Privacy Policy

Arise (“Arise,” “we,” “our,” or “us”) values the privacy of the individuals who use our technology, websites, and related services (collectively, the “Arise® Platform”). This privacy policy will help you understand what personal data we collect, retain, process, share and transfer when you visit our websites or use the Arise® Platform. This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our platform and services.

Our Commitment to Privacy

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

Scope

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

Personal Data

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

Personal Data We Collect

A. What We Collect

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

Service Data (including Session and Usage data). To help us understand how you use our websites and the Arise® Platform and to help us improve them, we automatically receive information about your interactions, like the pages or other content you view, your actions within the websites and Arise® Platform, and the dates and times of your visits. When you access our websites or use the Arise® Platform, we receive Personal Data generated through such use, either entered by you or third parties (for example, online profile information, schedules, attendee info, etc.), or from our websites or the Arise® Platform themselves (for example, duration of session, use of webcams, connection information, servicing information, etc.). We may also collect usage and log data, including diagnostic data to help us support the services.

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

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

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

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

Personal Data from Cookies and Similar Technologies. We are continuously improving the Arise® Platform through the use of various third-party web analytics tools, which help us understand how visitors use our websites, desktop tools, platform, and mobile applications, what they like and dislike, and where they may have problems. We collect Personal Data through the use of “cookies”, tracking pixels, and similar technologies to understand how you navigate through our systems and interact with Arise advertisements, to learn what content is popular, and to save your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you open our website or use the Arise® Platform. You can consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept certain cookies from us, you may be missing out on certain features of our websites and the Arise® Platform.

Examples of Cookies We Use:

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

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

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

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

B. Personal Data You Provide to Us

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

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

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

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

C. Personal Data We Collect from Third Parties

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

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

How We Use the Personal Data We Collect

Arise may access and use the Personal Data we collect as necessary (a) to provide and maintain the Arise® Platform; (b) to provide our services to you and our other clients; (c) to verify your identity; (d) to address and respond to service, security, and customer support issues; (e) to detect, prevent, or otherwise address fraud, security, unlawful, or technical issues; (f) as required by law; (g) to fulfill our contracts; (h) to improve and enhance the Arise® Platform; and (i) to provide analysis or valuable information back to you and our other clients.

Some specific examples of how we use the Personal Data are as follows:

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

How We Share the Personal Data We Collect With Third Parties

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

Examples of how we may share Personal Data with service providers include:

• Providing our services
• Payment processing and fraud prevention
• Verification of your identity
• Providing customer support
• Sending marketing communications
• Conducting research and analysis
• Providing cloud computing infrastructure

Clients. We will transfer Personal Data about you to clients if you are providing services for one of such client’s programs via the Arise® Platform.

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

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

Other Sharing. We may share your Personal Data with third parties in the following cases:

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

Communications 

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

• Responding to your questions and requests. If you contact us with a problem or question, we will use your Personal Data to respond.
• Sending you service and administrative emails and messages. We may contact you to inform you about changes in our services or the Arise® Platform, our offerings, and important service- related notices, such as client updates, security and fraud notices. These emails and messages are considered a necessary part of the services and you may not opt-out of them.
• Sending emails about new products or other news about Arise that we think you’d like to hear about either from us or from our business partners. You can always opt out of these types of messages at any time by clicking the unsubscribe link at the bottom of each communication.
• Conducting surveys. We may use the Personal Data gathered in the surveys to enhance and personalize our platform, services, and websites.
• Offering referral programs and incentives.

Your Choices

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

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

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

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

If would like to terminate your account on the Arise® Platform, please open a ticket with Partner Support. If you choose to terminate your account, we will deactivate it for you but may retain Personal Data from your account for a certain period of time and disclose it in a manner consistent with our practices under this privacy policy for accounts that are not closed. We also may retain Personal Data from your account to collect any fees owed, resolve disputes, troubleshoot problems, analyze usage of the Arise® Platform, assist with any investigations, prevent fraud, enforce our agreements, or take other actions as required or permitted by law.

Your Rights – Canada

If you are a resident of Canada, you have the right to:

• Access your Personal Data and rectify it;
• Withdraw any consent provided; and
• Where applicable, lodge a complaint with your supervisory authority.

Your Rights – Columbia

If you are a resident of Columbia, you have the right to:

• Access your Personal Data and rectify it;
• Request erasure of your Personal Data;
• Request restriction of processing of your Personal Data; and
• Withdraw any consent provided.

Your Rights – European Union and the United Kingdom

If you are a citizen of the European Union or the United Kingdom, under the GDPR or UK GDPR you have the right to:

• Request access to your Personal Data;
• Request rectification of your Personal Data;
• Request erasure of your Personal Data;
• Request restriction of processing of your Personal Data;
• Request data portability;
• Object to the processing of your Personal Data (including objection to profiling), and
• Withdrawal of your consent at any time.

Your Rights – India

Under the Indian Information Technology Act 2000 and the Information Technology Rules of 2011, residents of India have certain rights. If you are an Indian resident, you may exercise the following rights regarding your Personal Data, subject to certain exceptions and limitations:

• Right to access and review your Personal Data;
• Right to amend or correct your Personal Data;
• Right to withdraw your consent; and
• Right to file a grievance in relation to the to the collection and processing of your Personal Data.

Your Rights – Jamaica

Under the Jamaica’s Data Protection Act, Jamaican residents have certain right with respect to your Personal Data. If you are a Jamaican resident, you may exercise the following rights regarding your Personal Data, subject to certain exceptions and limitations:

• Right to be informed and the right to access: You have the right to know what Personal Data is collected and/or processed by Arise;
• Right to correction. You have the right to request correction of inaccurate Personal Data;
• Right to erasure (data deletion): You have the right to request deletion of your Personal Data;
• Right to object to or opt-out of processing of your Personal Data for targeted advertising, its sale, and profiling activities affecting you; and
• Right not to be subject to automated decision-making using your Personal Data.

Your Rights – Mexico

If you are a resident of Mexico, you have the right to:

• Right to access and review your Personal Data;
• Right to amend or correct your Personal Data;
• Right to obtain a privacy notice which discloses the purposes for which Personal Data may be used;
•  
• Notice – Data subjects should be given notice when their personal data is being collected. (Art. 3.I)
• Consent – Personal data should not be disclosed without the data subject’s consent. (Art. 8)
• Disclosure – Data subjects should be informed about the identity of the data collector. (Art. 16)
•  

Your Rights – California

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

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

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

Your Rights – Illinois

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

International Transfer of Personal Data

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

Data Privacy Framework

We comply with the EU-US Data Privacy Framework (“EU-U.S. DPF”), and as applicable, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. Date Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data from European Union, the United Kingdom and Switzerland to the United States. We have self-certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  We have certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

We commit to adhering to the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF and apply these to all of your Personal Data we collect. Arise includes the following entities: Arise Virtual Solutions Inc., Arise Virtual Solutions (Canada) Inc., Arise Virtual Solutions International Limited, Arise Virtual Solutions Limited and Officium Labs, Inc.

You have a right to access and in certain circumstances, limit the use and disclosure, of your Personal Data under the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. You may contact us at [email protected] to further information about your rights. Within the scope of our authorization to do so, and in accordance with our commitments under the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF, we will work with any third-party partners to provide you access to your Personal Data we hold on behalf of our partners or held by our partners on our behalf. We also will take reasonable steps to enable you, either directly or in connection with our third-party partners, to correct, amend, or delete Personal Data that is demonstrated to be inaccurate. We may disclose your Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We may subsequently transfer your Personal Data to a third parties acting on our behalf for processing as indicated in the International Transfer of Personal Data section above. In accordance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF, we are liable for any processing of Personal Data by such third parties that is inconsistent with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF unless we were not responsible for the event giving rise to any alleged damage. For the types of third parties to which we disclose your Personal Data see above “How We Share the Personal Data We Collect With Third Parties”. For the purposes for which we disclosure your Personal Data see “How We Use the Personal Data We Collect”.

Our compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we commit to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact us at [email protected].

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to International Centre for Dispute Resolution by the American Arbitration Association (“ICDR/AAA”), an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you.

In certain circumstances, we are obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that you have invoked binding arbitration by delivering notice to us and following the procedures and subject to conditions set forth in Annex I of Principles.

Other Information

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

Data Retention. We will retain your Personal Data for as long as your account with us is active and then (a) pursuant to our records retention schedules and practices, (b) to comply with our legal obligations, (c) to resolve disputes, and (d) to enforce our agreements.

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

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

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

Last Updated: December 20, 2023