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Privacy Policy

This Privacy Policy describes how Areté Create collects, uses, and shares information about you and applies to your use of any online service location that posts a link to this Privacy Policy and all features, content, and other services that we own, control, and make available through such online service location (collectively, the “Service”). This Privacy Policy does not apply to information collection activities outside of the Service, such as ARETÉ CREATE’S products and services that ARETÉ CREATE’S customers may use to collect information on their own behalf (unless otherwise stated below or at the time of collection).  For information about processing on behalf of our customers, please see the section entitled “Customer Data” below.

By using the Service, you agree to our collection, use, and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree with this Privacy Policy, then do not use the Service.

Information Collection

Information You Provide to ARETÉ CREATE

ARETÉ CREATE collects information that you voluntarily submit to ARETÉ CREATE through the Service. For example, we collect information when you contact us to inquire about our products and services. The information we collect may include information that identifies or could identify you (whether alone or in combination), such as your name, email address, or physical address. Do not submit any information to us that we have not requested.

Information Collected Automatically

Device and how your device interacts with our Service. Examples of this type of information include your device’s IP address and other device identifiers, the type of internet browser you are using on your device, the type of operating system application software and peripherals you are using on your device, the domain name of the website from which your device linked to our Service, and your browsing habits on and usage of the Service through your device.

We use various current – and later – developed technologies to collect this information (“Tracking Technologies”), including the following:

  • Cookies – A cookie is a small data file that certain websites write to your hard drive when you visit them. We may also use web bugs, clear gifs and similar technologies that collect data similar to that collected by a cookie.  A cookie file can contain various types of information, including a user ID that the site uses to track the pages you have visited.
  • Pixels – A pixel (also known as a web beacon) is code embedded in a website, video, e-mail, or advertisements that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, e-mail, or advertisements that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your device. Pixels are used in combination with cookies to track activity by a particular browser on a particular device.
  • Location-identifying Technologies – Location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.

Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.

For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Third Party Services, Features, and Devices” and “Your Rights and Choices” below.

Information from Other Sources

We may obtain information about you from other sources. Such information may be intermingled with and used by us in conjunction with information we have collected about you through the Service. To the extent we combine such third party sourced information with information we have collected about you on the Service, we will treat the combined information in accordance with this Privacy Policy, plus any additional restrictions imposed by the source of the data.  These third party sources vary over time, but have included:

  • Data brokers from which we purchase demographic data to supplement the data we collect;
  • Social networks when you reference our Service or grant permission to us to access your data on one or more of these services;
  • Partners with which we offer co-branded services or engage in joint marketing activities; and
  • Publicly-available sources such as open government databases or other data in the public domain.

For further information on Third Party Services, see the section entitled “Third Party Services, Features, and Devices” below.

Use of Information

ARETÉ CREATE uses information we collect through the Service for our legitimate interests, including the following purposes:

  • To manage our Service;
  • To perform services requested by you, such as to respond to your comments, questions, and requests, and provide customer service;
  • To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
  • To prevent and address fraud, breach of policies or terms, and threats or harm;
  • To monitor and analyse trends, usage, and activities; and
  • To improve the Service or other ARETÉ CREATE websites, applications, marketing efforts, products and services.

We also use information about you with your consent, including:

  • To send you direct marketing about our products, services, offers, promotions, rewards, and events we think you may be interested in;
  • To provide you with advertisements tailored to your interests; and
  • To fulfil any other purpose disclosed to you and with your consent.

We may use information that does not identify you (including personally identifiable information that has been de-identified) without obligation to you except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.

Sharing of Information

ARETÉ CREATE shares information we collect through the Service as follows:

  • Service Providers – Our agents, vendors, consultants, and other service providers (collectively “Service Providers”) may process your information in connection with their work on our behalf. These Service Providers are contractually prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
  • Affiliates – We may share your information with our affiliates for internal business purposes. For example, we may share your information with our affiliates for customer support, marketing, or technical operations.
  • Third parties – We may share your information with third parties for purposes of providing you with advertisements tailored to your interests.
  • Merger or Acquisition – We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Security and Compelled Disclosure – We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information as required by courts or administrative agencies and to the extent necessary to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Service rules or policies, or the rights of third parties or to investigate any suspected conduct which ARETÉ CREATE deems improper. We may also share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
  • Consent – We may share your information for any other purpose disclosed to you and with your consent.

Without limiting the foregoing, we may share aggregated information which does not identify you or de-identified information with third parties or affiliates except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.

Third Party Services, Features, and Devices

Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated, owned, and maintained by third parties.  (“Third Party Services”). In addition, our Service contains features that allow you to interact with, connect to, or access our Service through certain Third Party Services and third party devices (“Third Party Features”). For example, you use a Third Party Feature when you “like” or “share” content over social media through our Service. Remember that third parties may use Tracking Technologies to independently collect information about you and may solicit information from you. Also, if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature. If you publicly reference our Service on a Third Party Service (e.g., by using a hashtag associated with ARETÉ in a tweet or post), we may use your reference on or in connection with our Service.

Our Service also contains Tracking Technologies operated by third parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Service to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Similarly, ad serving services, advertisers, and other third parties may use Tracking Technologies on our Service and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Service (“Interest-based Advertising”).

The information collected and stored by third parties, whether through our Service, a Third Party Service, a Third Party Feature, or a third party device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. ARETÉ CREATE is not responsible for and makes no representations regarding the privacy practices of such third parties.  You should carefully read their own privacy policies before providing any information to such third parties. To the extent we combine information we receive from third parties with information we collect directly from you on the Service, we will treat the combined information in accordance with this Privacy Policy.

For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.

Your Rights and Choices

Tracking Technologies Choices

Most browsers are initially set up to accept cookies; however, you generally can reset your browser to refuse all cookies or indicate when a cookie is being sent or you can flush your browser of cookies from time to time. (Note: you may need to consult the help area of your browser application for instructions.) If you choose to disable cookies or refuse to accept a cookie, you may not be able to utilize all features of the Service.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit.  Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Analytics and Interest-Based Advertising

You may exercise choice regarding the use of cookies from Google Analytics by visiting https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

Your European Privacy Rights

If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service.

If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. For information on how to exercise your rights for information collected and processed at the direction of our customers, see the section entitled “Customer Data” below.

EEA Withdrawal of Consent

If you are a data subject in the EEA, you have the right to opt out or withdraw your consent for us processing your personal data collected through the Service (or providing it to third parties to process) for direct marketing purposes (including promotional emails) or purposes materially different than for which it was originally collected or subsequently authorized by you. You may also withdraw your consent at any time for any data processing we do based on consent you have provided to us. Please note that withdrawal of your consent does not impact any data that was processed on the basis of that consent before it was withdrawn.

To exercise this right, please e-mail us or send us a letter to the mailing address in the section entitled “Contact Us” below and specify your withdrawal of consent. We will try to make the requested changes in our active databases as soon as reasonably practical.

Customer Data

We provide products and services for our customers, and may collect and process information about individuals at the direction of our customers (“Customer Data”). Our processing of Customer Data is governed by the terms of our service agreements with our customers, and not this Privacy Policy. We are not responsible for how our customers treat the information we collect on their behalf, and we recommend you review their own privacy policies.

ARETÉ CREATE acknowledges that you may have rights in connection with Customer Data. If your information has been processed by ARETÉ CREATE on behalf of a customer and you wish to exercise any rights you have with such information, please inquire with our customer directly. If you wish to make your request directly to ARETÉ CREATE, please provide the name of the ARETÉ CREATE customer on whose behalf ARETÉ CREATE processed your information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.

Data Security

We take reasonable steps to help protect the security of your information. To help prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we have put into place physical, electronic, and managerial procedures. However, due to the inherent open nature of the Internet, we cannot guarantee the security of your information collected through the Service.

Data Controller

European data protection law makes a distinction between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). In limited circumstances, ARETÉ CREATE (located at the address set forth in the section entitled “Contact Us” below) operates as a controller, such as in connection with data collected from users who browse our website. However, ARETÉ CREATE generally operates as a processor on behalf of our customers. The customers are the controllers and determine the purposes for which and the manner in which personal data are to be processed by ARETÉ CREATE.  If you are a data subject in the EEA, see the sections entitled “Your Privacy Rights” and “Customer Data” above for information on how to exercise your rights.

Changes to this Privacy Policy

We may amend our Privacy Policy at any time and will post those changes on this page, so you can understand what information we collect, how we use it, and under what circumstances we may disclose it. Any changes will be effective immediately upon posting of the revised Privacy Policy. However, if we plan to materially change the way in which we use or disclose your information, we will provide you with prior notice and a chance to opt-out of such differing uses.