Privacy Policy

 

Arise (“Arise,” “we,” “our,” or “us”) values the privacy of the individuals who use our technology, websites, and related services (collectively, the “Arise® Platform”). This privacy policy will help you understand what personal data we collect, retain, process, share and transfer when you visit our

websites or use the Arise® Platform. This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our platform and services.

 

Our Commitment to Privacy

Our privacy commitments are fundamental to the way we run our business. Unless otherwise noted or governed by law, these commitments apply to everyone who has a relationship with us – including clients, service partners, agents and website visitors. Arise is committed to providing you with the best overall experience in all of our products and services. We strive to strike the right balance between using your data to ensure the quality of those experiences and protecting your privacy.

 

Scope

This policy applies to all information we collect including information about you, information we collect directly from you, information we automatically collect, information we collect through our mobile applications, and information we collect about you from third parties.

 

Personal Data

Personal Data, also referred to as PII or personally identifiable information, is information that identifies or reasonably can be used to identify you. Examples include your: (i) name, (ii) mailing address, (iii) email address, (iv) phone number, (v) date of birth or age, (vi) credit/debit card number, (vii) purchase information, (viii) mobile device information, (ix) how you use our sites, platform and mobile applications, (x) geo-location, (xi) social media information, and (xii) biometric data, such as fingerprints or voice recordings.

 

Personal Data We Collect

A. What We Collect

Device Information. Arise receives personal data from your devices, including IP address, location, GPS data, web browser type, mobile operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, push notification tokens, and, if you register with your social media account (such as Facebook, Google or LinkedIn), your applicable social media identifier.

 

Service Data (including Session and Usage data). To help us understand how you use our websites and the Arise® Platform and to help us improve them, we automatically receive information about your interactions, like the pages or other content you view, your actions within the websites and Arise®

 

Platform, and the dates and times of your visits. When you access our websites or use the Arise® Platform, we receive personal data generated through such use, either entered by you or third parties (for example, online profile information, schedules, attendee info, etc.), or from our websites or the Arise® Platform themselves (for example, duration of session, use of webcams, connection information, servicing information, etc.). We may also collect usage and log data, including diagnostic data to help us support the services.

 

Call, Email and Text Information. We work with third-party partners to facilitate calls, emails and text messages to you. We may receive personal data about these communications including the date and time of the call, email or SMS message, and whether the call was answered or the message was received or opened. We will share your personal data with such partners to facilitate these communications and to help us provide information and services to you.

 

Biometric Information. Following your registration on the Arise® Platform, we will collect biometric information, which consists of your physical or behavioral characteristics. The biometric information may be used to verify personal identity or to detect fraud and may be shared with third-party partners. Examples of physiological characteristics that we may collect include, but are not limited to, your fingerprints or facial features. Behavioral characteristics that we may collect include, but are not limited to, your voice, gestures, typing rhythm, or gait. Examples include voice recordings for support purposes; facial recognition systems for identity verification; or fingerprints for computer log on.

 

Call and Screen Recordings While Providing Services Using the Arise® Platform

While you are providing customer support and other services through the Arise® Platform, we may employ tools to: (a) record or listen to your calls or view your emails or texts; and (b) view you through your computer camera during your calls; and (c) video your desktop screens. These tools may be utilized without notice but only occur while you are logged into the Arise® Platform to provide services or participate in certification courses. These tools are used to provide support to you and to assist in improving your performance in providing customer support services.

 

Third Party Analytics. We use third party technologies, such as Facebook Analytics and Google Analytics, to help us to understand how you use our website and the Arise® Platform and ways that we can improve your experience. These technologies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content and improve the Arise® Platform and your experience. We also use social media buttons and plugins that allow you to connect with your social network in various ways, including Facebook, Twitter, and LinkedIn. These sites may set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

 

Personal Data from Cookies and Similar Technologies. We are continuously improving the Arise® Platform through the use of various third-party web analytics tools, which help us understand how visitors use our websites, desktop tools, platform, and mobile applications, what they like and dislike, and where they may have problems. We collect personal data through the use of “cookies”, tracking pixels, and similar technologies to understand how you navigate through our systems and interact with Arise advertisements, to learn what content is popular, and to save your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your

 

browser and may be accessed every time you open our website or use the Arise® Platform. You can consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept certain cookies from us, you may be missing out on certain features of our websites and the Arise® Platform.

 

Examples of Cookies We Use:

 

Cookie Type Purpose Description
Session Cookies We use these cookies to operate our websites and the Arise® Platform. Some cookies are essential for the operation of our websites and platform. If you choose to disable these cookies, you will not be able to access all of the

content and features.

Preference Cookies We use these cookies to remember your preferences. When you register on the Arise® Platform, we use cookies to store unique, randomly assigned user IDs that we generate for administrative purposes. These cookies enable you to enter the Arise sites without having to log on each

time.

Advertising Cookies These cookies are used to serve you with advertisements that may be relevant to you and your interests. We use cookies to make advertising more engaging to users, as well as to assist in reporting on marketing program

performance and analytics.

Security Cookies These cookies are used for general security purposes and user authentication. We use security cookies to authenticate users, prevent fraudulent use of login credentials, and protect user data from access by

unauthorized parties.

 

Tracking Technologies. Arise and our partners use cookies and similar tracking technologies to track user traffic patterns and hold certain registration information. Tracking technologies we use include web beacons, pixels, tracking tags and scripts to collect and track personal data and to improve and analyze our service.

 

Location Information. We collect your location-based information for the purposes such as providing and supporting users of the Arise® Platform, for fraud prevention and for security monitoring.

 

Servicing Information. When you use the Arise® Platform, we collect your servicing information, such as login and logout times, calls taken, accounts accessed, schedules, etc.

 

Mobile Device Log Information. If you use a mobile device to interact with an Arise website or platform, we will collect (a) location information (using GPS, IP addresses, or information from cell towers or Wi-Fi access points) and (b) mobile device information (hardware settings, crashes, browser information, or system activity).

 

B. Personal Data You Provide to Us

Your Profile Information. When you register to use the Arise® Platform, you may give us personal data such as your name, email address, phone number, date of birth, physical address, Social Security number, driver’s license number or other government-issued identification number, biometric data such as images of your face, hand, retina or ear, fingerprints, behavioral characteristics, such as gestures, voice, typing rhythm, or gait, and certain other personal data.

 

Payment Method. When you use a credit card on the Arise® Platform, a third party that handles payments for us will receive your card information. To keep your financial data secure, we generally do not store credit card information on our servers.

 

Communications. If you contact us directly, we may receive additional personal data about you. For example, when you contact our Partner Support Team, we may receive the contents of a message or attachments that you may send to us, and other personal data you choose to provide.

 

Payment Information. To make sure businesses using the Arise® Platform get paid, we keep information about bank routing numbers, tax information, and any other payment information provided by you.

 

C. Personal Data We Collect from Third Parties

Third Party Partners. Once you register on the Arise® Platform, we may receive additional personal data about you, such as demographic data, payment information, or fraud detection information, from third party partners and combine it with other personal data that we have about you. We may receive personal data about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with personal data we already have about you. We may also receive personal data from other affiliated companies that are a part of our corporate group. This helps us to update, expand and analyze our records, confirm your identity, identify new prospects for marketing, and provide products and services that may be of interest to you.

 

Background Information. Arise works with third party partners to perform identity verification and criminal background checks on individuals using the Arise® Platform, and we may receive personal data from them, including publicly available personal data about your criminal history. We share certain of your personal data with these partners who help us by running background checks and identity verifications on you for security purposes and we also may share such data with clients that you are servicing or law enforcement authorities.

 

How We Use the Personal Data We Collect

Arise may access and use the personal data we collect as necessary (a) to provide and maintain the Arise® Platform; (b) to provide our services to you and our other clients; (c) to verify your identity; (d) to address and respond to service, security, and customer support issues; (e) to detect, prevent, or

 

otherwise address fraud, security, unlawful, or technical issues; (f) as required by law; (g) to fulfill our contracts; (h) to improve and enhance the Arise® Platform; and (i) to provide analysis or valuable information back to our you and our other clients.

 

Some specific examples of how we use the personal data are as follows:

 

  • Create and administer your account
  • Provide, improve, expand, and promote the Arise® Platform
  • Provide services to you and other clients
  • Confirm your identity and perform background checks
  • Send you updates and servicing information
  • Analyze how you use our websites and the Arise® Platform
  • Analyze the customer support services you provide on client programs (which may include screen recording, voice recording, viewing or listening while servicing)
  • Communicate with you, either directly or through one of our partners, including for marketing and promotional purposes
  • Send emails and text messages to individuals who have started the registration process for providing customer support services on the Arise® Platform regarding the status of their registration
  • Determine your eligibility to use the Arise® Platform
  • Analyze data, including through automated systems and machine learning, to understand what servicing opportunities you might be interested in
  • Notify you about servicing opportunities and service updates
  • Personalize the Arise experience for you
  • Call you or send you emails and text messages
  • Facilitate transactions and payments
  • Provide you with support
  • Conduct research and analysis and analyze data, including through automated systems and machine learning, to improve our services and your experience
  • Find and prevent fraud and other unlawful conduct
  • Respond to security, confidentiality and safety issues that may arise, and requests from government authorities

 

How We Share the Personal Data We Collect With Third Parties

Ensuring your privacy is important to us. We will never sell your personal data and we do not share your personal data with third parties except as described in this privacy policy. We may share your personal data with (a) third party service providers; (b) business partners; (c) the company/service partner you work for; (d) affiliated companies within our corporate structure and (e) as needed for legal and security purposes. Third party service providers have access to personal data only as needed to perform their functions.

 

Examples of how we may share personal data with service providers include:

 

  • Providing our services
  • Payment processing and fraud prevention
  • Verification of your identity

 

  • Providing customer support
  • Sending marketing communications
  • Conducting research and analysis
  • Providing cloud computing infrastructure

 

Clients. We will transfer personal data about you to clients if you are providing services for one of such

client’s programs via the Arise® Platform.

 

Service Partners. We will share your personal data with the Service Partner you work for. We will also share your personal data with third party service partners (including other users of the Arise® Platform such as instructors or support resources) that are supporting you and your business as part of a client program you are servicing.

 

Third Party Services. The Arise® Platform may allow you to connect with other websites, products, or services that we don’t have control over. If you use these services, we will provide the third party with personal data about you to allow them to provide the service to you. We can’t speak to the privacy practices of these third parties, and we encourage you to read their privacy policies before deciding whether to use their services.

 

Other Sharing. We may share your personal data with third parties in the following cases:

 

  • While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets
  • If a government authority requests personal data and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process
  • With law enforcement officials, government authorities, or third parties if we think doing so is necessary to protect the rights, property, or safety of a client or its customers, Arise, other Service Partners or agents, or the public
  • To comply with a legal requirement or process, including but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures, or to prevent fraud
  • If you signed up for a promotion with a referral or promotion code, with your referrer to let them know about your redemption of or qualification for the promotion
  • To provide personal data about the use of the Arise® Platform to potential business partners in aggregated or de-identified form that can’t reasonably be used to identify you
  • Whenever you consent to the sharing

 

Communications

We may need to communicate with you for a variety of different reasons, including:

 

  • Responding to your questions and requests. If you contact us with a problem or question, we will use your personal data to
  • Sending you service and administrative emails and messages. We may contact you to inform you about changes in our services or the Arise® Platform, our offerings, and important service- related notices, such as client updates, security and fraud notices. These emails and messages are considered a necessary part of the services and you may not opt-out of

 

  • Sending emails about new products or other news about Arise that we think you’d like to hear about either from us or from our business partners. You can always opt out of these types of messages at any time by clicking the unsubscribe link at the bottom of each
  • Conducting surveys. We may use the personal data gathered in the surveys to enhance and personalize our platform, services, and
  • Offering referral programs and

 

Your Choices

We give you choices about the ways we collect, use, and share your personal data. Arise requests certain personal data from individuals registering to use the Arise® Platform to provide customer support and other services. If you do not provide the requested information in the registration process, we may be unable to complete your registration and allow you to provide customer support services. In instances other than the registration process, if you choose not to provide certain details, some of your experiences with us may be affected.

 

Email Subscriptions. You can always unsubscribe from our marketing and promotional emails but we will still send you service and administrative emails about your use of the Arise® Platform and servicing client programs. You can opt out of receiving marketing emails from Arise by clicking on the unsubscribe link at the bottom of any marketing email. To opt out of all other emails from Arise, email [email protected] Please include your name, the name of your service partner, your email address, and your User/CSP ID.

 

Text Messages. When you register to use the Arise® Platform to provide customer support and other services, Arise will request your consent to send you text messages. You can opt out of receiving all texts from Arise by editing your contact data in your profile in the Arise portal. Unselect the check box at the bottom left-hand side of the page that says “Check here to confirm your agreement to receive text messages from Arise” and save the change. After opting out of the text message feature, you will stop receiving text messages within 24 hours. If you are unable to login to the portal, please send an email to [email protected] withdrawing your consent to receive text messages. Please include your name, the name of your service partner, your phone number and your User/CSP ID.

 

Editing and Accessing Your Personal Data. You can review, update and edit certain account personal data by logging in to your profile. If you request, we may also provide you with information about whether a third party holds or processes any of your personal data on behalf of Arise. Please contact us if you need assistance in reviewing your personal data via [email protected] Arise will respond to your access request to review the personal data we have on file for you within a reasonable time. If you would like to limit the use of, disclosure of, or delete your personal data, please open a ticket with Partner Support or contact [email protected] You may request the limited use of your data including limiting the use related to marketing as set forth in this privacy policy. You may also request to halt

Arise’s use of, processing of, or onward transfer to third-party partners of your personal data.

 

If would like to terminate your account on the Arise® Platform, please open a ticket with Partner Support. If you choose to terminate your account, we will deactivate it for you but may retain personal data from your account for a certain period of time and disclose it in a manner consistent with our practices under this privacy policy for accounts that are not closed. We also may retain personal data from your account to collect any fees owed, resolve disputes, troubleshoot problems, analyze usage of

 

the Arise® Platform, assist with any investigations, prevent fraud, enforce our agreements, or take other actions as required or permitted by law.

 

Your Rights – Canada

If you are a resident of Canada, you have the right to: Access your personal data and rectify it; withdraw any consent provided; and where applicable, lodge a complaint with your supervisory authority.

 

Your Rights – European Union

If you are a citizen of the European Union or the United Kingdom, you have the following rights under GDPR: (i) request access to your personal data; (ii) request rectification of your personal data; (iii) request erasure of your personal data; (iv) request restriction of processing of your personal data; (v) request data portability; (vi) object to the processing of your personal data (including objection to profiling), and (vi) withdrawal of your consent at any time.

 

Your Rights – California

Under the California Consumer Privacy Act (CCPA), California residents have certain rights with respect to personal data about them we have collected. If you are a California resident, you may exercise the following rights regarding your personal data, subject to certain exceptions and limitations:

 

  • Right to access the personal data we have collected about you and learn how we collect this information, our purpose in collecting it, and the types of parties we may have disclosed it to
  • Right to delete the personal data we have collected from you
  • Right to opt-out of our sales of your personal data, if applicable
  • Right not to receive discriminatory treatment for the exercise of the relevant privacy rights conferred by the CCPA

 

In the past twelve months, we have not sold any personal information, nor do we intend to sell any personal information in the next twelve months.

 

Your Rights – Illinois

We collect and store biometric information from Illinois residents. Your biometric information will be retained for the purpose of verifying your identity, for security purposes or to detect fraud. It will be destroyed when it is no longer needed to verify your identity or to detect fraud or within three years of your last interaction with Arise, whichever occurs first.

 

Location of Data

Arise is headquartered in the United States of America and maintains a global infrastructure, as do many of the third-party service providers with whom we work. Personal data that we collect and maintain may be transferred to, or controlled and processed in, the United States and other countries around the world. When you provide us with personal data or use the Arise® Platform or our websites and services, you consent to this transfer. We will protect the privacy and security of personal data we collect in accordance with this privacy policy, regardless of where it is processed or stored.

 

EU Privacy Shield

We comply with the EU-US Privacy Shield Framework regarding the collection, use, and retention of personal data from European Union and the United Kingdom to the United States. We have self-certified that we adhere to the privacy shield principles as defined by the U.S. Department of Commerce

(“Privacy Shield Principles”). Although reliance on the Privacy Shield Principles as a legal basis for transfers of personal data was struck down by the Court of Justice of the EU in 2020, Arise has chosen to continue to continue our self-certification. This decision does not remove our obligations under the Privacy Shield Principles. For more information about the Privacy Shield Principals, and to view our certification, please visit https://www.privacyshield.gov/. If there is any conflict between the terms of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles will govern.

 

We commit to adhering to the Privacy Shield Principles and applies these to all of your personal data we collect. Arise includes the following entities: Arise Virtual Solutions Inc., Arise Virtual Solutions (Canada) Inc., Arise Virtual Solutions International Limited, Arise Virtual Solutions Limited and Officium Labs, Inc.

 

We will share your personal data with third parties. (See above “How We Share the Personal Data We Collect With Third Parties.”) Within the scope of our authorization to do so, and in accordance with our commitments under the Privacy Shield, we will work with any third-party partners to provide you access to your personal data we hold on behalf of our partners or held by our partners on our behalf. We also will take reasonable steps to enable you, either directly or in connection with our third-party partners, to correct, amend, or delete personal data that is demonstrated to be inaccurate. In accordance with the Privacy Shield Principles, we are liable for any processing of personal data by such third parties that is inconsistent with the Privacy Shield Principles unless we were not responsible for the event giving rise to any alleged damage. Our compliance with the Privacy Shield Principles is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

 

Please contact us at [email protected].com with any questions or concerns relating to our Privacy Shield certification. You have the option to resolve any applicable disputes you have with us in connection with our certification through the International Centre for Dispute Resolution by the American Arbitration

Association (“ICDR/AAA”), an alternative dispute resolution provider based in the United States. You can contact ICDR/AAA through their website http://go.adr.org/privacyshield.html. In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles.

 

Other Information

Data Security. We are committed to protecting your data. Even though we take reasonable precautions to protect your data, no security measures can be 100% secure and we cannot guarantee the security of your data. We recommend safeguarding your login and password, as this is one of the easiest ways you can manage the security of your own account – remember that if you lose control over your login or password, you may lose control over your personal data.

 

Data Retention. We will retain your personal data for as long as your account with us is active and then

(a) pursuant to our records retention schedules and practices, (b) to comply with our legal obligations,

(c) to resolve disputes, and (d) to enforce our agreements.

 

Children’s Privacy. We do not knowingly collect personal data from children under 18. If we find out that a child under 18 has given us personal data, we will take steps to delete that personal data. If you believe that a child under the age of 18 has given us personal data, please email us at [email protected]. For California residents, we do not knowingly collect information about children under the age of 13 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under the age of 13 has provided personal data through one of our websites, we will use reasonable efforts to remove that information from our databases.

 

Changes to Our Privacy Policy. We may make changes to this privacy policy from time to time. If we make any material changes, we will let you know by promptly posting the updated version. We encourage you to read this privacy policy periodically to stay up-to-date about our privacy practices. As long as you visit our websites or use the Arise® Platform, you are agreeing to this privacy policy and any updates we make to it.

 

Inquiry, Complaint and Dispute Process. You may contact Arise with any questions, concerns, or inquiries about this Privacy Policy or how we collect, retain, process, share and transfer your personal data. If you would like to make a formal complaint, please contact Partner Support or email us at [email protected] All complaints will be evaluated and a reply will be sent as soon as appropriate. In some instances, Arise may have to delete your registration on the Arise® Platform or otherwise cease services to you as necessary to satisfy your request.

 

 

 


Last Updated: January 3, 2022