Effective Date: September 27th, 2020
INFORMATION WE COLLECT
The categories of information we collect depend on how you interact with our Services. Information You Provide to Us
Learner Account. When you register to be a Learner, as part of the Account setup process, we’ll collect personal information from you including your name, email address, phone number, and Payment Information. We’ll also collect information about your interests.
Author Account. When you register to be an Author, as part of the Account setup process, we’ll collect personal information such as your name, email address, phone number, a description of your skill set with respect to Course subject areas, Payment Account information, and any other necessary Account information.
Your Communications with Us. We collect personal information from you such as your email address, phone number, or mailing address when you request information about our Services, sign up for marketing from us, register for our newsletter, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information.
Interactive Features. We may offer interactive features such as the Course Library, messaging and chat features, collaboration and commenting functionalities, blogs and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein.
Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Arist and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and process the information contained therein to assess your suitability, aptitude, skills, and qualifications for employment with Arist.
Information Collected Automatically
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, mobile carrier, the Courses you enroll in and details about your interactions with such Courses, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services.
• Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Analytics. We may use Google Analytics and other service providers to collect and process analytics information on our Services. You can opt out of Google Analytics’ processing of your information on our Site by following the instructions here. We also use Hotjar for session replay analytics. You can opt-out of Hotjar’s processing of your information on our Site by following the instructions here.
Information from Other Sources
We may obtain information about you from other sources, including from third party services and organizations. For example, if you are a Learner and access our Services through your SNS Account, we may collect information about you from that SNS Account that is made available via your privacy settings. In addition, we may choose to conduct background checks on Authors (through the use of third party vendors), to the fullest extent permitted by law.
HOW WE USE YOUR INFORMATION
We use your personal information for a variety of business purposes, including:
To Provide the Services or Information Requested, such as:
• Fulfilling our contract with you;
• Recommending Courses to you based on your interests;
• To send you text messages;
• Responding to questions, comments, and other requests;
• Allowing you to register for events;
• Providing access to certain areas, functionalities, and features of our Services; and
• Answering requests for customer or technical support.
Administrative Purposes, such as:
• Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention (only applies to your email – we will never use your phone number for marketing purposes);
• Measuring interest and engagement in our Services;
• Improving the Services;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities;
• Carrying out audits;
• Preventing and prosecuting potentially prohibited or illegal activities;
• Enforcing our agreements; and
• Complying with our legal obligations.
Marketing Our Products and Services. We may use personal information (excluding your phone number) to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
• Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
• Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising or Targeting Related. We may use first party or third-party Technologies, including cross-device tracking, to deliver content, including ads relevant to your interests, on our Services or on third-party sites.
DISCLOSING YOUR INFORMATION TO THIRD PARTIES
We may share your personal information with the following categories of third parties:
Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising (email only, no phone number data will be shared); (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.
Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.
Affiliates. We may share personal information with Arist’s affiliated entities.
APIs and Software Development Kits. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth below.
Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the United States. We endeavor to safeguard your information consistent with the requirements of applicable laws.
General. You may be able to opt out of certain uses of your personal information.
Text Messages. You may opt out of receiving text messages by replying "STOP" to a text message you have received from us or by otherwise contacting us.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.
Please note you must separately opt out in each browser and on each device.
YOUR PRIVACY RIGHTS
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
SECURITY OF YOUR INFORMATION
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
THIRD PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third party websites or applications is at your own risk.
The Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
This section only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Arist has collected about them and whether Arist disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information at the end of this page.
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.
California residents also have certain rights in their personal information which are covered above in “YOUR PRIVACY RIGHTS.” In some cases, a California resident’s authorized agent may contact us on their behalf to exercise these rights. For purposes of the CCPA, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age. California residents have the right not to receive discriminatory treatment by Arist for the exercise of their rights conferred by the CCPA.
If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
ARIST SHORT CODE PROGRAM POLICY
1. After subscribing to content, users can expect to receive one message a day for the duration of the course that they signed up for. All messages will be educational in nature and will be no longer than 1,200 characters in length.
2. You can cancel the SMS service at any time. Just text "STOP" to the short code. After you send the SMS message "STOP" to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again.
3. If you are experiencing issues with the messaging program you can reply with the keyword HELP for more assistance, or you can get help directly at firstname.lastname@example.org.
4. Carriers are not liable for delayed or undelivered messages
5. As always, message and data rates may apply for any messages sent to you from us and to us from you. Message frequency varies. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.
Arist Holdings, Inc.
15 Jasons Grant Dr, Cumberland, RI 02864