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Arist Privacy Policy 

Effective Date: September  27th, 2020 

SCOPE 

This Privacy Policy applies to information, including personal information, processed by Arist Holdings, Inc. (“Arist,” “we,” “us,”  and “our”) in the course of our business, including our website located at http://arist.co (the “Site”), our  platform accessible via our Site that allows individuals and/or businesses (“Authors”) to create online  courses (“Courses”), which will be completed through text messages or such other messaging features  offered by the Services, for individuals and/or businesses that wish to enroll in such Courses (“Learners”),  and our related offerings.  

To make this Privacy Policy easier to read, the Site and our platform, services, and related offerings are  collectively called the “Services.” 

Capitalized terms not defined in this Privacy Policy have the meaning set forth in the Terms of Service at  www.arist.co/terms. 

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, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third parties that  provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local  storage, and other technologies (“Technologies”) to automatically collect information through the  Services. Technologies are essentially small data files placed on your device that allow us and our  partners to record certain pieces of information whenever you visit or interact with our 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; 

• Communicating with you about your account, activities on our Services and Privacy Policy changes; 

• 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. 

How We Use Automatic Collection Technologies. We, as well as third parties that provide content,  advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other  technologies to automatically collect information through the Services. Our uses of these Technologies fall  into the following general categories:  

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: 

Authors. If you are a Learner and sign up for a Course, you are instructing Arist to share your personal  information (excluding your phone number) with the Author whose Course you have signed up for. In  addition, you may choose to provide additional personal information directly to Authors. Once your personal  information has been shared with the Author, it will also be subject to the Author’s privacy policy and the  Author may use your personal information for its own purposes. Please note that we do not control and we  are not responsible for the Author’s processing of your personal information. Providing information to  Authors is at your own risk. 

Third-Party Messaging Platforms. If you interact with a Course or Author via a third-party messaging  platform (e.g., Facebook Messenger or WhatsApp), the third-party messaging platform can collect and use  any information you provide via that channel in accordance with its terms of service and privacy policy.  These platforms are not controlled by us and we are not responsible for the privacy and security practices  of any third-party messaging platforms. Providing information to these platforms is at your own risk. 

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. 

YOUR CHOICES  

General. You may be able to opt out of certain uses of your personal information.  

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link  found at the bottom of the email to opt out of receiving future emails. Note that you will continue to  receive transaction-related emails regarding products or Services you have requested. We may also  send you certain non-promotional communications regarding us and our Services, and you will not be  able to opt out of those communications (e.g., communications regarding the Services or updates to our  Terms of Service or this Privacy Policy).  

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. 

DATA RETENTION 

We store the personal information we receive as described in this Privacy Policy for as long as you use our  Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve  disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements, and  comply with applicable laws.

SECURITY OF YOUR INFORMATION 

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.  Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information  you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for  unauthorized disclosure. 

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. 

CHILDREN’S INFORMATION 

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. 

CALIFORNIA RESIDENTS 

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. 

SUPERVISORY AUTHORITY 

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. 

CHANGES TO OUR PRIVACY POLICY 

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes  to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you 

will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the  new Privacy Policy takes effect. 

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 support@arist.co. 

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. 

6. If you have any questions regarding privacy, please read our privacy policy: www.arist.co/terms 

CONTACT US 

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a  request to exercise your rights as detailed in this Privacy Policy, please contact us at:  

Arist Holdings, Inc.  

15 Jasons Grant Dr, Cumberland, RI 02864 

support@arist.co

CCPA information: