Revised: 16 July 2018
We are committed to protecting the privacy and security of the personal information we receive or collect from you. We also believe in transparency and are committed to informing you about how we treat your personal information.
We use the terms “you,” “your” and “yours” to denote you as a user of the Arria Website/Services, either on your own behalf or on behalf of an organization you represent or for which you work (in which case, these signifiers include the organization) or on behalf of those of your clients, customers or users whose data you process in the course of using the Arria Website/Services.
This Policy does not apply to information you may provide to Arria offline or through means other than through the Arria Website/Services.
2 Personal Information Responsibilities & GDPR
Arria NLG Limited is responsible for implementing the applicable data protection principles and for safeguarding the personal information you provide to us through the Arria Website/Services. If you are a user in the European Union (“EU”) or European Economic Area (“EEA”), for purposes of the EU General Data Protection Regulation, 2016/679 (the “GDPR”), Arria NLG Limited acts as data controller for the personal information we collect from you via the Arria Website/Services.
3 Personal Information Collection
You can generally visit the Arria Website/Services without actively entering any personal information about yourself. However, in certain areas of the Arria Website/Services, we may ask you to contact us with questions, comments or requests for more information about our services. In such cases we will collect personal information from you directly, as described below. We may collect and process the following personal information from you for the purposes set forth below:
|Category||Type of Data and Purpose|
|Contact Information||When you visit the Arria Website/Services or request our services, we may ask for your name, address, telephone number, email address, or other contact details in order to respond to your request or inquiry.|
|Business Information||When you seek services from us in the course of contractual or customer relationships with us involving you or your organization, we may collect business contact information and other personal information to provide you with the services you have requested.|
|Location Information||When you use the Arria Website/Services, we may collect information about your use of the Arria Website/Services and your interaction with advertising and analytics services in order to serve you content and to protect the Arria Website/Services and services. The location information we collect from you may include your Internet Protocol (IP) address or unique device identifier.|
|Cookies||When you visit the Arria Website/Services, we may collect cookies and use similar technologies to, among other things, provide you with a more personal and interactive experience on the Arria Website/Services in order to improve our marketing efforts and for the Arria Website/Services usage analytics (e.g., page response times, download errors, length of visit, webpages visited, etc.). If you choose to disable cookies and similar technologies, some areas and features of the Arria Website/Services may not work properly.|
|Automated Information||When you visit the Arria Website/Services, we automatically collect information from your browser or your mobile device, which may include your Internet Protocol (IP) address or unique device identifier, cookies, and data about which pages you have visited to allow us to operate the Arria Website/Services and provide the Arria Website/Services and our services. This information is used to maintain, and to improve the quality and security of, our Arria Website/Services and services. This information is also used to better understand how you interact with the Arria Website/Services in order to provide you with advertising content and a more personalized experience.|
|If you receive email communications from us, we may use certain tools to capture data that are invoked when you open our message, click on any links or banners it contains, or make purchases. Other information collected through this email tracking feature includes your email address, the date and time of your “click” on the email, a message number, the name of the list from which the number was sent, a tracking URL number, and a destination page. We use this information to enhance our marketing efforts. We do not sell or distribute this information to third parties.|
|Feedback / Support / Inquiries||If you provide us with feedback, contact us for support or ask us questions, we will collect your name, email address, other contact information, and any other information needed to (a) respond to your feedback, (b) provide the requested support or (c) answer your questions.|
|Mailing List||When you sign up for one of our mailing lists, we collect your contact information including your email address.|
|Sensitive Personal Information||If necessary to respond to your request for services, we may collect information regarding your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, financial information, or data concerning your sex life or sexual orientation. We will only collect this sensitive personal information with your express consent or as otherwise permitted by applicable law.|
|Employment||If you apply for a job with us or become our employee, we collect personal information necessary to process your application for employment and to perform management and human resources tasks related to your employment. This may include, among other things, your contact information, your social security number, employment history, and other permitted personal information.|
4 Personal Information Usage
Arria collects and uses the types of personal information listed above to improve your experience on the Arria Website/Services and to serve you better. We may also use personal information to help target specific offers to you. Additionally, we may use your personal information in the following ways:
- To provide you with the services and products you have requested and to manage our relationship with you, including administering your account (i.e., processing payments, auditing, billing and collections, and taking other steps necessary to the performance of our business relationship with you;
- To present and improve the Arria Website/Services content and functionality;
- To respond to visitor, subscriber, and customer inquiries;
- To determine user interests, needs, and preferences;
- To provide notice of changes to our Arria Website/Services or the services and products we offer or provide through them;
- To conduct marketing and operational research and analysis;To develop new products and services;
- To manage and maintain the security of our Arria Website/Services and services;
- To market our services and products to you. In jurisdictions where we are legally required to offer you an opt-out election, we will only provide you with marketing-related information after you have opted in to receive those communications, and in those jurisdictions we will provide you with the opportunity to opt-out of such communications at any time. We do not sell or distribute this information to third parties or use it for any other purpose;
- To comply with our legal and compliance obligations, including but not limited to maintaining records and performing compliance audits;
- For insurance purposes;
- To exercise and defend our legal rights or to comply with court orders;
- For any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your personal information has been provided to us;
- In any other way we may describe when you provide the information; and
- For any other purpose to which you have consented or for which we have a legal basis.
We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
- Because it is necessary to perform the services you have requested;
- Because it is necessary to comply with your instructions or other contractual obligations between you and Arria;
- Because it is necessary to comply with our legal obligations as well as to keep records of our compliance processes;
- Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing of your personal information necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
- Because you have chosen to publish or display your personal information on a public area of the Arria Website/Services, such as a comment area;
- Because it is necessary to protect your vital interests;
- Because it is necessary in the public interest; or
- Because you have expressly given us your consent to process your personal information in a particular manner.
We do not use your personal information for making any automated decisions affecting or creating profiles other than as described above; however, our software may carry out on an automated basis your instructions as to how your data will be processed.
5 Personal Information Sharing & Disclosure
We may share your personal information in the following contexts:
|Subsidiaries and Acquisitions||We may share your personal information within our organization including our subsidiaries and affiliates. In addition, we may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users is among the assets transferred. For example, if another company acquires Arria, we will share your personal information with that company.|
|Disclosures with Your Consent||We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context and with your consent.|
|Third Parties||Arria may provide personal information about you to third parties that offer products and services specifically requested by you|
|Service Providers||We may share your personal information with our service providers. Among other things, service providers may help us to administer the Arria Website/Services, support our provision of services requested by you, provide technical support, send marketing, promotions and communications to you about our services, perform payment processing, and for other legitimate purposes permitted by law.|
|Aggregated Data||We may disclose aggregated information about our users as well as information that does not identify any specific individual (such as groupings of demographic data and customer preferences) for new product development and marketing.|
6 Personal Information Retention
Arria will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as long as necessary to comply with our business requirements and legal obligations, or to resolve disputes, protect our assets, provide our services or enforce our agreements.
When we no longer have a purpose to retain your personal information, we will securely destroy your personal information in accordance with applicable law and our policies. We take reasonable steps to delete the personal information we collect if you opt out of receiving further communications from us or if you ask us to delete your information, unless we determine that doing so would violate our existing legitimate, legal, regulatory, contractual or similar obligations, or for the purpose of dispute resolution. We may retain and use anonymous and aggregated information for performance reporting, benchmarking, analysis, and for product and service improvement.
7 Updating Personal Information
If any of the personal information you have provided to us changes, please let us know. For instance, please update us if your email changes, or should you wish to cancel any request you have made of us, or if you become aware of inaccurate personal information about you. Use our “Contact Us” details provided at the end of this Policy to update your information.
We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete personal data that you provide to us.
8 Cross Border Transfers of Personal Information
Arria has offices throughout the world with infrastructure located in Ireland; therefore, your personal information may be transferred to, stored, or processed in Ireland. While the data protection, privacy, and other laws of Ireland might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the privacy and security of your personal information. By using our Arria Website/Services or requesting our services, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in Ireland and those third parties with whom we share it as described in this Policy.
9 Personal Information Access & Control Rights
Please use the “Contact Us” details at the end of this Policy to exercise your rights and choices under this Policy. If you would like to manage, change, limit, or delete your personal information or should you no longer wish to receive any email, postal mail, or telephone contact from us or our affiliates, such requests may be submitted via the “Contact Us” details at the end of this Policy.
- Right of Access. If required by law (e.g., under the GDPR), upon request we will grant reasonable access to the personal information that we hold about you.
- Right to Object. In certain circumstances, as permitted under applicable law, you have the right to object to the processing of your personal information and to ask us to erase or restrict our use of your personal information. If you would like us to stop using your personal information, please contact us and we will let you know if are able to agree to your request.
- Right to Erasure and Deletion of Your Personal Information.
- You may have a legal right (for instance, if you are located in the EU and/or EEA under the GDPR) to request that we delete your personal information when it is no longer necessary for the purposes for which it was collected or when, among other things, your personal information has been unlawfully processed. All deletion requests should be sent to the address noted in the “Contact Us” section of this Policy.
- We may decide to delete your personal information if we believe it is incomplete, inaccurate, or our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete personal information, it will be removed from our active servers and databases and our Arria Website/Services. Or, we may retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.
- Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you have the right to fully or partially withdraw your consent at any time. To withdraw your consent, please notify us using the information in the “Contact Us” section of this Policy, and you may also follow opt-out links on any marketing communications sent to you.
- Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and and then withdrew consent unless there are compelling legitimate grounds for further processing your information where such grounds override your interests, rights, and freedoms or for the establishment, exercise, or defense of our legal claims.
- Withdrawal of your consent to receive marketing communications will not affect the processing of personal information for the provision of our services.
- Right to Complain. If you believe that your rights relating to your personal information have been violated, you have a right to lodge a complaint with the applicable enforcement authority or seek a remedy through the courts. You may also lodge a complaint with us by contacting us using the information provided in the “Contact Us” section of this Policy.
- Accuracy. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.
- Online Tracking. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. It is a standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals on our Arria Website/Services, or on third-party websites, or via online services where we may collect information.
- California Residents. California residents may be entitled under California Civil Code Section 1798.83 to ask us for a notice describing what categories of personal information (if any) we can share with third parties or affiliates for their use in direct marketing. If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the “Contact Us” section of this Policy.
- European Union and/or European Economic Area Residents. If you are located in the EU and/or EEA and believe we have not processed your personal information in accordance with applicable provisions of the GDPR, you may lodge a complaint with your local data protection or supervisory authority.
10 Opt-Out Requests
If you no longer wish to receive communications from us via email, you may opt-out by contacting us at [email protected]. Please give the name of the service for which your information was provided, along with your full name, mailing address, phone number, and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.
Arria has implemented reasonable and appropriate technical and organizational security measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.
If a security breach causes an unauthorized intrusion into our Website or systems that compromises your data, we will, if and when required by applicable law, either (a) notify you, (b) notify any applicable regulator or (c) do both.
12 Children’s Online Privacy Protection Act
The US Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the internet. The Arria Website/Services and services are not directed to children younger than age 18, nor is information knowingly collected from children under the age of 18. No one under the age of 18 may access, browse or use the Arria Website/Services or provide any information to or on the Arria Website/Services. If you are under 18, please do not use or provide any information on the Arria Website/Services unless we choose to accept a written consent provided by your parent or legal guardian. If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it.
For more information about COPPA, please visit the US Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
13 Links to Third-Parties
This Arria Website/Services may contain links to, and media and other content from, third-party websites. These links are to external websites and third parties with which we have no relationship. Because of the dynamic media capabilities of the Arria Website/Services, it may not be clear to you which links are to the Arria Website/Services and which are to external, third-party websites. If you click on an embedded third-party link, you will be redirected away from the Arria Website/Services to the external third-party website. You can check the URL to confirm that you have left this Arria Website/Services.
Arria cannot and does not (a) guarantee the adequacy of the privacy and security practices employed by, or the content and media provided by, any third-parties or their websites; (b) control third-parties’ independent collection or use or your personal information; or (c) endorse any third-party information, products, services, or websites that may be reached through embedded links on this Arria Website/Services.
15 Contact Us
Arria NLG Limited Attn: Legal Department
9th Floor, MacRobert Building, University of Aberdeen, Aberdeen, AB24 5UA, Scotland