Privacy Policy

Arcnine LLC d/b/a “Arcnine” (“Arcnine,” “we,” “us,” or “our”) collects, uses and processes information about our users. We are committed to handling your information with respect because your privacy is important to us. We provide this Arcnine Privacy Notice to explain how we collect, use and disclose information about you when you use our Website, Services, or mobile application (“Application”). Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in the Arcnine Terms of Use.

This Arcnine Privacy Notice does not apply to websites, applications, or services that do not display or link to this Arcnine Privacy Notice or that display or link to different privacy statements. By using our Website, Application and/or the Services, you consent to this Arcnine Privacy Notice. In the event you do not agree to the collection, use, and disclosure practices described in this Arcnine Privacy Notice, please do not use the Website or the Services.

1. THE PERSONAL INFORMATION WE COLLECT

a. Information You Provide to Us

  • You may choose voluntarily to provide or direct third parties to provide certain personal information to us. Personal information is information from which you can be directly or indirectly identified, such as your name, address, email address, phone number, payment card and financial account information, driver's license number, Social Security (or Insurance) number, and certain online identifiers
  • For example, you may decide to share or direct third parties to share with us your name, date of birth, location, email address, phone number, username and password, and the state, province or territory and country in which you reside when you create an Arcnine Account to log in to our Services. We need this information to set up your Arcnine Account, verify your identity, and provide you with our Services. The personal information you provide in connection with Arcnine Account creation will be collected in accordance with this Arcnine Privacy Notice.
  • When you use our Website, Application, or Services, we may collect all information necessary to provide you with the Services, including your name, address, email address, phone number, credit or debit card number, other financial account and billing information, Social Security (or Insurance) number, tax information, and records of the Services you purchased, obtained, or considered.
  • In the event you provide us feedback, contact, or communicate with us via email, chat, phone call, or text message, we will collect your name, email address, and/or phone number, as well as any other message content, in order to send you a reply, provide user and technical support, develop, improve and optimize our Services, satisfy our legal obligations, enforce our contracts and legal rights, and address any existing or anticipated disputes. We and our service providers may record, monitor, and retain emails, chats, calls, and texts. By communicating with us, you consent to this recording, monitoring, and retention. We may use AI chatbot technology and other automated methods of communication.
  • In the event you tell us where you are (e.g., by allowing any devices or the Application to send us your location or by otherwise permitting us to geolocate you), we may store and use that information to verify your eligibility to use the Services, to comply with relevant laws, and for fraud detection and prevention purposes.
  • Subject to our obligations under applicable anti-spam laws, we may use the personal information we collect from you, including, but not limited to, your name and address, for purposes of direct mail marketing. This means that you may receive postal mailings from us about our products, Services, promotions, and/or other marketing materials that we believe may be of interest to you.
  • If you participate in one of our surveys, we may collect additional information about your activity, usage, and preferences related to the Website, Application, and Services, so we can evaluate your interest in, and the quality of, our Services and provide you with user and technical support.

If you fail to provide information to us when requested, we may be unable to provide the Services to you and/or provide you with access to our Website and/or Application.

b. Information Collected Via Technology

Information Collected by our Services

In order to improve, personalize, and optimize the Services and meet our legal obligations, we may automatically track certain information about your access and usage of our Website, Application and the Services, including your operating system, Internet protocol (IP) address, device identifier, domain name, clickstream data, referring/exist pages, and a date/time stamp for your visits. We also use this information to analyze trends, administer the Services, gather demographic information about our user base, deliver advertising, perform research, provide technical and user support, inform our product development efforts, protect our legal rights, address disputes, and prevent the Services from being used to commit harmful or unlawful activities, including, but not limited to, fraud. Some of this information may also be collected so that when you access or use our Website, Application or the Services again, we will be able to recognize you and optimize your experience accordingly.

Device Information

We may collect information about the devices you use to access our Website or the Services, including the hardware models, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information. In the event you have downloaded our Application, we may also collect certain information from your mobile device, including information about how you use our Application. This information is generally used to help us deliver relevant information to you and to detect and prevent fraud and other unlawful activity. In the event our Application crashes on your mobile device, we will also receive information about your mobile device model, software version, and device carrier, which allows us to identify and fix bugs, provide other technical support, and improve and optimize the performance of our Applications.

Cookies

Like many online services, we use "cookies" and similar technologies to improve and personalize your experience on our Website and Application. Cookies are small pieces of information stored on your browser or device that a website sends to your computer's hard drive while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them or they expire). We may use cookies to collect information about your IP address, browser type, operating system, device type and identifiers, platform type, as well as your usage of and activity on our Website and Application and the performance of our Services. You can use the options in your web browser to manage your cookies settings, including controlling, disabling, or deleting cookies used by our Services at any time. You can delete all existing cookies on your computer and adjust settings for most browsers to prevent cookies from being received; however, disabling certain cookies may affect how our Services function.

2. INTERACTION WITH THIRD-PARTY SITES AND SERVICES

Certain products, services, or other materials displayed on our Website, Application and the Services may integrate with, be integrated into, or be provided in connection with certain third- party services and content. We do not control those third-party services and content, and our various terms of use and this Arcnine Privacy Notice do not apply to those services and content. You should read the third-party terms of use agreements and privacy policies that apply to such services and content. We are not responsible for the practices used by any third-party websites or services linked to or from our Website or Application, including, but not limited to, the information or content contained within them. By using our Website, Application, or by accessing or using the Services, you acknowledge and agree that we are not responsible for and do not have control over any third-party services and content that you authorize to access the information you provide to them. In the event you are using a third-party website or service and allow it to access your personal information, you do so at your own risk.

3. ADDITIONAL USES AND DISCLOSURES OF PERSONAL INFORMATION

User Feedback

We may post user feedback on the Website from time to time. To the extent we share your feedback, we will do so with your first name and last initial only. In the event you make any comments on a blog or forum associated with our Website, Application or the Services, you should be aware that any personal information you submit there can be read, collected, or used by other consumers of the blog or forum and might be used to send you unsolicited messages. We are not responsible for any personal information you choose to submit in these blogs and forums.

Creation of Aggregated, Anonymous or De-Identified Data

We may create aggregated, anonymized, or de-identified data (i.e., data that is not reasonably capable of being associated with or linked to you) from personal information we collect from or about you. We use such data to analyze request and usage patterns so that we may develop, improve, optimize, and/or enhance our Services and improve our users’ experience with and ability - 4 - 4919-7391-5569v5 to navigate our Website and Application. We reserve the right to use aggregated, anonymized or de-identified data for any purpose and to disclose it to third parties for any reason.

Responsible Use

We may use the information collected about you to assess whether you are responsibly using the Services. In the event we identify potentially problematic information, we may contact you to provide resources to help ensure that you are responsibly using the Services. By using our Website or Application, or by accessing or using the Services, you consent to our use of your information for these purposes.

SMS Text Communications and Transcription Services

Subject to our obligations under applicable anti-spam laws, we may use the telephone number(s) we collect from you for the purpose of one-to-one calls and text messages. By accepting this Arcnine Privacy Notice, you consent to receive calls and text messages from us, including, but not limited to, from our user support and personnel. This means we may contact you via call or text message to:

  • Provide user support and respond to your inquiries;
  • Inform you about important updates and changes to our Services; and
  • Offer personalized assistance and services tailored to your interests.

You may opt out of receiving calls and text messages from us by following the instructions in the communications you receive, by contacting user support at support@arcnine.com.

In addition to the disclosure practices discussed above, we may disclose your personal information as follows:

Service Providers

We may share your personal information with certain service providers to provide you with our Services; conduct quality assurance testing; facilitate the creation of Arcnine Accounts; provide account authentication and user verification services; provide technical and user support; geolocate users; personalize, customize, and improve your use of and experience with the Services; send email and push notifications; enable security support and technical maintenance; send newsletters, surveys, messages, and promotional materials related the Services; verify your identity; prevent unlawful uses of our Services; deliver customized or personalized content, information, and advertising; understand when consumers have installed our Applications; send consumers links to download our Applications; request feedback; monitor the health of our servers; manage search engine optimization; and improve and optimize the performance of our Services. We also use the personal information we collect in connection with your use of our Services to detect and prevent harmful, abusive, fraudulent, and other malicious activity. We may share this information with vendors and service providers.

Fraud Detection and Prevention, Risk Analysis, and Identity Verification Vendors

We may use fraud detection and prevention, risk analysis, and identity verification vendors to detect and prevent fraud, evaluate risk (including, but not limited to, regarding your ability to successfully complete a transaction), confirm your identity, and/or enhance or assist your Arcnine Account opening and onboarding experience. By using our Services, you also authorize us to disclose your full name, date of birth, address, phone number, identification information, transaction details, and decisions information directly to such vendors for purposes of detecting and preventing fraud, evaluating risk, and/or verifying your identity. By using our Services, you also agree to permit such vendors to verify your identity with a credit bureau and access your credit file solely for the purpose of identity verification, which will not affect your credit score. This data will be maintained for the duration of our business relationship with such vendors and any applicable retention period.

Affiliates

We may share some or all of your personal information with affiliates, including, but not limited to, any subsidiaries, joint venturers, and any other companies under common control ("Affiliates"), in which case we will require our Affiliates to respect this Arcnine Privacy Notice.

Corporate Restructuring

We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition, corporate divestiture, dissolution transaction, or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, your personal information may also be transferred as a business asset.

Other Disclosures

Regardless of the choices you make regarding your personal information, we may disclose your personal information in the event we, in good faith, believe that such disclosure is necessary: (i) to comply with relevant laws or to respond to discovery requests, subpoenas, or warrants served on us; (ii) in connection with any legal investigation; (iii) to protect or defend the rights or property of Arcnine or users of our Website, Application or Services; (iv) to investigate or assist in preventing any violation or potential violation of law, this Arcnine Privacy Notice, or our terms of use; or (v) in the event we believe that an emergency involving the danger of death or serious injury to any person requires or justifies disclosure of the information.

4. DATA SECURITY AND RETENTION OF PERSONAL INFORMATION

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use reasonable administrative, technical, and physical procedures, practices, and safeguards designed to protect personal information we collect from unauthorized access, use, alteration, exfiltration, or destruction.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services, such as Discord - 6 - 4919-7391-5569v5 threads or on social media. The information you share in public areas may be viewed by any user of the Services.

You can also play a role in protecting your personal information. To protect your personal information while accessing or using our Website, Application, and/or Services, we strongly suggest that you do not share your Arcnine Account information and that you adhere to the following password practices:

  • Use a strong password that is at least ten (10) alphanumeric characters long, and contains upper and lower-case characters, numbers, punctuation marks, and special characters such as !@#$;
  • Use a password that is not easily guessed and is not a word in any language, slang, or is based on personal information such as a family name;
  • Treat your password as confidential and do not disclose it to anyone else;
  • Do not write down your password;
  • Do not store your password online in unencrypted form;
  • Change your password every three (3) months; and
  • Choose a password that is unique, not one that you use for any other website or application.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. To the greatest extent permitted under applicable law, we are not responsible for circumvention of any privacy settings or security measures contained in the Services.

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of that personal data, the purposes for which we process that personal data and whether we can achieve those purposes through other means as well as the applicable legal requirements.

6. CHILDREN

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any information through the Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information through the Services or through any of their features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@arcnine.com.

7. INTERNATIONAL USE

The Services are hosted in the United States. The Services are not intended to subject us to the laws or jurisdiction of any country or region other than those of the United States. In the event you are accessing the Services from any other country or region, please be advised that through your continued use of the Website, or Services, which are subject to this Arcnine Privacy Notice, you are transferring your personal information to the United States. Your information may be stored and processed in the United States or any country where we have facilities or in which we engage service providers or other vendors. By accepting this Arcnine Privacy Notice and by using our Website, Application or the Services, you consent to the transfer of your information to the United States, which may have different privacy and data protection rules than those of your country or region.

8. GDPR PRIVACY RIGHTS – ADDITIONAL INFORMATION FOR INDIVIDUALS

If you are a “data subject” for whom the processing of personal information is subject to Regulation (EU) 2016/679 (“GDPR”) or the U.K. General Data Protection Regulation (“UK GDPR”) (“Covered Person”), this Section 8, including the rights described in sections (A) through (E) apply to you. For the purposes of the GDPR and the UK GDPR, Arcnine is the controller of your personal data.

(A) Right of Access, Rectification, Erasure and Restriction of Processing. You may obtain access to your personal information stored by us by contacting us. If we process or use your personal information, we shall endeavor to ensure, by implementing suitable measures, that your personal information is accurate and up to date for the purposes for which they were collected. If your personal information is inaccurate or incomplete, you may obtain the rectification of such personal information by contacting us. You may obtain the erasure or restriction of processing of your personal information in certain situations where we have no good reason to continue to process it, or the further storage is unnecessary under statutory storage obligations. A request for restriction of processing your personal data also enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

(B) Right to Data Portability. You may receive the personal information about you that you have provided to us, in a structured, commonly used and machine-readable format or transmit this information to another controller. To exercise this right, contact us at support@arcnine.com.

(C) Right to Object. You may be able to object, on grounds relating to your particular situation, to the processing of your personal information, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. To exercise this right, you must contact us as provided herein. We may be unable to provide Services to you if you object to our processing of personal data. You may use ad-blocking software to limit information capture and usage of personal data.

(D) Right to Withdraw Your Consent. If you have given your consent to the collection or processing of your personal information, you may withdraw your consent without affecting - 8 - 4919-7391-5569v5 the lawfulness of processing based on consent before its withdrawal by contacting us in writing.

(E) Right to Lodge a Complaint. Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority in the UK (the ICO) and/or Member State of your residence, place of work or place of alleged infringement if you consider the processing of your personal information is infringing on GDPR or UK GDPR. You can also lodge a complaint to us directly, and we would appreciate the opportunity to deal with your concerns directly.

(F) If you make a request under sections (A) – (E) above, requests can be emailed directly to support@arcnine.com. Please try to provide us with as much detail as possible as to what you are seeking. The GDPR and UK GDPR allow us one (1) calendar month to respond to requests from the date we receive your request. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you are a Covered Person, please note that we primarily rely on the following legal bases for processing your personal data:

  • it is necessary for the performance of a contract between you and us, or in order to take steps at your request to enable us to enter into a contract with you;
  • the processing is necessary to enable us to comply with the law; and/or
  • it is in our legitimate interests (or the legitimate interests of a third party), unless those interests are overridden by your rights or interests. Our legitimate interests include providing the Services to you, pursuing and growing our business, performing administrative tasks, ensuring the security of our IT systems, and complying with our legal obligations.

If you are a Covered Person, notwithstanding the references to processing personal data on the basis of 'consent' in this privacy policy, we do not expect to need to rely on your consent to process personal data and instead for the purposes of the GDPR and UK GDPR intend to rely on a different legal basis (as set out above). Where we do require your consent to process your personal data, we will obtain that consent from you in accordance with the law. Circumstances where we might seek to obtain your consent include:

  • to send electronic marketing information to you (unless we are relying on our legitimate interest); and/or
  • to place non-essential cookies on any of your devices.

Arcnine is based in the United States and we will process and store your personal data in the United States. Your personal data may also be transferred to, stored and processed in other countries outside of the UK, EU and United States. Whenever personal data is transferred by us to another country or territory, we take steps to ensure we comply with the law, including by ensuring appropriate safeguards are in place.

9. ADDITIONAL INFORMATION FOR CANADIAN RESIDENTS

If you are a Canadian resident, in addition to those rights set forth in this Arcnine Privacy Notice, you have the following rights:

  • Access And Modify: You may access or amend the personal information we hold about you by contacting us using the contact information in the “How to Contact Us” section below.

Please note that your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you such as when such information also includes the personal information of a third party. In addition, the personal information may have been destroyed, erased, or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

  • Withdrawal Of Consent. You also may also withdraw your consent to certain of our uses and disclosures of your personal information. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.
  • Quebec Residents’ Rights. If you reside in the province of Quebec, in certain circumstances, you may also have: i) the right to request that we cease disseminating your personal information, ii) the right to request that we de-index any hyperlink attached to your name that provides access to information by a technological means; iii) the right to request that we re-index a link providing access to information; or iv) the right to request that we communicate to you, as well as to any person or body authorized by law to collect such information, any computerized personal information collected from you in a commonly used technological format.
  • Right To Lodge A Complaint. Although we ask that you first contact us at the contact details below if you believe that any of your rights regarding our collection, use, and disclosure of your personal information may have been violated, you have, at all times, the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts.

We will not retaliate against an individual who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their personal information.

When requesting access to or seeking to enforce any of your rights regarding your personal information, we may request specific information from you to enable us to confirm your identity.

10. STATE PRIVACY RIGHTS

Residents of certain states with comprehensive privacy laws may have rights concerning their personal information.

11. CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge. To make such a request, please send an email to support@arcnine.com.

California Notice of Collection and Use of Personal Data

This California Notice of Collection and Use of Personal Data supplements the Arcnine Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopted this California Notice to comply with California privacy laws, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA and not defined here have the same meaning when used in this California Notice.

Categories of Personal Information:

In the last twelve (12) months, we have collected the following categories of Personal Information:

  • Identifiers such as a real name, postal address, internet protocol address, email address, or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)), such as education, employment, employment history, and financial information.
  • Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
  • Geolocation data.
  • Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Personal Information that is deemed “Sensitive Personal Information,” including precise geolocation.

We will not collect additional categories of Personal Information other than those categories listed above. If we intend to collect additional categories of Personal Information, we will provide you with a new notice at or before the time of collection.

How We Share Your Personal Data

In the past 12 months, we have disclosed the following categories of personal data for a business purpose with the following categories of third parties:

  • Our service providers. Third parties such as social networks.
  • Our affiliated entities.
  • Our partners or prospective partners in order to provide us and/or our affiliates and partners with information about the use of the Services and levels of engagement with the Services, to allow us to enter into new business relationships, and to allow us to market products or services on their behalf.

Finally, we may also share personal data with government entities, agencies or regulators when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, health, or safety, and/or that of our users, visitors and others.

Your CCPA Rights

If you are a California resident, you have the following CCPA rights:

  • Right to Know: You have the right to request that we disclose certain information to you about the personal data we collected, used, disclosed, sold, and shared about you in the past 12 months. This includes a request to know any or all of the following:
    • The categories of personal data collected about you;
    • The categories of sources from which we collected your personal data;
    • The categories of personal data that we have sold, shared, or disclosed about you for a business purpose;
    • The categories of third parties to whom your personal data was sold, shared, or disclosed for a business purpose and the categories of persons to whom it was disclosed for a business purpose;
    • Our business or commercial purpose for collecting, selling, or sharing your personal data; and
    • The specific pieces of personal data we have collected about you.
  • Data Portability: You have the right to request a copy of personal data we have collected and maintained about you in the past 12 months.
  • Right to Deletion: You have the right to request that we delete the personal data we collected from you and maintained, subject to certain exceptions.
  • Right to Opt-Out/In: You have the right to opt-out of the Sale or Sharing of your personal data.
  • Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:
    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
    • Right to Correct: You have the right to correct inaccurate personal data about you. Once we receive and verify your request, we will use commercially reasonable efforts to correct the inaccurate personal data about you.
  • Right to Restrict or Limit the Use of Sensitive Personal Data: You have the right to restrict the use and disclosure of Sensitive Personal Information to certain purposes related to the offering of goods or services as listed in the CCPA.

Some of our Services, however, may require your personal data. If you choose not to provide your personal data that is necessary to provide any aspect of our products or Services, you may not be able to use those products or Services.

Submitting a Verified Consumer Request

To exercise your rights, you must provide us with sufficient information to allow us to verify your identity, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Once we receive the information you provide to us, we will review it and determine if more information is necessary to verify your identity as required by law, and we may request additional information in order to do so.

To exercise your California privacy rights described above, please submit a verifiable request to us by emailing us at support@arcnine.com.

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your personal data. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative. We will need to verify your identity with at least two (2) pieces of information, such as name and email address.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

Consumer Request by an Authorized Agent

If any authorized agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorized agent’s identity, we require an email be sent to support@arcnine.com, along with one or more of the following: (1) California Secretary of State authorization, (2) written permission from the California resident, or (3) power of attorney.

To verify the identity of the California resident for whom the request is being made, provide two or more of the following: (1) Valid Government Issued ID (not expired); (2) Utility Bill; (3) Bank Statement; (4) Email Address; or (5) Last 4 of the SSN.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will acknowledge receipt of the request within ten (10) business days of its receipt. We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability requests, we will provide the responsive information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

12. NEVADA PRIVACY RIGHTS

Nevada law permits our users who are Nevada consumers to request that their personal information not be sold (as defined under applicable Nevada law), even if their personal information is not currently being sold. Requests may be sent by sending an email to support@arcnine.com.

13. OTHER U.S. STATE PRIVACY RIGHTS

If you are located in Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have certain rights regarding your personal information under applicable state privacy laws, including the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“PDPOM”), the Delaware Personal Data Privacy Act (“DPDPA”), the Indiana Consumer Data Protection Act (“ICDPA”), the Iowa Consumer Data Protection Act (“Iowa CDPA”), the Kentucky Consumer Data Protection Act (“KCDPA”), the Maryland Online Data Privacy Act (“MODPA”), the Minnesota Consumer Data Privacy Act (“MCDPA”), the Montana Consumer Data Privacy Act (“MNCDPA”), the Nebraska Consumer Data Privacy Act (“NCDPA”), New Hampshire SB 255 (“NH Act”), New Jersey SB 332 (“NJ Act”), the Oregon Consumer Privacy Act (“OCPA”), the Rhode Island Data Transparency and Privacy Protection Act (“RDTPPA”), the Tennessee Information Protection Act (“TIPA”), the Texas Data Privacy and Security Act (“TDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”).

As a resident of one of the foregoing states, you may have some or all of the rights listed below. However, these rights are not absolute, and we may decline your request as permitted by law. You can ask to appeal any denial of your request in the same manner through which you may submit a request.

Right to Access and Portability. You have the right to access your personal information and/or receive a copy of the personal information that we have collected about you.

Right to Correct. You have the right to correct inaccurate personal information that we have collected about you.

Right to Delete. You have the right to delete the personal information we have obtained about you or that you have provided to us, with certain exceptions.

Right to Opt-out of Tracking for Targeted Advertising Purposes. You have the right to opt-out of certain tracking activities for targeted advertising purposes.

Right to Opt-out of Profiling. If we process your personal information for profiling purposes as defined by the foregoing state privacy laws (other than the ICDPA), you can opt-out of such processing.

Right to Opt-Out of Sales. You have the right to opt out of the sale of your personal information to third parties.

Right to Opt-In for Sensitive Data Processing. To the extent we process any of your sensitive personal information (as defined under applicable state law), you have the right to opt-in before we can process any such data.

Right Against Automated Decision-making. You have the right to opt-out of certain automated decision-making about you.

To exercise any of the foregoing rights, please contact us at support@arcnine.com.

14. OPTIONS REGARDING PERSONAL INFORMATION

Email Communications

We may periodically send you free newsletters and emails that contain information about our Website, and the Services or other products and services we feel may be of interest to you. You can indicate your preference to stop receiving such communications from us, and you may opt out of receiving further marketing from us by emailing us at support@arcnine.com or by following the unsubscribe instructions provided in the email you receive. Despite your indicated email preferences, we may send you transactional and service-related communications, including, but not limited to, notices of any updates to our terms of use and this Arcnine Privacy Notice.

Direct Mail

In the event you prefer not to receive direct mail marketing, you can opt out by contacting us directly at support@arcnine.com.

Opt Out of Application

You may stop all collection of information by our Application by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application network. In the event you use an Apple device, you may initiate the closure of your Arcnine Account from the Login & Security tab of the My Account or Profile page within the Application. You may also request to delete your Account by contacting us at support@arcnine.com.

Opt Out of Nonpublic Personal Information Sharing with Nonaffiliates

In the event you have directed Arcnine to share your nonpublic personal information with third parties who are not Affiliates or service providers of Arcnine (e.g., to deliver advertisements targeted to your interests and for Website optimization), you may change your preference and opt out by emailing support@arcnine.com. To opt out of certain non-required data sharing of personal information (including, without limitation, for marketing, advertising, and analytics purposes, to the extent applicable) on the Arcnine Website, please email support@arcnine.com.

15. HOW TO CONTACT US

Any inquiries or comments regarding your personal information and privacy rights, our data privacy practices, including our use of service providers outside your jurisdiction of residence, this Arcnine Privacy Notice, or any reports regarding suspected or actual security violations or harmful or unlawful activity, including, but not limited to, fraud on your Arcnine Account should be directed to support@arcnine.com.

16. CHANGES AND UPDATES TO THIS ARCNINE PRIVACY NOTICE

We reserve the right to modify this Arcnine Privacy Notice at any time. All changes will be effective immediately upon posting of the updated notices on the Website and, by accessing or using the Services after any changes are made, you agree to those changes. Material changes will be clearly posted on the Website or otherwise communicated to you (e.g., via email) in accordance with applicable privacy laws.