Privacy Policy

Owner and Data Controller

Arcazy, Inc.
Owner contact email: privacy@arcazy.com

Types of Data Collected

Among the types of Personal Data that Arcazy collects, by itself or through third parties, there are:

• Trackers and Usage Data
• Email address, username, and password credentials
• Device information, browser type, and operating system
• IP address and geographic location data
• Session statistics and interaction patterns
• Page views, clicks, and navigation paths
• Performance metrics and application telemetry

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Arcazy. Unless specified otherwise, all Data requested by Arcazy is mandatory and failure to provide this Data may make it impossible for Arcazy to provide its services.

Personal Data Processed for the Following Purposes

Authentication

Personal Data: email address, username, password credentials

Analytics

Google Analytics 4
Personal Data: number of Users, session statistics, Trackers, Usage Data

Remarketing and Behavioral Targeting

Facebook Remarketing
Personal Data: Trackers, Usage Data

Application Telemetry

Personal Data: device information, browser information, performance metrics, interaction events, session duration, page views

Mode and Place of Processing the Data

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Arcazy (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own.

Retention Time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users' consent.

The Purposes of Processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:

• User authentication and account security
• Analytics and performance monitoring
• Remarketing and behavioral targeting
• Application telemetry for performance improvement
• Pattern matching to create a better user experience
• Content personalization based on user preferences

Future Use of Data

We reserve the right to update this Privacy Policy and to use data collected for additional purposes not yet specified, which may include advertising platforms, personalized marketing, or other commercial purposes. The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top.

Should the changes affect processing activities performed on the basis of the User's consent, the Owner shall collect new consent from the User, where required.

Detailed Information on the Processing of Personal Data

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics 4
Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Google utilizes the Data collected to track and examine the use of Arcazy, to prepare reports on its activities and share them with other Google services.
Personal Data processed: number of Users, session statistics, Trackers, Usage Data.

Remarketing and Behavioral Targeting

This type of service allows Arcazy and its partners to inform, optimize and serve advertising based on past use of Arcazy by the User.

Facebook Remarketing
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of Arcazy with the Facebook advertising network.
Personal Data processed: Trackers, Usage Data.

Information on Opting Out of Interest-Based Advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy or by visiting:

• Network Advertising Initiative opt-out page
• Digital Advertising Alliance opt-out page
• Your Online Choices (EU)

This section applies to all Users in the European Union, according to the General Data Protection Regulation (the "GDPR"), and for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Legal Basis of Processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes.
• Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
• Processing is necessary for compliance with a legal obligation to which the Owner is subject.
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner.
• Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

The Rights of Users Based on the GDPR

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

How to Exercise These Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law.

This section applies to Users in Switzerland, and for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

The Rights of Users According to the Swiss Federal Act on Data Protection

Users may exercise certain rights regarding their Data within the limits of law, including:

• Right of access to Personal Data
• Right to object to the processing of their Personal Data (including the right to demand that processing be restricted, Personal Data be deleted or destroyed, or specific disclosures to third parties be prohibited)
• Right to receive their Personal Data and have it transferred to another controller (data portability)
• Right to ask for incorrect Personal Data to be corrected

How to Exercise These Rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.

This section applies to all Users in Brazil, according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

The Grounds on Which We Process Your Personal Information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

• Your consent to the relevant processing activities
• Compliance with a legal or regulatory obligation that lies with us
• The carrying out of public policies provided in laws or regulations
• Studies conducted by research entities, preferably on anonymized personal information
• The carrying out of a contract and its preliminary procedures
• The exercising of our rights in judicial, administrative or arbitration procedures
• Protection or physical safety of yourself or a third party
• Our legitimate interests, provided that your fundamental rights and liberties do not prevail
• Credit protection

Your Brazilian Privacy Rights

You have the right to:

• Obtain confirmation of the existence of processing activities on your personal information
• Access to your personal information
• Have incomplete, inaccurate or outdated personal information rectified
• Obtain the anonymization, blocking or elimination of unnecessary or excessive personal information
• Obtain information on the possibility to provide or deny your consent and the consequences thereof
• Obtain information about the third parties with whom we share your personal information
• Obtain, upon your express request, the portability of your personal information to another service or product provider
• Obtain the deletion of your personal information being processed if the processing was based upon your consent
• Revoke your consent at any time
• Lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority)
• Request the review of decisions made solely on the basis of automated processing of your personal information

How to File Your Request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document.

This section applies to all Users who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

Categories of Personal Information Collected

• Internet or other electronic network activity information: browsing history, search history, interaction with websites and applications
• Identifiers: email address, username, IP address, device identifiers
• Geolocation data: approximate location derived from IP address
• Inferences: drawn from other personal information to create a profile

Your Privacy Rights Under US State Laws

You may exercise certain rights regarding your Personal Information, including:

• The right to access Personal Information: You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information.
• The right to correct inaccurate Personal Information: You have the right to request that we correct any inaccurate Personal Information we maintain about you.
• The right to request the deletion of your Personal Information: You have the right to request that we delete any of your Personal Information.
• The right to obtain a copy of your Personal Information: We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
• The right to opt out from the Sale of your Personal Information.
• The right to non-discrimination: We will not discriminate against you for exercising your privacy rights.

Additional Rights for Users Residing in California

In addition to the rights listed above, as a User residing in California, you have:

• The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising
• The right to request to limit our use or disclosure of your Sensitive Personal Information

Additional Rights for Users Residing in Other States

As a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have:

• The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you
• The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information

How to Exercise Your Privacy Rights Under US State Laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document. For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity.

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Legal Action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Arcazy or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

System Logs and Maintenance

For operation and maintenance purposes, Arcazy and any third-party services may collect files that record interaction with Arcazy (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Changes to This Privacy Policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Arcazy and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top.

Contact Us

If you have questions about this Privacy Policy or wish to exercise any of your rights, please contact us at:

Arcazy, Inc.
Email: privacy@arcazy.com