY DAMAGES OF ANY FORM HOWEVER CAUSED UNDER ANY OTHER THEORY OF LIABILITY, WITH RESPECT TO THE CONTENT, USE, AVAILABILITY, OR UNAVAILABILITY, OF THE PROFILE INFORMATION OF THAT INDIVIDUAL, OR FOR ANY OTHER REASON. THE FOREGOING DISCLAIMER SHALL NOT APPLY TO THE EXTENT PROHIBITED BY APPLICABLE LAW.
If you are accessing the Site from the European Economic Area, which includes the European Union, Iceland, Liechtenstein, and Norway, you have the following rights under the General Data Protection Regulation (GDPR).
a. Right to be informed about the collection and use of your personal data
b. Right to access your personal data
c. Right to have any inaccurate personal data corrected
d. Right to have your personal data erased
e. Right to restrict use of your personal data
f. Right to personal data portability
g. Right to object to the processing of your personal data
If you wish to exercise any of these rights under the GDPR, please email us at email@example.com or write to us at the address below with such request. We will respond to any requests without undue delay and no later than one-month after receipt of your request.
Opting-Out of Data Use or Withdrawing Consent
As described above, we collect personal data about you when you voluntarily provide it to us and collect other data about you and your use of the Site automatically when you interact with us. If you do not want us to use your collected data as described above, or if you wish to withdraw your consent to permit us to process your personal data, please email us at firstname.lastname@example.org or write us at the address below with such request.
If you no longer wish to receive communications from ARSENAL ADVISORS, you can opt-out from receiving such messages in the future by following the instructions in the message or contacting us at email@example.com.
You may remove certain tracking technologies and opt-out of online behavioral advertising messaging by using the opt-out tools available from the Digital Advertising Alliance http://youradchoices.ca/choices/ and the Network Advertising Initiative http://optout.networkadvertising.org/?c=1#!/ . Please note that these opt-out tools are device and browser specific, so you must repeat the opt-out from each of your browsers and devices.
You may also adjust your advertising preferences on various social media websites by adjusting your Settings on the platform (for example, you may adjust the types of Facebook ads you receive https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen .
ARSENAL is headquartered in the State of California. Its practices with respect to the handling of Profile or Personal Information are governed by the laws of the State of California, except for its conflicts of law principles, and will be subject to the sole and exclusive jurisdiction and venue of the courts seated in San Francisco, California, USA.
NOTICE TO CALIFORNIA RESIDENTS
Access, Deletion and Do Not Sell Right
As a Consumer under the CCPA, you have the following right subject to certain limitations described in the CCPA: (1) to request that we disclose to you what Personal Information we collect, use, disclose and sell, including the right to request that we provide you the specific Personal Information we have collected about you in the prior twelve (12) months (the “Right To Know”), and (2) to ask us to delete your Personal Information (the “Right to Delete”). You can also opt-out from our sale of your Personal Information (“Do Not Sell My Information”).
The following links are provided as an easy way for you to exercise these rights. Alternatively, you can contact us for more information or to make a request regarding your Personal Information. To ensure that we do not provide or delete your Personal Information in response to a fraudulent request, we will verify your identity prior to proceeding with your request. In the event we are unable to verify your identity, we will not be able to proceed with a Right to Know request, and will proceed with a “Do Not Sell My Information” request in response to a Right to Delete request.
ARSENAL ADVISORS, LLC
Attention: California Privacy Rights
9 Cornerstone Square
Westford, MA 01886
The data controller for the personal data that you provide or that is collected by ARSENAL ADVISORS is ARSENAL ADVISORS, LLC, 9 Cornerstone Square, Westford, MA 01886.
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