Website and Mobile Application Privacy Policy

Arkera Inc. and its group companies (" Arkera", " we", " our", and " us") are committed to ensuring that your privacy is protected. This policy explains how and why we use the information we collect and receive on our website (the "Site") and our mobile application (the "App") and how you can tell us if you would prefer us not to use the information, or to limit its use. By using the Site or the App, you are consenting to our processing of your information in ways set out in this Privacy Policy.

About Us

We are Arkera Inc., a company incorporated under the laws of the state of Delaware in the U.S (company number 5129813). Our registered office address is at PHS Corporate Services, Delaware, 10022. Arkera Inc., is a wholly owned subsidiary of CarbonNV Limited.

Arkera is the data controller of any personal data you provide to us or that we collect about you when you use the Site and App.

We are registered with the Information Commissioner's Office (" ICO") under registration number ZA334752

Contacting Us

If you have any questions about our privacy policy or your information, or to exercise any of your rights as described in this privacy policy or under data protection laws, you can contact us:

By post: Arkera Inc., 30 Stamford Street, London, SE1 9LQ

By email: data-privacy@arkera.ai

Data Protection Principles

Arkera adheres to the following principles when processing your personal data:

  1. Lawfulness, fairness and transparency - data must be processed lawfully, fairly and in a transparent manner.
  2. Purpose limitation - data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  3. Data minimisation - data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  4. Accuracy - data must be accurate and, where necessary, kept up to date.
  5. Storage limitation - data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.
  6. Integrity and confidentiality - data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage by using appropriate technical or organisational measures.

Personal data we collect

Information you give us

You may provide us with information through the Site or on the App, when you:

The categories of personal data you provide may include:

When you register to use the App, an "ArkeraID" is created using your personal information. We will save your information and assign you with a personal Arkera ID.

We do not generally seek to collect sensitive personal data through our Site or App. Sensitive personal data is information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; health or sex life, sexual orientation; genetic data or biometric data. If we do collect sensitive personal data, we will ask for your explicit consent to our proposed use of that data at the time of collection.

Information we collect about you and your Device

Each time you visit our Site or use the App, we will automatically collect the following information:

We collect information from Instabug Inc., a third party.

Instabug takes device resource use. This includes phone storage, memory capacity of your handset and battery level

What we do with your personal data

We will only use your personal data if we have a legal basis for doing so, including:

  1. to comply with our legal and regulatory obligations;
  2. for the performance of our contract with you or to take steps at your request before entering into a contract;
  3. for our legitimate interests or those of a third party;
  4. where you have given consent to our specific use.

The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is further explained below.

Purposes for which we will process the information Legal Basis for the processing
To deliver services to users in accordance with our terms of use. It is necessary for us to process your personal data in order to deliver the services to you in line with our terms of use.
Customising the App and its content to your particular preferences / user profiling and analysing your content preferences. It is in our legitimate interests to develop and improve the App for our users. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
Marketing. It is in our legitimate interests to market our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
To notify you of any changes to the App or Site that may affect you. It is in our legitimate interests to ensure that any changes to the App or Site are communicated to you. We consider this use to be necessary for our legitimate interests and will
To provide you with information and services that you request from us. It is in our legitimate interests to respond to your queries and provide any information requested in order to generate and develop business. We consider this use to be proportionate and will not be prejudicial or detrimental to you.
  • To administer our Site and App including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To improve our Site and App to ensure that consent is presented in the most effective manner for you and your computer, Device or other item of hardware through which you access the Site and App; and
  • To keep our Site and App safe and secure.
For all these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the Site and App and to ensure network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you.

Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences by contacting us using the contact details set out above.

Arkera will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.

Marketing

You will receive marketing communications from us if you have requested information from us or registered to use the App and, in each case, you have not opted out of receiving that marketing. This can include information about services which may be of interest to you, details of events hosted by us and software updates.

If you would prefer not to receive any direct marketing communications from us, you can opt-out at any time by contacting us at unsubscribe@arkera.ai.

Disclosure of your personal data to third parties

Arkera will share your personal data with our group companies, affiliates and advisers as necessary to carry out the purposes for which the information was supplied or collected.

Personal data will also be shared with our third party service providers who assist with the running of the Site and App including marketing and others. Our third party service providers are subject to security and confidentiality obligations and are only permitted to process your personal data for specified purposes and in accordance with our instructions.

In addition, Arkera will disclose information about you:

International Transfers

We share your personal data within the Arkera group. This will involve transferring your data outside the European Economic Area (" EEA"). Some of our external third party service providers are also based outside of the EEA so their processing of your personal data will involve a transfer of data outside the EEA. This includes the USA and India.

Where personal data is transferred to and stored in a country not determined by the European Commission as providing adequate levels of protection for personal data, we take steps to provide appropriate safeguards to protect your personal data, including:

If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, please contact us using the details set out above.

Security of your personal data

Arkera use appropriate technical and organisational safeguards to protect personal data both online and offline from unauthorised use, loss or destruction. We use industry standard physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes encryption, firewalls, access controls, policies and other procedures to protect information from unauthorised access

Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal data.

Despite these precautions, however, Arkera cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal data. In the event of a data breach, Arkera have put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.

How long we keep your personal data

Your personal data will not be kept for longer than is necessary for the purposes for which it was collected and processed.

The criteria we use for retaining your personal data, includes the following:

Your rights

Access to and updating your personal data

You have the right to access information which we hold about you ("data subject access request"). You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another data controller ("data portability").

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. Please keep us informed if your personal data changes during your relationship with us.

Right to object

Direct marketing

You have the right to object at any time to our processing of your personal information for direct marketing purposes.

Where we process your information based on our legitimate interests

You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Your other rights

You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.

In certain circumstances, you have the right to:

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

Exercising your rights

You can exercise any of your rights as described in this privacy policy and under data protection laws by contacting us as provided in "Contacting us" above.

Save as described in this privacy policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

Cookies

In order to improve the Site and App, we may use small files commonly known as "cookies". A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or Device from the Site and App and is stored on your Device's browser or hard drive. The cookies we use on the Site and App won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your Device to third parties.

By continuing to browse the Site and App, you are agreeing to our use of cookies.

If you don't want us to use cookies when you use the Site and App, you can set your internet browser not to accept cookies. However, if you block cookies some of the features on this Site and App may not function as a result.

You can find more information about how to manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your Device.

Please note that we do not currently recognize or respond to browser-initiated Do Not Track signals, as the Internet industry has not reached a consensus as to Do Not Track standards, implementations and solutions

We currently set the following cookies:

Cookie Purpose
Customer's (App) data Your data is stored only within the App and in our database

We only use "Google Analytics" on the Site and App. This cookie provides us with a visitor count and an understanding of how visitors move around and use the website. We can then use this information to improve navigability and the Site and App generally. The cookies we use on the Site and App won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your Device to third parties.

Visitors to our Site can adjust their browsers to refuse cookies but if not adjusted, the Site will deliver the cookie as soon as the Site is visited. You can find more information about how to manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your Device.

We are obliged by Google Analytics to state the following:

This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Links

The Site and App contain links to and from the websites of third parties.

If you follow a link to any of these websites, please note that these websites have their own privacy policies and Arkera does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

Children

The Site and App are not intended for children under the age of 18 and we do not knowingly collect data relating to children. Children below the age of 18 are not permitted to use the App under the Terms of Use. If we become aware that data has been collected from a person under the age of 18, we will delete this data and terminate the person's account as quickly as possible. If you believe that we may have data from or about a child under the age of 18, please contact us at data-privacy@arkera.ai and we will promptly delete that information.

Complaints

If you have concerns about our use of your personal data, please send an email with the details of your complaint to data-privacy@arkera.ai. We will aim to respond to your concerns within 30 days. You also have the right to complain to the Information Commissioner's Office

Your California Privacy Rights

California Civil Code Section 1798.83 permits users of our Site or App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to data-privacy@arkera.ai.

Changes to our privacy policy

Arkera reserves the right to change this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. We will post a prominent notice on the website to notify you of any significant changes to our privacy policy, or update you by other appropriate means.

This privacy policy was last updated on. 04/05/2018.