Privacy Policy

This privacy notice for ARCASACRA LLP (doing business as Arcasacra) (“Arcasacra,” “we,” “us,” or “our”), describes how and why we collect, store, use (referred as “process”) and share your information when you use our services (“Services”), such as when you:

• Visit our websites at www.arcasacra.com, www.ethicarts.com and comunidad.ethicarts.com (collectively, the “Site”), or any website of ours that links to this Privacy Policy.
• Download and use our application(s), such as our mobile application, or any other application of ours that links to this Privacy Policy.
• Engage with us in other related ways – including any sales, marketing or events.

The most important part in ARCASACRA is our Comunidad (“Community”, “you”, “You”, “Member”, “Members”). Your privacy is extremely important to us and as important as it should be for you. To better protect it, we provide this Privacy Policy explaining our online information practices and the choices you can make about the way your information is collected and used.

We believe in a free, non-data-selling Internet and we will never trade your personal information with any third-party company (unless you decide so) or share it without your knowledge. We will protect your data, your right to own it and your access to it at any time, and we will only use it to provide you with the best Services we can offer (as referred in our Terms of Service)

Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. Whether you still have any questions or concerns, or just want to address any error or something that you think could be clarified for you and/or others, please contact us at hola@arcasacra.com. 

We rule our Privacy Policy according to he Data Protection Act 2018 (DPA 2018), the UK General Data Protection Regulation (UK GDPR) and the European GDPR law that was put in effect on May 25, 2018. They are some of the most respectful laws regarding your Privacy Rights.

We reserve the right to make changes to this Privacy Policy at any time and for any reason we consider beneficial to you (in fact, we must review it regularly by GDPR law). We will notify you about any changes via email and by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site.

You are encouraged to periodically review this Privacy Policy to stay informed of any updates. You will be deemed to have made aware of, will be subject to and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

Scope of this Privacy Policy

This Privacy Policy governs all the information we process. There is information about how our partners collect data from you through our Site in here. We need to use third party services such as Sharetribe and Siteground, and we encourage you to read their own Terms of Use and Privacy Policies.

This Privacy Policy is also incorporated into and governed by our Terms of Service and its Disclaimer. As well, we recommend you to take a look at our Cookie Policy and any other legal document we provide to you. They explain your rights and obligations as well as ours.

Our commitments to employees are governed by our internal Employment Policies.

In all instances we are committed to transparency with our customers and employees and to protecting your data privacy.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy policy, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.

• What personal information does Arcasacra process? When you visit, use, or navigate our Services, we process personal information depending on how you interact with Arcasacra and our Services, the choices you make and the products and features you use. Click here to learn more.
• Does Arcasacra process any sensitive personal information? We do not process sensitive personal information.
• Does Arcasacra receive any information from third parties? We do not receive any information from third parties.
• How Arcasacra process my information? We process your information to provide, improve, and administer our Services, to communicate with you, for security and fraud prevention, and to comply with law. We will never use your data for any other purpose without your previous acceptance. We process your information only when we have a valid legal reason to do so. Click here to learn more.
• In what situations and with which parties does Arcasacra share personal information? We share information in specific situations and with specific third parties. Click here to learn more.
• How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the Internet or any information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Click here to learn more.
• What are my rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. However, we gobernate ourselves in general by EU privacy laws, which are one of the most privacy protection-oriented on the planet. Click here to learn more.
• How do I exercise my rights? The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS 

1. INFORMATION WE COLLECT

2. HOW WE PROCESS YOUR INFORMATION

3. WHAT LEGAL BASES WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION

4. WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

5. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

6. HOW WE HANDLE YOUR SOCIAL LOGINS

7. IS MY INFORMATION TRANSFERRED INTERNATIONALLY?

8. HOW LONG WE KEEP YOUR INFORMATION FOR

9. HOW WE KEEP YOUR INFORMATION SAFE

10. YOUR PRIVACY RIGHTS

11. CONTROLS FOR DO-NOT-TRACK FEATURES

12. CALIFORNIA RESIDENTS’ SPECIFIC PRIVACY RIGHTS

13. UPDATES TO THIS POLICY

14. HOW TO COMPLAIN AND TO CONTACT US ABOUT THIS POLICY

15. HOW TO REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU

1. INFORMATION WE COLLECT

Personal information you disclose to us.

In Short: We only collect the personal information that you provide to us and the usual automatically collected (usually anonymous)

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.Personal Information Provided by You.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following: 

• names
• phone numbers
• email addresses
• mailing addresses
• job titles
• usernames
• passwords
• contact preferences
• contact or authentication data billing addresses
• debit/credit card numbers certificates
• country
• date of birth (“DOB”)
• skills
• education
• languages
• portfolio
• location

Sensitive Information. We do not process sensitive information.Derivative Data. Derivative Data refers to non-personally identifiable information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site. This information usually also includes your device name and type, your operating system, your country, your likes and replies to a post, and other interactions with the application and other users via server log files, as well as any other information you choose to provide. We only collect this data for the normal function of our services and we will never sell it or give to any other party without your consent. However, we use third party services through associate companies like Sharetribe, SiteGround so we encourage you to read their terms and conditions as stablished in our Disclaimer.Payment Data. We collect data necessary to process your payment if you make purchases, order, return or exchange your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. We store only very limited, if any, financial information that we collect. Otherwise, all payment data is stored by Stripe and Paypal, (click the names to see their Privacy Policies and contact them directly for responses to your questions).Social Media Login Data. Since we do not agree with the Privacy Policies of the main social media networks, we do not offer the possibility of signing up through them. This could change in the future if we find any social network really committed to the privacy of its users as long as the platform we use has that functionality. This will be always explained in detail in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.Application Data. If you decide to use our application(s) once we release it/them, we will also may collect the following information if you choose to provide us with access or permission to:

• Geolocation Information. We will request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We will request access or permission to certain features from your mobile device for using our future app that may include your mobile device’s calendar, camera, reminders, storage, and other features. If you would wish to change our access or permissions, you will be able to do so in your device’s settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you were using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications. We do not request to send you push notifications regarding your account or certain features of the application(s) at the moment. If you wish to opt out from receiving these types of communications, you will be able to turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes. 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. 

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services. 

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. 

In order to improve our Services, we also collect information through cookies and similar technologies. The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed on our web, searches through our site(s), and other actions you take such as which features you use), device event information (such as system activity), error reports (sometimes called “crash dumps”), and hardware settings. This is only for our internal use and we will never use it with any other purpose or sell to third parties 
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information. This is done automatically but we will not use it for any purpose.
• Location Data. We collect location data such as information about your location, which can be either precise or imprecise if you want to service locally to your collectors. How much information we collect depends on the type and settings of the device you use to access the Services. For example, when using the future app we will use GPS and other technologies to collect geolocation data that will tell us your current location (based on your IP address). You will always be able to opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you would choose to opt out, you will not be able to use certain aspects of the Services based in geolocation.

2. HOW WE PROCESS YOUR INFORMATION

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. If we process your information for other purposes this will be always with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We must process your information so you can create and log in to your account, as well as keep your account in working order. Your user account is what diference yourself inside our Comunidad.
• To deliver and facilitate delivery of services to the members. We may process your information to provide you with the requested service. Whatever is your role in the Comunidad (Collector, Creator, Forum admin, etc) you need an account to differniciate from the other members.
• To respond to user members inquiries / offer support to users members. We must process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We process your information to send you details about our products and services (do not worry, we will not spam you), to communicate you any changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We will process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We have to process your information if you choose to use any of the available methods that allow for communication with another user. You have to have an unique name user ID, and have access to your internet connection in order to provide you those services.
• To request feedback. We process your information when necessary to request feedback and to contact you about the use of our Services. Giving feedback to us we can improve Services and create a better and more efficient Comunidad based on your demands and needs. However, this is voluntary and we intend to compensate your time and effort helping us.
• To send you marketing and promotional communications. We process the personal information you send to us for  marketing purposes in accordance with your marketing preferences. We will not spam you, or offer you products or services you have not requested. However, you can opt out of our marketing emails at any time. For more information, see WHAT ARE YOUR PRIVACY RIGHTS?below.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. This has to be done to ensure a safe and controlled environment where you can freely trade, buy and participate in our Comunidad. We commit to keep your data safe at all times.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used in order to improve them, for example how you create your profile or listings and how we can improve to make your experience easier and more productive.
• To determine the effectiveness of our marketing and promotional campaigns. We process your information to better understand how to provide internal marketing and promotional campaigns about the services and products that are most relevant to you. We will not share any data to third parties without your previous agreement, and in case this happens, those third parties would be from ethic companies similar to us.
• To save or protect an individual’s vital interest. We will process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm. This is a peaceful Comunidad and we will not tolerate any harassment, discrimination, menospreciation and, of course, we reserve the right to cancel the account to any member who do not contribute to the peaceful and right development of the Comunidad.
• To mediate and resolve disputes. We need your data regarding to any disputes about agreed dates of a transaction, its price and conditions, the communication between parts, unsatisfactory inspections or delays or cancellations due to force majeure or to carry out a refund. In essence, we need the details of the transaction in order to act according and provide the best solution to any dispute.

3. WHAT LEGAL BASES WE RELY ON TO PROCESS YOUR INFORMATION

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose as detailed in this Privacy Policy, our Terms Of Service and other legal document we create for you; and to provide you with the best experience as part of our Comunidad. You can withdraw your consent at any time. Click here to learn more. 
• Performance of a Contract. We process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you. Our main commitment is You and You deserve the best Service possible. This commitment to You is the most important part of our contract.
• Legitimate Interests. We process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we will process your personal information for some of the purposes described in order to:
  • Send users information about special offers and discounts on our products and services. Do not worry, we will not spam you and you will be always able to cancel the newsletter and choose what kind of information you would like to receive.
  • Analyze how our services are used so we can improve them to engage and retain Members. This analysis will be always anonymous and it will have not negative impact in how you participate in the Comunidad.
  • Support our marketing activities. Always with your help, we will try to offer you the best Service possible and for this, we will have to use your data. We will not spam you and you will always be able to deny or cancel your subscription to those marketing activities.
  • Diagnose problems and/or prevent fraudulent activities. If we receive an alert from a Member from the Comunidad, we will open a ticket trying to solve this and prevent any form of fraud or ilegal activity on our Site. We will not tolerate any form of fraud or illegal activity against other member of the Comunidad or under our name.
  • Understand how our Members use our products and services so we can improve user experience. Our compromise with you is to provide you always with the best service possible from our side and we need to analyse how you interact with us.
• Legal Obligations. We must process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in any litigation in which we might be involved. We will only do that when the situation is required and as last resort to a legal action, always looking for the benefit of the Comunidad and keeping your privacy as safe as possible.
• Vital Interests. We may process your information where we believe is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. As stablished before in this Privacy Policy, we will not tolerate any action that endanger our members and our Comunidad.

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy policy, since we determine the means and/or purposes of the data processing we perform. This Privacy Policy does not apply to the personal information we process as a “data processor” on behalf of our customers. However, this case does not apply currently within our services as we do not sell any information about you. If this would change in the future, it would be always with your knowledge and consent. In that case, the third party company that we provide services to and with whom we will have entered into a data processing agreement would be the “data controller” responsible for your personal information, and we would merely process your information on their behalf in accordance with your instructions. If you would like to know more about our third party companies’ privacy practices, you should read their privacy policies and direct any questions you have to them.

If you are located in Canada, this section applies to you.

We process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to learn more.

In some exceptional cases, we can be legally permitted under applicable laws to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way. We will do that as the last resort possible as your privacy rights are as important to us as they are to you.
• For investigations and fraud detection and prevention. If we detect any possible fraud we will start the right actions to prevent this.
• For business transactions provided certain conditions are met. A transaction is a legal bonding and it will be treated as such.
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
• For identifying injured, ill, or deceased persons and communicating with next of kin. Under these sad circumstances we will always try to honour our Members and their express will.
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse. One of our commitments with our Comunidad is to provide a fair marketplace for both sides and we will not tolerate any abuse regarding this matter.
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records. We will always try to protect your privacy but if the law required to do so, we will collaborate for the right law compliment always with your knowledge.
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced. You give your consent for the development of your professional activities and we will try to provide you with the right tools for that.
• If the collection is solely for journalistic, artistic, or literary purposes. However, we will not allow to publish any information about you or your private data without your knowledge.
• If the information is publicly available and is specified by the regulations. Any listing, comment or review are publicly accessible to anybody on the internet, so we encourage you all the time to not post or publish anything that can be considered sensible for you.

4. WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

In Short: We only share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. Until we manage to emancipate from the major corporations and other companies which make a profit from selling their users’ personal data, they happen to be our only affordable providers of certain services at the moment, and thus we are obliged to share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. However, we have contracts in place with said third parties, which are designed to help safeguard your personal information. This means that they should not share with any other third parties or process your personal information for any purpose other than the ones we have instructed them to. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. They commit themselves to not share your personal information with any other organization apart from us, so if you think they could break the contract please let us know writing to hola@arcasacra.com and we will try to solve that hypothetic case. Anyhow, the aforementioned is explained in their own privacy policy and terms of use, so we encourage you to read their own legal documents and contact them in case you think their part of the agreement might have been breached, as we can not vouch for them or guarantee that they will strictly follow those commitments.

 The third parties we may share personal information with are as follows: (click on the names to navigate to their own Privacy Policy and Terms Of Use)

• Cloud Computing Services: Google Cloud Platform. They provide the host as part of the SiteGround service and we can not change it. Despite Google is not supposed to resell your data to third parties, please read their Privacy Policy and Terms Of Use about it.
• Content Optimization: YouTube video embed, Vimeo video, Google Fonts and Gravatar. Even when we encourage the use ethic and privacy focused companies, these third parties are widely used and we are forced to use them as well. However, please read their Privacy policy and Terms of Conditions for more info.
• Functionality and Infrastructure Optimization: SiteGround Hosting. We have chosen this company for their reputation, strong security and service. However, we will continue improving our services and we could change this host provider in the future if they reveal themselves as non-ethical or because of any other issue that clashes with the core values and ethics of ARCASACRA.
• Invoice and Billing: Stripe and PayPal. They are the only option we can use at the moment and they may be changed in the future for a more ethic one, closer to the fairer and ethical Community we aspire to build.
• Web and Mobile Analytics: Google Analytics. We will change this in the future as we do not agree in general with Google ethics. However, right now, it is just the only service we can afford for Internet analytics.
• Website Hosting: Sharetribe and SiteGround. Regarding Siteground please refer to the comments above about Functionalitity and Infrastructure. We have chosen Sharetribe as marketplace providers due to their contribution to a better shared and collaborative economy.

We also need or could need to share your personal information in the following situations:

• Business Transfers. In the hypothetic and unlikely situation of being forced to sell or merge the company (since we haven’t created this company with that goal in mind at all), we would only share or transfer your information (always with your previous explicit consent) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You would have the right to cancel your account with them and we will always let you know if something like this would happen.
• When we use Google Maps Platform APIs. We must share some of your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link. We will try to use a more friendly API for this purpose (such as Open Street Map or Qwant Maps) as soon as we can or if Sharetribe give us that option.
• Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact in public areas of the Services sharing personal information, such as your name, profile link or reviews given, it may be viewed by all Members and may be publicly made available outside the Services in perpetuity, so please be aware of the personal information you share on the public areas of the Services, as we are not responsible for any personal information voluntarily made public by you when using our Services.
• Offer Wall. Only applicable if our application(s) would display a third-party hosted “offer wall” in the future. Such an offer wall would allow third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. If this would the case, we will ensure that all those third-party companies comply with the ethics and privacy standards established by ARCASACRA’s Core Values. Such an offer wall would appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information, if you give us your consent to share this data with said third-party advertiser. In that case, you would receive any profits from the trade of your personal data minus our transaction fee of 13%. When you click on an offer wall, you would be brought to an external website belonging to other company and will leave our application(s) and Services. A unique identifier, such as your user ID, would be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. We will try our best to partner with third-party advertisers which treat your privacy in the same way we do. However, we would always recommend reading their privacy policies so you know exactly the way they treat your personal data. 

5. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

In Short: We use cookies and other tracking technologies to collect and store your information.

We use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

6. HOW WE HANDLE YOUR SOCIAL LOGINS

In Short: We do not let you choose to register or log in to our services using a social media account. 

Our Services do not offer you the ability to register and log in using your third-party social media account details because we have not found any social network close to our values that we can use for this service. If Sharetribe provide us more ethical choices for this purpose we will let you know accordingly in case you would like to use that feature. In this case and would you choose to do this, we would receive certain profile information about you from your social media provider. The profile information we receive would vary depending on the specific social media provider used, but this will often include your name, email address, friends list and profile picture, as well as other information you choose to make public on such a social media platform.

We would use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider and your interaction with us through them. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. IS MY INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We have to transfer, store, and process your information in countries other than your own.

The servers we use through our hosting providers are located in the United States, United Kingdom, Netherlands, Germany, Australia and Singapore. If you are accessing our Services from outside the United States, United Kingdom, Netherlands, Germany, Australia or Singapore, please be aware that your information may be transferred to, stored, and processed by us in their facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION” above), in the United States, United Kingdom, EEA, and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), some of the countries we may transfer your information to may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, such as using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information they process which originates from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. HOW LONG WE KEEP YOUR INFORMATION FOR

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than six (6) months past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW WE KEEP YOUR INFORMATION SAFE

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We and our providers Siteground and Sharetribe have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment and we encourage yourself to always use the Internet keeping in mind your privacy and personal data as a human right and use all the tools at your disposal in order to contribute to an Internet free of both anti-privacy corporations and criminal individuals.

10. YOUR PRIVACY RIGHTS

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You have the right to review, change or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can contact us to make such a request by using the contact details provided in the section “HOW TO CONTACT US ABOUT THIS POLICY” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here here.

If you are located in Switzerland, the contact details for the data protection authorities are available here.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW TO CONTACT US ABOUT THIS POLICY” below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by opting out on the user’s account settings, directly on the email in case of electronic communication, or by contacting us using the details provided in the section “HOW TO CONTACT US ABOUT THIS POLICY” below. You will then be removed from the marketing lists — however, we may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information : If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements only during a limited amount of time as expressed above.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you can email us at hola@arcasacra.com.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted and we can follow it in the future, we will inform you about that practice in a revised version of this privacy policy.

12. CALIFORNIA RESIDENTS’ SPECIFIC PRIVACY RIGHTS

In Short: If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with our Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.) or the Internet (e.g., someone may have copied it and store it outside our Services and servers).

CCPA Privacy Policy 

The California Code of Regulations defines a “resident” as:

• (1) every individual who is in the State of California for other than a temporary or transitory purpose and
• (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect? 

We have collected the following categories of personal information in the past twelve (12) months: 

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal Information categories listed in the California Customer Records Statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under California or federal law	Date of birth	YES
D. Commercial information	Transaction information, purchase history, financial details, and payment information	YES
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behaviour, interest data, and interactions with our and other website, applications, systems, and advertisements	YES
G. Geolocation data	Device location	YES
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recording created in connection with our business activities	YES
I. Professional or employment-related information	Business contact details in order to provide you our services at a business level or job titile, work history, and professional qualifications if you apply for a job with us	YES
J. Education Information	Student records and directory information	YES
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	YES

We may also collect other personal information outside of these categories for instance when you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information? More information about our data collection and sharing practices can be found in this privacy policy. In essence, we do not share your personal information with any other third party not included in this Privacy Policy, and in the case this could happen in the future, it would be with your consent. You may contact us by email at hola@arcasacra.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else? With your consent, we could disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider would be a for-profit entity that processes the information on our behalf.

We use your personal information only for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

ARCASACRA LLP has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. ARCASACRA LLP has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION“. 

Your rights with respect to your personal data

• Right to request deletion of the data — Request to delete
  • You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
• Right to be informed — Request to know
  • Depending on the circumstances, you have a right to know:
    • whether we collect and use your personal information;
    • the categories of personal information that we collect;
    • the purposes for which the collected personal information is used; whether we sell your personal information to third parties;
    • the categories of personal information that we sold or disclosed for a business purpose;
    • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
    • the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

• Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights.
  • We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make said request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• You have the right to object to the processing of your personal information.
• You have the right to request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You have the right to designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You have the right to request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at hola@arcasacra.com, or by referring to the contact details at the bottom of this document.

13. UPDATES TO THIS POLICY

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We will update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we will notify you both by prominently posting a notice of such changes and by directly sending you a notification by email and you will have always the right to not agree with the new version. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

14. HOW TO COMPLAIN AND TO CONTACT US ABOUT THIS POLICY

If you have questions or comments about this policy, or if you have a complain about how we handle your data, we would like to hear from you. Please contact us by email at hola@arcasacra.com or by post to:

ARCASACRA LLP

119 Whitecraig Avenue

Whitecraig, East Lothian EH21 8PA United Kingdom 

If you are a resident in the European Economic Area, the “data controller” of your personal information is ARCASACRA LLP. You can contact us directly regarding the processing of your information,

• by email at hola@arcasacra.com,
• by phone at +447707374577 (UK)
• or by post to: 

ARCASACRA LLP

119 Whitecraig Avenue

Whitecraig, East Lothian EH21 8PA United Kingdom 

If you are a resident in the United Kingdom, the “data controller” of your personal information is ARCASACRA LLP. You can contact us directly regarding the processing of your information,

• by email at hola@arcasacra.com,
• by phone at +447707374577 (UK)
• or by post to:

ARCASACRA LLP

119 Whitecraig Avenue

Whitecraig, East Lothian EH21 8PA Scotland 

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

15. HOW TO REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU

Based on this privacy policy and on Arcasacra’s principles, you always have the right to request access to the personal information we collect from you, change that information, or delete it in all circumstances except from those required by law or fraud prevention. To request to review, update, or delete your personal information, please submit a request form by clicking here.

This privacy policy was last updated on September 3rd, 2022.