By accessing or using this site, you agree to the Terms and Conditions, Privacy Notice, Cookie Info, SMS and MMS Terms, and any other policies and notices listed below.

Terms and Conditions, Privacy Notice, Cookie Info, and SMS and MMS Terms and Conditions.

1. Terms and conditions

Ara Foundation ("Ara Foundation", "Ara", "we" or "us") provides the content on this Web site (the "site") subject to the following Terms and Conditions ("terms"). By accessing and using this site, you agree to these terms. We may periodically change the terms, so please check back from time to time. You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes in any revised terms by your continued use of the site after the date such revised terms become effective. For an explanation of Ara Foundation's practices and policies related to the collection, use, and storage of our users' information, please read our Privacy notice.

1.1. Site content and use

All content and functionality on the site, including text, graphics, logos, icons, and images and the selection and arrangement thereof ("site content"), is the exclusive property of Ara Foundation, its affiliates or its licensors and is protected by US and international copyright laws. The trademarks, service marks, designs, and logos (collectively, the "trademarks") displayed on the site are the registered and unregistered trademarks of Ara Foundation, its affiliates and its licensors. All rights not expressly granted are reserved.

Any reproduction or redistribution of the site content and functionality displayed on the site in whole or in part, is expressly prohibited by law, and may result in criminal or civil fines. You may not reproduce, modify, distribute, transmit, post, or disclose the site content without Ara Foundation's prior written consent.

You agree that you will not refer to or attribute any site content to Ara Foundation or its affiliates or licensors in any public medium (e.g., press release, social media post, app notification, websites) for advertising or promotion purposes or for the purpose of informing or influencing any third party, and that you will not use or reproduce any trademark of, or imply any endorsement by or relationship with, Ara Foundation or its affiliates or licensors.

You agree that you will not (a) use the site in any way that (i) is, or may be, damaging to the site; (ii) impacts user access to the site or interferes with, disrupts, or creates an undue burden on the site or the networks or services connected to the site; or (iii) is contrary to applicable laws and regulations, or in a way that causes, or may cause, harm to the site, or to any person or business entity; (b) access the site through automated or non-human means, whether through a bot, script, or otherwise; circumvent, disable, or otherwise interfere with security-related features of the site, including features that prevent or restrict the use or copying of any site content or enforce limitations on the use of the site and/or the site content contained therein; (c) use the site as part of any effort to compete with us or otherwise use the site and/or the site content for any revenue-generating endeavor or commercial enterprise; (d) decipher, decompile, disassemble, or reverse engineer any of the software comprising or in any way making up a part of the site (e) upload or transmit (or attempt to upload or to transmit) viruses, Trojan horses, or other material that interferes with any party's uninterrupted use and enjoyment of the site or modifies, impairs, disrupts, alters, or interferes with the use, features, functions, operation, or maintenance of the site or (f) disparage, tarnish, or otherwise harm, in our opinion, us and/or the site.

1.2. Notices of infringement

Ara Foundation prohibits the posting of any content that infringes or violates the copyright rights and/or other intellectual property rights (including rights of privacy and publicity) of any person or entity. If you believe that your intellectual property right (or such a right that you are responsible for enforcing) is infringed by any content on the site, please write to Ara Foundation at the address shown below, giving a written statement that contains: (a) identification of the copyrighted work and/or intellectual property right claimed to have been infringed; (b) identification of the allegedly infringing material on the site that is requested to be removed; (c) your name, address, and daytime telephone number, and an e-mail address if available; (d) a statement that you have a good faith belief that the use of the copyrighted work and/or exercise of the intellectual property right is not authorized by the owner, its agent, or the law; (e) a statement that the information in the notification is accurate, and, under penalty of perjury, that the signatory is authorized to act on behalf of the owner of the right that is allegedly infringed; and (f) the signature of the intellectual property right owner or someone authorized on the owner's behalf to assert infringement of the right. Ara Foundation will remove any posted content that infringes the copyright or other intellectual property right of any person under US law upon receipt of such a statement (or any statement in conformance with 17 USC § 512(c)(3)).

1.3. Disclaimers

THE CONTENT AND FUNCTIONALITY ON THE SITE IS PROVIDED WITH THE UNDERSTANDING THAT ARA FOUNDATION IS NOT HEREIN ENGAGED IN RENDERING PROFESSIONAL ADVICE AND SERVICES TO YOU. ALL CONTENT AND FUNCTIONALITY ON THE SITE IS PROVIDED "AS IS," WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. ARA FOUNDATION AND ITS THIRD-PARTY CONTENT PROVIDERS MAKE NO WARRANTIES, EXPRESS OR IMPLIED, AS TO THE OWNERSHIP, ACCURACY, OR ADEQUACY OF THE SITE CONTENT. ARA FOUNDATION SHALL HAVE NO LIABILITY OR RESPONSIBILITY FOR ANY INFORMATION PUBLISHED ON LINKED WEB SITES, CONTAINED IN ANY CONTENT PUBLISHED ON THE SITE, OR PROVIDED BY THIRD PARTIES. NEITHER ARA FOUNDATION NOR ITS THIRD-PARTY CONTENT PROVIDERS SHALL BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES OR FOR LOST REVENUES OR PROFITS, WHETHER OR NOT ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES AND REGARDLESS OF THE THEORY OF LIABILITY.

1.4. Third party websites

We may provide links to third party sites ("third party sites"), and some of the content appearing to be on this site is in fact supplied by third parties ("third party content"), for example, in instances of framing of third party sites or incorporation through framesets of content supplied by third party servers. Such third party sites and third party content are not investigated, monitored, or checked for accuracy, appropriateness, or completeness by us, and we are not responsible for any third party sites accessed through the site or any third party content posted on, available through, or installed from the site, including the content, accuracy, offensiveness, opinions, reliability, privacy practices, or other policies of or contained in the third party sites or the third party content. Inclusion of, linking to, or permitting the use or installation of any third party sites or any third party content does not imply approval or endorsement thereof by us. If you decide to leave the site and access the third party sites or to use or install any third party content, you do so at your own risk, and you should be aware these terms no longer govern.

1.5. Indemnification

You agree to defend, indemnify, and hold us harmless, including our subsidiaries, affiliates, and all of our respective officers, agents, partners, and employees, from and against any loss, damage, liability, claim, or demand, including reasonable attorneys' fees and expenses, made by any third party due to or arising out of: (a) your use of the site; (b) your breach of these terms or (c) your infringement of any intellectual property or other right of anyone.

Notwithstanding the foregoing, we reserve the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify us, and you agree to cooperate, at your expense, with our defense of such claims. We will use reasonable efforts to notify you of any such claim, action, or proceeding which is subject to this indemnification upon becoming aware of it.

1.6. Governing law; Jurisdiction

You agree that these terms and any claim, dispute or controversy (whether in contract, tort or otherwise, whether preexisting, present or future, and including statutory, common law and equitable claims) between you and Ara Foundation arising from or relating to these terms, its application, interpretation or breach, termination or validity, the site, or any related transaction, shall, to the maximum extent permitted by applicable law, be governed by the laws of the state of Wyoming, without regard to its conflicts of laws rules. You agree that all claims you may have arising from or relating to the operation, use or other exploitation of the site will be heard and resolved in the federal and state courts located in the State of Wyoming. Any claim or cause of action arising out of or related to your use of the site must be filed within one year after such claim or cause of action arose, regardless of any statute or law to the contrary. In the event any such claim or cause of action is not filed within such one year period, such claim or cause of action shall be forever barred.

2. Privacy notice

Ara Foundation ("Ara Foundation", "Ara", "we", "us", or "our") is an interactive agency providing web development, media planning and buying, technology and innovation, emerging media, analytics, mobile, advertising, creative, social influence marketing, and search services to our clients. This privacy notice ("notice") sets out how we collect, use, share, and protect any information we collect through this website ("site"). This notice also explains the measures we take to safeguard your information and describes how you may contact us regarding our privacy practices.

Please note, this notice does not apply to the services provided by us on behalf of clients or to data that the agency processes on behalf of our clients.

2.1. Introduction

Any data collected through this site, including personal data (as defined under applicable data protection laws, referred to as "personal data" or "data"), will only be used for the purposes set out in this notice. Notwithstanding, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. When data is collected on this site, Ara Foundation is acting as a data controller.

Please read this privacy notice thoroughly. If you disagree with the way personal information will be used, please do not use this site. For our Canadian users, your use of the site constitutes your implied consent for us to process your data for the above-noted purposes.

We may include links to other sites, including social media platforms. This notice only covers this site and does not apply to the data practices of other sites. We encourage you to read the privacy notices available on other sites you visit.

2.2. What personal data and sensitive personal information do we collect and process through the site?

The following list describes the categories of Personal Data ("personal data", "data") and Sensitive Information ("sensitive information") we collect, and examples of that data and sensitive information.

Contact information and identifiers, such as: first name, last name, email address, and telephone number, and online identifiers, such as IP address, browser information, and mobile ad identifiers.

Professional or employment information (may be B2B contact information), such as: your employer or company, title, or department.

Internet or other electronic network activity information (technical data) such as: browsing history, search history, and online interests, such as: information about categories of consumer interests derived from online usage, and information on a consumer's interaction with a site, application, or advertisement.

General geolocation data such as: non-precise location information from your device or IP address.

Your communications to us such as: information that you send us directly.

Inferences such as information drawn from any of the information identified in this section to create an attribute about your preferences, characteristics, or behavior.

2.3. Categories of the sources of data we may collect:

We may collect the personal data outlined above from the following categories of sources:

• Directly from you, for example, when you send us your questions or comments using the query form or make use of your privacy rights.

• From publicly available sources, data brokers, partners (e.g., that offer co-branded services, sell or distribute our products, or engage in joint marketing activities), advertising networks, internet service providers, data analytics providers, operating systems, and social networks.

• Indirectly from you by using automated technologies, such as cookies, pixels, third party tags, scripts, log files, and other means to automatically collect information about the use of our site.

Further information about our use of cookies can be found in this privacy notice, and from our Cookie info.

2.4. Purpose of data collection and legal basis

The following list provides information about our purposes and legal basis for collecting your personal data, specifically, our purposes for collecting and using your personal data, and our basis for processing.

Purpose: When you contact us through the data access request form. Basis: We rely on our legal obligation to provide you with a process to exercise your rights.

Purpose: To contact you where you have indicated you wish to receive news from us. Basis: For visitors from the European Union, we rely on your consent, where you indicate that you want to receive marketing material from us.

Purpose: Operating our site, for example, operating, analyzing, improving, and securing our site. Basis: For visitors from the European Union, we rely on your consent to obtain your personal data through cookies. For visitors from other geographies, we rely on our legitimate interest to improve our services and develop new products.

Purpose: Marketing services, for example: assisting in targeting and optimizing of direct mail and email campaigns, display, mobile and social media marketing; Measuring the effectiveness of online or offline ad campaigns by determining which messages are most likely to be seen or opened by which types of clients and potential clients, or which types of ads are most likely to lead to purchases; Analyzing and optimizing our (or our service providers') proprietary databases or helping us identify and mitigate potential fraud; and providing "verification" or data "hygiene" services, which is how companies update and/or "clean" their data by either verifying or removing or correcting old, incorrect or outdated information. Basis: For visitors from the European Union, we rely on your consent to use your personal data for marketing services.

Purpose: Online targeting, for example: creating or helping to create defined audience segments based on common demographics and/or shared (actual or inferred) interests or preferences. When we do this, we work with a data partner that "matches" our or other information through de-identification techniques (such as through coded data or cryptographic "hashing") with site activity identifiers, in order to target and measure ad campaigns online across various display, mobile and other media channels; creating "identity" graphs, to help locate users across various channels, such as connecting identities based on common personal, device-based, or network-based identifiers (e.g., IP address, email address). Basis: For visitors from the European Union, we rely on your consent to use your personal data for online targeting.

Purpose: Other internal purposes, such as: internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. Basis: Our legitimate interest to support our internal operations and conduct research.

Purpose: Legal purposes, such as: (a) comply with legal process or a regulatory investigation (e.g. regulatory authorities' investigation, subpoena, or court order); (b) enforce our terms of Service, this privacy notice, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of other parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. Such disclosure may be for a business purpose, but may also be considered a "sale" under certain state privacy laws. Basis: We rely on our legal obligation or the performance of contract to support such legal purposes.

Purpose: In the event of a corporate transaction including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction. Basis: Our legitimate interest or performance of contract to support our corporate transactions.

Purpose: We may aggregate, de-identify and/or anonymize any information collected so that such information can no longer be linked to you or your device ("aggregate or de-identified information"). We may use aggregate or de-identified information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any other party, including advertisers, promotional partners, and sponsors, in our discretion, unless otherwise prohibited by applicable law. Basis: Our legitimate interest to support our internal operations.

Purpose: We use analytics services, such as Google Analytics, to help us understand how users access and use the site. Basis: Our legitimate interest to support our internal operations.

2.4.1. Interest-based advertising

We work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other sites and services. For example, we place ads through Google, Facebook, Twitter, and LinkedIn, that you may view on their platforms as well as on other sites.

2.4.1.1. How we engage in target advertising or cross-context behavioral advertising

As part of this process, we may incorporate tracking technologies into our own site as well as into our ads displayed on other sites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and/or other content to you ("interest-based advertising"). Interest-based advertising is also called targeted advertising or cross-context behavioral advertising

We also use audience matching services to reach people (or people similar to people) who have visited our site or are identified in one or more of our databases ("matched ads"). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our own site, and the other party matching common factors between our data and their data or other datasets. For instance, we incorporate the Facebook pixel on our site and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

As indicated below, vendors and other parties may in certain contexts independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

2.5. With whom do we share or sell personal data or sensitive personal data?

We may disclose your personal data collected and processed through this site for various purposes related to our business. The disclosure may be to our clients, partners, or vendors.

Sharing personal data under the California Privacy Rights Act means to disclose your personal data to a third party for Interest-based Advertising.

Selling personal data means to disclose your personal data to a third party for an exchanged value and a purpose other than one of the listed business purposes below.

The following list shows with whom we may share or sell your personal data, and whether we believe we have "sold" or "shared" a particular category of information in the prior 12 months.

• We have not sold or shared contact information and identifiers with analytics partners, service providers, affiliates in the last 12 months.

• We have not sold or shared professional or employment information (may be B2B contact information) with analytics oartners, service providers, affiliates in the last 12 months.

• We have not sold or shared Internet or other electronic network activity information with analytics partners in the last 12 months.

• We have not sold or shared geolocation data with analytics partners in the last 12 months.

• We have not sold or shared your verbatim communications to us with service providers, analytics partners, affiliates in the last 12 months.

• We have not sold or shared inferences with service providers, analytics partners in the last 12 months.

2.6. With whom do we disclose personal data or sensitive personal data for a business purpose?

We may disclose your personal data or sensitive information to our service providers that assist us with our business purposes. Our service providers are to only process your personal data in accordance with our instructions and only for the purpose listed below.

The list below shows with whom we disclose your personal data for the specific business purpose(s). Specifically outlined are the category of personal data, the categories of parties with whom we disclosed your data for a business purpose, and the business purpose for the disclosure.

Data: Contact Information and Identifiers. Parties: Analytics Partners, Service Providers, Affiliates. Purpose: Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Controller, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Controller.

Data: Internet or other electronic network activity information. Parties: Analytics Partners, Service Providers. Purpose: Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Controller, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Controller.

Data: Geolocation data. Parties: Analytics Partners. Purpose: Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Controller, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Controller.

Data: Your verbatim communications to us. Parties: Service Providers, Analytics Partners, Affiliates. Purpose: Depending on your request, we will rely on our legitimate business interest or the performance of pre-contractual measures to respond to individuals' queries and helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes.

Data: Inferences. Parties: Service Providers, Analytics Partners. Purpose: Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the Controller, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the Controller.

2.7. Automated decision making and profiling

To the extent that we use processes that involve automated decision-making or profiling when processing your personal data, we take steps to ensure that any automated decision-making or profiling practices are fair and not discriminatory.

2.8. How long do we keep your information?

We keep personal data for as long as is necessary for the purposes described in this privacy notice, complying with legal and regulatory obligations, protecting our or other's interests, and as otherwise permitted or required by law. When personal data is no longer necessary for or compatible with these purposes, it is removed from our systems in accordance with our internal retention policies. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the site or our services to you;

• Whether our processing of the personal data is consistent with what an average consumer would expect when the personal data was collected;

• Whether the personal data is processed for any other disclosed purpose(s) compatible with what is reasonably expected by the average consumer;

• Whether the personal data is relevant and useful to the provision of our services and our further processing is permitted by law;

• Whether the personal data has been de-identified, anonymized, and/or aggregated; and

• Whether there is a legal obligation to which we are subject.

2.9. Your rights and choices regarding your personal data

Please email [email protected] if you want to make use of any of your below-mentioned legal rights.

2.9.1. Where you are a resident of the EU

Subject to certain exceptions and the jurisdiction in which you live, if you are a resident of the EU, the GDPR provides you with specific rights regarding your personal data. This subsection describes your rights and explains how to exercise those rights regarding personal data that we hold about you. These rights include:

2.9.1.1. The right of access

You can access all personal data we hold about you, know the origin of this personal data and obtain a copy in an understandable format. You may also use your right to access your personal data to control the exactness of the data and have them rectified or deleted. You have no justification to provide to exercise your right to access;

2.9.1.2. The right to rectification

In order to avoid inaccurate or incomplete personal data relating to you is processed or shared, you can ask us to rectify them;

2.9.1.3. The right to erasure

You may request the erasure or deletion of the personal data we hold on you. This is not an absolute right since we may have to keep your personal data for legal or legitimate reasons. You may, for example, exercise your right to deletion in the following cases:

• if you have withdrawn your consent to the processing (see below);

• if you legitimately objected to the processing of your data (see below);

• when data is not or is no longer necessary for the purposes for which it was initially collected or processed;

• the data is processed unlawfully (e.g., publishing hacked data);

2.9.1.4. The right to object to the processing of your personal data

We process your personal data based on our legitimate interest (to determine to which processing this applies, please refer above in this privacy notice), you may at any time object to the processing of your personal data for reasons relating to your personal situation. We may nevertheless, on a case-by-case basis, reject such a request by pointing out the legitimate and imperious reasons justifying the processing of this data which prevail on your interests, rights and freedoms, or when this data is necessary to establish, exercise or defend a right before a Court.

2.9.1.5. The right to restrict processing

The right to limit the processing completes your other rights. This right means that the data processing relating to you and that we are performing is limited, so we may keep this data, but we cannot use it or process it in any other manner. This right applies in specific circumstances, i.e.:

• if you challenge the exactness of your personal data. The processing is then limited for a period of time so that the agency may verify the exactness of the personal data;

• if the processing is unlawful and you object to the erasure of your personal data and request instead that its use be limited;

• if we do not need the personal data for the purposes mentioned above anymore, but you still need it to establish, exercise or defend rights before a Court; and

• in the cases where you objected to the processing which is based on the legitimate interests of the agency, you may ask to limit the processing for the time necessary for us to verify if we can accept your objection request (i.e., the time necessary to verify whether the legitimate reasons of the agency prevail over yours).

2.9.1.6. The right to object to data processing for direct marketing purpose

You may unsubscribe or object, at any time and without any justification, to the reception of direct marketing communications. Simply either (a) reply STOP to a SMS text message you receive from us; (b) click on the link in the footer of the email communications you receive from us; or (c) send us an email at [email protected] with the word unsubscribe in the subject field of the email.

2.9.1.7. The right to data portability

• You may request to retrieve the personal data you provided us with, in a structured, commonly used, and machine-readable format, for personal use or to share them with a third party of your choice.

• This right only applies to personal data you provided us with, directly or indirectly, and which was processed through automated means, if this processing is based on your consent or the performance of a contract.

Please check the list of our personal data processing activities' legal grounds to know whether our processing is based on the performance of a contract or on consent.

2.9.1.8. The right to withdraw your consent to the processing of your personal data at any time

• You may read earlier sections of this privacy notice to identify the purposes for which the processing of your personal data is based on your consent.

• If you are unsatisfied with the way we process your personal data or if your request has been rejected, you may also lodge a formal complaint with your local competent data protection authority.

• Personal data will be stored in accordance with our applicable data retention requirements and corporate policies. The retention period for personal data varies depending on the type of personal data and the purposes of processing it.

• We will respond without undue delay from the data we receive your request. Response time can be extended to take the complexity of the request, or the number of requests received into account. In this case, we will inform you specifying the reasons for extending the response timeframe.

2.9.2. Where you are a US resident

Residents of certain US states, such as California, Virginia, Colorado, Connecticut, and Utah, have specific rights regarding their personal data. This section describes how to exercise those rights and our process for handling those requests. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

2.9.2.1. Right to request access to your personal data

You may request access to your personal data that we collect, use, disclose, or sell. In particular, you may request:

• the specific pieces of personal data that we process about you;

• the categories of personal data we have collected about you;

• the categories of sources from which the personal data was collected;

• the categories of personal data about you we disclosed for a business purpose or sold or shared;

• the categories of third parties to whom the personal data was disclosed for a business purpose or sold or shared; and

• the business or commercial purpose for processing the personal data.

When exercising the right to access personal data, you have the right to obtain materials in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

When we receive and verify your request to access your personal data, we will make best efforts to fulfill your request unless an exception applies. We will not disclose your government identification numbers, financial account numbers, health insurance or medical identification numbers, account passwords, security questions and answer, or unique biometric data; however, to the extent we have this information, we will inform you that we have collected this information. You are permitted 2 access reports every 12 months.

2.9.2.2. Right to request deletion of your personal data

You may also request that we delete any personal data that we obtained about you. However, we may retain personal data for certain important purposes, as set out by applicable law.

When we receive and verify your request to delete your personal data, we will proceed to delete the data unless an exception applies. We will retain a record of your deletion request in order to keep your personal data deleted, unless and until you provide consent for the processing of your personal data post your deletion request.

2.9.2.3. Right to correct your personal data

If you believe we hold inaccurate personal information about you, you may request that we correct that information. We may ask for documentation showing that the information you submit is accurate and the personal data we hold is inaccurate. Once we receive your request, we will verify your identity and taking into account the type of personal information and the purposes of our holding that personal information we will make best efforts to complete your request. We may deny your request if we determine that the contested personal data is more likely than not accurate. Additionally, we may choose to delete your personal data in response to your request to correct your personal data if the deletion of your personal data would not negatively impact you.

2.9.2.4. Right to limit use of sensitive personal data

We do not collect sensitive personal data as that term is defined in US state privacy laws like the California Consumer Privacy Act and the Virginia Consumer Privacy Act. You may request that we limit the use and disclosure of sensitive personal data. However, we may deny your request in part of in full under uses authorized by applicable law.

2.9.2.5. Right to nondiscrimination

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise your privacy rights.

2.9.2.6. Right to opt-out of the sale of your personal data

Depending what information we have about you, and whether we have disclosed any of it to a third party in exchange for valuable consideration, we may have sold (as defined by US state laws) certain personal data about you, as described in the above list in this privacy notice.

2.9.2.7. Right to opt-out of share/cross contextual behavioral advertising and targeted advertising

You may opt-out of the processing or sharing of your personal data for cross-contextual behavioral advertising or targeted advertising (what we refer to above as Interest-based Advertising).

Additionally, you may choose not to receive targeted advertising from ad networks, data exchanges, and other digital advertising providers by opting out of targeted advertising.

2.9.2.8. Right to opt-out of automated decision making and profiling

It's your right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

2.9.2.9. Universal opt-out mechanisms

Our site recognizes certain global opt-out of sale and share preference signals like the Global Privacy Control and the IAB CCPA privacy string/MSPA privacy string. This means that if you enact your choice to opt-out or opt-in through these signals, we will honor your choice upon receiving the signal related to your visit on our site. We will apply your preference to the personal data we collected from our site. If you have previously provided affirmative consent for the sale or share of your personal data, and your opt-out choice via the signal conflicts with such consent, we will ignore the opt-out choice via the signal.

2.9.2.10. Shine the light

Customers who are residents of California may request (a) a list of the categories of personal data disclosed by us to third parties during the immediately preceding calendar year for those third parties' own direct marketing purposes; and (b) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in the section Further Information below and specify that you are making a California Shine the Light Request.

2.9.2.11. How to exercise your US state privacy rights

US residents may exercise their applicable privacy rights by sending an email to [email protected].

For security purposes, and as required under US state laws, we will verify your identity, in part by requesting certain information from you, when you make a request to access, correct, or delete, your personal data. The verification process may use verification processes based on email, telephone, a request for an assigned ID number or similar data previously communicated to you, or a combination of these and similar secure methods.

If we are unable to complete your request fully for any reason, we will provide you additional information about the reasons why we could not comply with your request.

You may also designate an agent to make requests to exercise your rights under certain US state laws. We will take steps both to verify your identity and to verify that your agent has been authorized to make a request on your behalf by requesting your agent to provide us with a signed written authorization or a copy of a power of attorney executed by you.

2.9.2.12. Appeal

It is your right to appeal a decision made concerning the exercise of your data privacy rights. You may appeal this decision within 60 days of receiving your response from us. To submit your appeal, contact [email protected].

2.9.2.13. Where you are a Nevada resident

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal data that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal data for monetary consideration by the business to a third party for the third party to license or sell the personal data to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us at [email protected].

2.9.3. Where you are a resident of Canada

2.9.3.1. Right to request access to your personal data

You have a right to access your personal data in our control. We will also provide you with a description of what uses we have made of your personal data and which third parties we have shared it with. In some cases, we may not be able to provide you with access to your personal data, such as where:

• Personal data about another person might be revealed and the other person's personal information cannot be separated from yours;

• Commercially confidential information might be revealed and the confidential information cannot be separated from yours;

• The requested data is subject to solicitor and client privilege;

• Someone's physical or similar safety or security might be threatened as a result of giving you access and the personal data about the other person cannot be separated from yours;

• The information was collected for purposes related to an investigation of a breach of an agreement or contravention of the law.

2.9.3.2. Right to request correction to your personal data

If you note any inaccuracies or wish to update any of your personal data, we will make those changes upon your request.

2.9.3.3. Right to withdraw your consent

At any time, you may withdraw your consent for us to process your personal data for the purposes described in this privacy notice. However, this may affect our ability to offer you some of the services. For example, we may not be able to respond to your queries.

2.9.4. Your general rights regarding data collection

2.9.4.1. Do not track

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, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to Do Not Track signals.

2.9.4.2. Analytics

We may use our own technology or third party technology to track and analyze usage information to provide enhanced interactions and more relevant communications and to track the performance of our advertisements.

For example, we use Google Analytics ("Google Analytics"), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, US. You can learn about Google's privacy practices by going to www.google.com/policies/privacy/partners/.

Google Analytics uses cookies to help us analyze how our sites are used, including the number of visitors, the sites from which visitors have navigated to our sites, and the pages on our sites to which visitors navigate. This information is used by us to improve our sites. We use Google Analytics with restrictions on how Google can process our data enabled. For information on Google's Restricted Data Processing go to privacy.google.com/businesses/rdp/.

2.9.4.3. Interest-based advertising

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance ("DAA") and/or the Network Advertising Initiative ("NAI"). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (a) for site targeted ads from DAA participants, www.aboutads.info/choices; (b) for app targeted ads from DAA participants, www.aboutads.info/appchoices; and (c) for targeted ads from NAI participants, www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, it does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants' other customers or from other technology services).

To opt out of us using your data for Matched Ads, please contact us at [email protected] and specify that you wish to opt out of matched ads. We will request that the applicable party not serve you matched ads based on the information we provide to it. Alternatively, you may contact the applicable party directly to opt out.

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with any opt out options or programs, or the accuracy of any other entities' statements regarding their opt out options or programs.

2.9.4.4. Email and SMS messages

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or by emailing us at [email protected] with the word Unsubscribe in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about identity, such as One-Time Password (OTP) codes, transactions, servicing, or our ongoing business relations.

You can opt-out of receiving SMS messages from us at any time by replying STOP to a message we sent. Please note that, at a user's requested and optional choice, we use SMS messages for user identity and sign-in. Please only reply STOP if you do not wish to use this sign-in feature, and other account security features that use it, and have configured your account to be secure and accessible by you using other methods, like email and password.

2.10. Children

The site is intended for general audiences and is not directed at children. We do not knowingly collect personal data (as defined by the U.S. Children's Privacy Protection Act, or "COPPA") from children. If you are a parent or guardian and believe we have collected personal data in violation of COPPA, contact us at [email protected]. We do not knowingly sell, as that term is defined under the US state privacy laws, like CCPA or VCDPA, the personal data of minors without legally required affirmative authorization.

2.11. Data security

We use a variety of methods, such as encryption, firewalls, intrusion detection software and manual security procedures, designed to secure your data against loss or damage and to help protect the accuracy and security of information and to prevent unauthorized access or improper use. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. If you think that the site or any personal data is not secure or that there has been unauthorized access to the site or your personal data, please contact [email protected] immediately.

2.12. Data transfers

Due to the international nature of our business, your personal data may be transferred outside the European Union. If you are an EU resident, your personal data may be transferred to the US or any country which is not considered to have the same level of data protection as in the EU. While in those jurisdictions, your personal data may be accessible to regulatory authorities in accordance with the laws of those jurisdictions. However, we ensure all data transfers from the EU comply with applicable legal requirements by executing standard contractual clauses. Should you wish to know more about how your personal data is protected or wish to request a copy of the contractual protections please contact [email protected].

2.13. Use of cookies, other tracking technology, social media and social media plug-ins

Cookies are small pieces of digital information sent to your device when you visit the site. Cookies are used to optimize the user experience, count visitors to a page, troubleshoot problems, keep sites secure, and better serve content. The following cookies are used on the site:

Strictly Necessary cookies are required to provide the basic functions of the site and cannot be turned off. They are essential for accessing certain features of the site and could include signing in, seeing or editing your information and the information you should be able to access, or billing.

Performance cookies are used to identify the pages used and to measure and track the performance of our site. This helps us to analyze page traffic data and improve our site to fit your needs. We only use the information for statistical analysis purposes.

Functional cookies are used to provide services you request. These cookies can remember your preferences to boost the user experience on a site.

Targeting cookies may be set by us or by our advertising partners. They may be used to build a profile of your interests and show you relevant advertisements on this site or others. They do not store personal information but are based on uniquely identifying your browser. If you do not allow these cookies, you will experience less relevant advertising.

Overall, cookies help us provide you with a better site, by enabling us to monitor which pages you find useful and which you do not. Most web browsers automatically accept cookies, but you can choose browsers and modify browser settings to decline cookies if you prefer. This may prevent you from taking full advantage of the site.

For more information about the cookies we use, please review the cookie notice.

2.14. Use of social media and social media plug-ins

Ara Foundation has a user page or a company page on social media platforms like X (previously Twitter), Facebook, Instagram, YouTube, and LinkedIn that you can use or visit. Ara Foundation acts as a joint data controller with the social media platform for the collection of your personal data when you visit our company page on the social media platform. We will collect personal data about you in order to understand our followers better and understand the public response to our products and services. We may use this information to send you marketing information that we think may be of interest to you and engage in social listening to identify and assess what is being said about us publicly to understand industry trends and market sentiment. Any information you provide to us when you engage with our content (such as through our brand page or via Facebook Messenger) is treated in accordance with this privacy notice. Also, if you publicly reference us or our site on social media (such as by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our site.

You can read more regarding our joint controllership with the platforms at the following links:

• Facebook: www.facebook.com/legal/controller_addendum

• Instagram: www.facebook.com/legal/controller_addendum

• LinkedIn: legal.linkedin.com/pages-joint-controller-addendum

• X (formerly Twitter): gdpr.twitter.com/en/controller-to-controller-transfers.html

• YouTube: business.safety.google/controllerterms/

We provide social media plug-ins on our site to allow you to easily share content from our site through social media, and in doing so, we may receive your personal data from the social media platform that you have authorized to share with us. When you share content using these buttons, a new page will pop up from the relevant social media platform. If you're already logged into your account on that social media platform, then you will probably be automatically logged into this pop-up page, so that you don't have to log in again. If, however, you are not logged in (or if you are not registered with the social media platform), the page will ask you for your information. Ara Foundation is joint data controllers with the social media platforms for the collection of your personal data that is collected by the platforms when you visit our site.

We have no control over how social media platforms use your personal data and they may independently collect information about you when you are not on our site. The information collected and stored by those parties 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 US or elsewhere. We encourage you to read the privacy notices on the various social media platforms and third party sites and apps you use.

2.15. Financial incentive

We do not offer any financial incentives related to our collection of your personal data.

2.16. Notification of changes

Any changes to this privacy notice will be promptly communicated on this page and you should check back to see whether there are any changes. Continued use of the site after a change in the privacy notice indicates your acknowledgment and acceptance of the use of personal data in accordance with the amended privacy notice.

2.17. Further information

This privacy notice has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at [email protected].

If you consider that we are not complying with this privacy notice, if you have any questions in relation to this privacy notice, or have questions about your rights and choices, please contact [email protected]. Data subjects in Europe may also lodge a formal complaint with their competent data protection authority.

If you have any questions about our data practices or you wish to exercise your rights or know about the contractual protections in place, please contact [email protected].

3. Cookie info

3.1. Cookie notice

This Ara Foundation website ("site") is edited and hosted by Ara Foundation ("Ara Foundation", "Ara", "we", "us", "our"), whose registered office is located at 2425 Canyon Blvd., Ste. 110, Boulder, CO 80302.

Ara Foundation is regarded as a co-controller of cookies placed on this site under applicable data protection laws.

The purpose of this notice is to inform you about the collection and use of cookies when browsing our site. For further information about this notice please contact [email protected].

We ensure the accuracy of this notice by keeping it up to date. Any changes to this notice will be promptly communicated on this page and you should check back to see whether any adjustments have been made.

Our site is designed with user privacy and user control of user data in mind. Many of the pages and features of our site do not require cookies, and do not use cookies. A cookie notice, and this cookie info, only apply to the pages and features of our site which do use cookies or applicable related technologies.

Depending on where your browser appears to be located geographically, the applicable data protection laws within that region, and the page or feature of our site you are using, you agree to the use of cookies on your browser.

3.2. What are cookies?

A cookie is a small amount of digital information your browser places in the storage of your device. This data does not identify you directly, but it can enable pages and features of the sites you use to function for you, and provide you with a personalized web experience.

If you choose to accept cookies, your browser adds the cookie data, and the cookie helps analyze web traffic, lets you know when you visited a particular website, or enables features of the site. In general, cookies allow the web to respond to you as an individual by allowing sites to tailor operations to your preferences by gathering and remembering information about your activity.

Depending on the type and settings of your browser, your browser may accept cookies by default. You may change the settings on your browser to delete existing cookies or prevent future cookies from being automatically accepted. If you disable cookies, certain pages and features of our site may not be available.

3.3. Our site uses the following types of cookies

3.3.1. Strictly necessary cookies

These cookies are required to provide the basic functions of the site and cannot be turned off. They are essential for accessing certain features of the site and could include signing in, seeing or editing your information and the information you should be able to access, or billing.

All cookies and similar related technologies that this site uses are in this category of strictly necessary cookies.

3.3.2. Performance cookies

These traffic log cookies are used to identify the pages used and to measure and track the performance of our site. This helps us to analyze page traffic data and improve our site to serve your needs. We only use the information for diagnostic and statistical analysis purposes.

3.3.3. Functionality cookies

These cookies are used to provide services you request.

3.3.4. Targeting cookies

These cookies may be set by us or by our advertising partners. They may be used to build a profile of your interests and show you relevant advertisements on this site or others. They do not store personal information but are based on uniquely identifying your browser. If you do not allow these cookies you will experience less relevant advertising.

You may object to cookies and other tracking technologies that may be used on this site by referring to your browser settings.

Different retention periods apply to different types of cookies according to whether they are session cookies (a cookie temporarily placed on your device that appears when you access the site and disappears when you close your browser window) or permanent cookies (a cookie that will remain on your device for a certain period to allow the site to remember your preferences as you visit again in the future).

4. SMS and MMS terms and conditions

How the site uses SMS. The site uses SMS text messages for user identification purposes. These purposes include: allowing a user to sign up, identifying a returning user who wishes to sign in, preventing a user from making multiple accounts, and generally demonstrating that a user has control of a mobile phone number. When you opt in to the service, the site will send you one SMS text message per user action, such as pressing a button to receive a code, as performed by you.

Optional use. Use of SMS on the site is optional for the user. The information a new user sees when choosing how to sign up indicates that it is optional.

Alternatives to use. A user does not need to use SMS to use any of the services of the website. For example, instead of signing in with SMS, a user can choose to sign in with email. Or, instead of signing in with SMS every time, a user can add a password to their account, and then sign in with that password. Users can change their preferences related to how they sign in, and how that method uses SMS, during account creation and at any time after account creation, in account settings.

Use is upon user action. The site sends a user an SMS message when the user clicks a button to explicitly perform that action. For instance, a user may have chosen to receive a message, and then press a button labeled Send Code.

Keywords. The site sends SMS messages from one or several toll-free numbers. You can cancel SMS service from a toll-free number at any time by texting STOP in response to a message. When you text STOP to a toll-free number, your mobile carrier will reply with an SMS message that confirms that you have been unsubscribed. After this, you won't be able to receive any additional messages from that number. To again be able to use SMS from us, reply with UNSTOP.

For toll-free numbers like those we use, the keyword opt-out and opt-in responses are set at the carrier level, using STOP and UNSTOP. These are the only keywords that you can use, and we cannot modify them. Response messages when you reply with STOP and UNSTOP are also managed by the carrier.

If you have chosen to sign in with SMS codes, but then reply to a message with STOP, we will be unable to deliver codes. This may prevent you from being able to sign in using this method. If you wish to use this method again, text UNSTOP, and request another code. Alternatively, sign in using an alternative means previously configured, like a password. Or, recover your account through additional identifying means, such as email.

Protecting use. Our site identifies users by combining several pieces of sign-in information, like date of birth, phone number, email address, and password. A third party that knows a user's phone number will be prevented from using the site to cause the site to send a message to that phone number by not knowing additional corresponding sign-in information for that user.

Security. Our site stores all personal and user information, including date of birth and telephone number, securely. Website systems are secure with API keys. These keys are kept secure in serverless cloud secrets vaults. In maintaining and improving the site, these keys are only accessed by authorized staff members using secure devices. Additionally, in the unlikely event of a data breach, sensitive user data is encrypted, both in transit and at rest. The site employs strong encryption algorithms to protect sensitive user information.

Carriers. We are able to deliver messages to the following mobile phone carriers: Major carriers: AT&T, Verizon Wireless, Sprint, T-Mobile, MetroPCS, US Cellular, Alltel, Boost Mobile, Nextel, and Virgin Mobile. Minor carriers: Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central IL (ECIT), Cellular One of Northeast Pennsylvania, Cincinnati Bell Wireless, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless). Carriers are not liable for delayed or undelivered messages.

Cost. Message and data rates may apply for any messages that we send to you or you send to us. You will receive one message per identification action. Contact your wireless provider for more information about your text plan or data plan. If you have questions about the services provided by our use of SMS, email us at [email protected].

Privacy. If you have any questions regarding privacy, read our Privacy notice.

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