1. Introduction

Welcome. You have arrived at a website provided by Al Rafay Consulting, LLC (“ARC,” “Company,” “we,” “our” or “us”). ARC is a leading Microsoft consulting and software development firm with 10+ years of experience and expertise in developing ingenious enterprise solutions based on innovative technology frameworks.

At ARC, we take your privacy seriously. We provide this Privacy Policy (this “Policy”) to tell you what information we collect about you, how we obtain it, how we share it, and how you may limit the ways in which we use your Personal Information (defined below). If you have questions about this Policy after you review it, feel free to contact us at contact@alrafayconsulting.com.

2. Scope

This Policy governs www.alrafayglobal.com, its subdomains, and all subdomains or portals that link to this Policy (the “Site”); our mobile applications (“Apps”); or otherwise when you provide Personal Information or interact with us online or in person. This Policy also applies to Personal Information that we may collect from you via phone calls or other communications with our representatives or in any other instance when you contact us. We refer to all the above as our “Services.” For the purpose of this Policy, “Personal Information” means any personal information relating to an identified or identifiable individual that is protected by applicable privacy laws. The term Personal Information does not include publicly available information from federal, state or local government records, such as professional licenses and real estate or property records.

By using our Sites or Apps or otherwise using our Services, you acknowledge this Policy and agree to our Terms of Service (“Terms”), which incorporate this Policy by reference.

3. What Information We Collect

As a rule, we limit the Personal Information we collect to that which is adequate, relevant and reasonably necessary for us to provide our Services to you.

Information That You Provide to Us

As you interact with our Services, we collect the following Personal Information via webforms or inputs/uploads on our Site or Apps, and through telephone calls, text messages, letters, emails and other communications with you:

Contact information, such as your first and last name, email address, job title, home or business address, telephone numbers, and/or mobile numbers;
If you purchase Services from us, financial information such as your business credit card or debit card number; bank account information; and payment, service and purchase history;
Information contained within the software to which you provide us access, including email, spreadsheets, databases, document management systems, customer relationship management platforms, and other software services you may ask us to integrate;
Social media handles, content and other data shared with us through third party features that you use with our Site, Apps or Services (such as tools, payment services, widgets and/or plug-ins offered by social media services like Facebook, Instagram, Twitter and Pinterest) or posted on social media pages (such as our social media page or other pages accessible to us); and
Other information that could reasonably be used to identify you personally.

Information That Is Automatically Collected

Like many businesses, we and our service providers automatically collect and/or store certain information when you visit or interact with the Site, Apps or Services (“Usage Information”), including via cookies and other tracking technologies (see Use of Cookies and Other Tracking Technologies below). Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site or Apps. Usage Information includes:

Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
Referring and exit web pages and URLs;
The areas within the Site and Apps that you visit and your activities there, including remembering you and your preferences;
Your Device location or other location information, including the zip code, state or country from which you access the Services;
Your Device characteristics (such as device type (computer vs. mobile) and ID, operating system, hardware);
Certain other Device data, including the time of day you visit our Site or Apps, or other information used to provide analytics or other usage information;
Information about your engagement with our emails; and
Statistical information about how both unregistered and registered users, collectively, use the Services.

For location information, some of our Services include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). If you use Location-Based Services, we collect and store information about your location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information comes from a variety of sources depending on the device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used.

If you do not wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device settings for instructions. Please note that, if you disable such features, your ability to access certain features, Services, content, promotions or products may be limited or disabled.

Information Collected from Third Parties

The Services include functionality that allows certain kinds of interactions between the Site or Apps and your account on a third party website or application. The use of this functionality may involve the third party site providing information to us, or us providing information to the third party. For example, we might obtain information about the traffic and usage of ARC from third parties. We might also provide links to make it easier to send a communication from the Site or the Apps, or we may use third parties to make it easier to send emails or post to social media (like a “Share” or “Forward” button). These third parties also use cookies and other tracking technologies to capture information about your interactions with ARC.

ARC does not have control over the information that is collected, used or shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

Information We Infer

We derive information or draw inferences about you based on information we collect about you. For example, based on your browsing or purchases, we may infer your gender, your interest in certain activities or brands, or information about your purchasing activities over time.

4. Use of Cookies and Other Tracking Technologies

We use various methods and technologies (“Tracking Technologies”) to store or collect Usage Information, recognize your browser or device, learn more about your interests to personalize your experience, and deliver our Site and Services to you. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Site, geographic location, web request and Internet Protocol address; the date and time of your web request; the domain name of your Internet service provider; and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information. Tracking Technologies may set, change, alter or modify settings or configurations on your Device. By using this Site, you consent to our use of Tracking Technologies.

A few of the Tracking Technologies used on the Site or in our Apps include, but are not limited to, the following (as well as future-developed tracking technologies and methods that are not listed here):

Cookies. A file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, and other types of cookie technology to store information on local storage;
Pixels. A small graphic file that allows us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site;
Web Beacons. A small tag (which may be invisible to you) that may be placed on our Site’s pages and messages;
Embedded Scripts. Programming code that is designed to collect information about your interactions with the Site, such as the links you click on;
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL;
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification; and
Recognition Technologies. Technologies, including application of statistical probability to data sets, that attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

We may use the following types of cookies:

Essential/Strictly necessary cookies. Essential for you to browse the Site or App and use their features, such as accessing secure areas of the Site. You cannot disable this type of cookie on our Site;
Functionality cookies. Also known as “preference cookies,” allow the Site to remember choices you have made in the past, like what language you prefer, or what your user name and password are so you can automatically log in. Disabling these cookies can cause some parts of the Site not to work properly;
Performance cookies. Also known as “analytics cookies,” collect information about how you use a website, like which pages you visited and which links you clicked on. Their purpose is to improve website functions. These cookies include cookies from third party analytics services if the cookies are for the exclusive use of the owner of the website visited; and
Targeting and Advertising cookies. Track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always from third parties.

First party cookies originate from the same domain as the website you are currently visiting. Third party cookies originate from a domain that is different from the website being visited. For example, when you visit our Site, we may link to another company’s website, or another company like Google Analytics, Bing Analytics and/or Facebook/Meta may place cookies or other tracking technologies on your Device to provide us with analytics on our website visitors, to let us know if you view our content, or to provide advertising to you. We do not control how these third parties use their cookies, so we suggest you check their website to see how they use them and how you can manage them.

You can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Site. For example, we may not be able to recognize your Device, and you may need to log in every time you visit.

You can opt out of non-essential cookies by enabling an opt out preference signal on your browser or opting out of cookies in our Site’s cookie preference centers.

You can control the use of cookies on most web browsers. Use the links below to modify your web browser’s settings on the most popular browsers:

We might also use a pixel tag, which is a small graphic file that allows us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. These tags may collect the IP address from the Device on which you loaded the page, and the browser type. Pixel tags are also used by our third parties to collect information when you visit our Site, and the links and other actions you take on our Site, and we may use this information in combination with cookies to display targeted advertisements. Other data technologies may be used to collect comparable information for security and fraud detection purposes.

See https://thenai.org/ for general information about the NAI and https://thenai.org/opt-out/ for the opt-out page. You may also visit https://optout.aboutads.info/?c=2&lang=EN to learn about interest-based advertising and how to opt out of online behavioral ads served by some or all participating companies. We do not control these opt out links or whether any organization chooses to participate in these opt out programs. Please note that you may need to opt out on each Device and browser you use to access our Site.

If you have any questions about cookies or generally want to find out more about cookies, visit this site. Please note that, even if you exercise the opt out choices above, you may continue to receive advertisements; for example, ads based on the website you are viewing (e.g., contextually-based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt out cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. We always do our best to honor your choices, but because some choices are set at the browser or Device level, you may have to make these choices multiple times if you use different browsers or Devices.

Additional Disclosures and Tools for Third Party Tracking Technologies

We may also share your Personal Information with advertisers and other third parties who may use it for advertising purposes, including to serve targeted advertising on unaffiliated third party sites. These companies may utilize cookies, pixels, web beacons or other technologies to collect user information (e.g., hashed, de-identified data; click stream information; browser type; time and date; subject of advertisements clicked or scrolled over) during your visits to this and other websites to provide advertisements about goods and services likely to be of greater interest to you. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information about your online activities on the Site or other websites over time. For example, information collected across multiple sites may enable the ad network to predict your preferences and show you ads that are likely to be of interest to you. To opt out of these types of ads, please visit the Network Advertising Initiative for information about how to opt out of interest-based advertising by their members.

Our Site uses Google Analytics for certain advertising and analytics features. Some of these features are already privacy-compliant because they use aggregated data or otherwise do not identify an individual. Google, however, provides additional opt out options as follows:

You can opt out of Google AdWords Remarketing here. Additional information about Google advertising and changing your preferences is available here.
You can block Google Analytics from accessing your online activity with a browser add-on here.

Data exported from us into Google Ads is subject to the Google Ads terms of service, and data imported into Google Analytics is subject to the Analytics terms of service. Please review these terms for more information.

How Google/DoubleClick uses Cookies is here; Bing/Microsoft’s privacy policy is here; and Facebook/Meta’s privacy policy is here. You can change your Facebook Ad Preferences here.

5. Why We Collect Information

We use the information we collect about you in a variety of ways, including the following:

To Provide Our Services

We process certain Personal Information when you access or use our Services, including to:

Process your purchases of or requests for products and Services;
Create and verify user accounts;
Facilitate the functionality of our Site and Apps, including payment-related functionality; and
Customize experiences and personalization when you are on our Site or using our Apps.

To Communicate with You

We process certain information to communicate with you in relation to your accounts, our Services, our marketing, and your requests, including to:

Communicate with you about orders, purchases, returns, services, accounts, programs, contests and sweepstakes;
Respond to your customer service inquiries and requests for information;
Post your comments or statements on our Site or Apps;
Send you personalized promotions, content and special offers;
Communicate with you about our brands, products and events, and for other promotional purposes; and
Implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives.

To Improve Our Site, Apps or Services

We want to ensure that our Site, Apps and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

Maintain, improve and analyze our Site, Apps and Services; and
Detect, prevent or investigate suspicious activity or fraud.

To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

Maintain appropriate records for internal administrative purposes; and
Comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce Our Terms, Agreements and Policies

To maintain a safe, secure and trusted environment for you when you use our Site, Apps and Services, we use your Personal Information to ensure our terms, policies and agreements with you and any third parties are enforced.

With Your Consent

We process certain Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.

6. When We Disclose Information

To the extent permitted by law, certain Personal Information about you may be disclosed in the following situations:

Service providers. To provide information to our affiliates and unaffiliated third parties who perform services or functions for us in conjunction with our Services to you, but only if we have a contractual agreement with the other party that prohibits them from disclosing or using the information other than for the purposes for which it was disclosed. Examples of such disclosures include using a payment processor, reservations maker, merchandise store, customer service provider, email marketing provider, or food delivery service;
Marketing and advertising. We also may share your information, including your Personal Information, with our affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described in this Policy;
Legal processes. To comply with a validly issued and enforceable subpoena or summons; or as a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings initiated either by or against us, provided we disclose only the information necessary to file, pursue, or defend against the lawsuit and take reasonable precautions to ensure that the information disclosed does not become a matter of public record;
Compliance. In the course of a review of our practices under the authorization of a state or federal law, or as necessary to properly respond to an inquiry or complaint; and
Business transactions. In conjunction with a prospective purchase, sale or merger of all or part of our practice, if we take appropriate precautions (for example, through a written confidentiality agreement) so the prospective purchaser or merger partner does not disclose information obtained in the course of the review.

Finally, we may aggregate, de-identify and/or anonymize any information collected through the Site, Apps or Services, such that such information is no longer linked to your Personal Information. We may use and share this aggregated and anonymized information for any purpose, including, without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

7. Ads and Information About You

You may see certain ads on our Site or Apps because we participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the Tracking Technologies described above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our Site or Apps, such as the pages you have viewed. This collection and ad targeting take place on our Site or Apps and on third party websites that participate in the ad network. This process also helps us track the effectiveness of our communications and marketing efforts.

You can find additional information above in the section about information that is automatically collected from you, including ways to opt out of certain Tracking Technologies.

8. Automated Decision Making

Automated decision making refers to a decision that is taken solely on the basis of automated processing of your Personal Information. We may use automated decision making for a variety of reasons, including verifying accounts and activity, promoting safety and security on and off our Services, and investigating suspicious activity or violations of our terms or policies. When we use the technology in this way, you cannot opt out of our use of decision-making technology. We work hard to protect your account using teams of engineers, automated systems, and advanced technology, such as encryption and machine learning. We also offer easy to use security tools that add an extra layer of security to your account. We never use automated decision making to produce an adverse legal effect on you or to profile you.

9. Retention of Personal Information

ARC will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third party data storage providers.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

How long we have had a relationship with you or provided our Services to you;
The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;
Whether we are required to retain the information, or the information is otherwise necessary, in order to comply with legal obligations or contractual commitments, defend against potential legal claims, detect or prevent potential illegal activity or actions in violation of our policies and procedures, secure our systems and online environment, or protect health and safety;
The privacy impact on individuals of ongoing retention; and
The manner in which information is maintained and flows through our systems, and how best to manage the life cycle of information in light of the volume and complexity of the systems in our infrastructure.

10. Your Choices about the Information We Collect

Communications Preferences

We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us using the information in the Contact Us section below. We will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable (but we may retain prior information as business records).

You can opt out of receiving marketing emails or text messages from us at any time. You will still receive transactional messages from us. To manage your email preferences with us, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below. Your choice will not affect our ability to share information in the other ways described in this Policy.

Controlling Your Cookies

You can opt out of cookies by enabling an opt out preference signal on your browser or opting out of cookies in our Site’s cookie preference centers. Please see the “Use of Cookies and Tracking Technologies” section above for more information on your options.

Do Not Track

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time, and across third party websites or online services (for example, browser do not track signals), but there is no universally agreed-upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about DNT here.

11. Children’s Privacy

Our Services are not intended for use by children under the age of 16. We do not request or knowingly collect any personally identifiable information from children under the age of 16. If you are the parent or guardian of a child under 16 whom you believe has provided her or his information to us, please contact us using the information in the Contact Us section below to request the deletion of that information.

12. Visitors to the Site outside the United States

If you are visiting the Site or Apps from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site or Apps will be created and processed on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts or law enforcement agencies in the U.S. according to laws of the U.S. By using the Services or providing us with any information, you consent to the transfer to and processing, usage, sharing and storage of your information in the U.S. and in other countries, as described in this Policy.

13. Links

For your convenience, the Site and Apps and this Policy may contain links to other websites. ARC is not responsible for the privacy practices, advertising, products, services or content of such other websites. None of the links on the Site or Apps should be deemed to imply that ARC endorses or has any affiliation with the links.

14. Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. No data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information, however, can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from the Site or Apps, and you provide us with your information at your own risk.

15. Your California Privacy Rights

This section of the Policy applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

California residents have the following rights:

To know the categories of Personal Information being collected about you, the purposes for which the categories of Personal Information are collected or used, and whether that information is sold or shared;
To know the length of time we intend to retain each category of Personal Information;
To know whether your Personal Information is sold or disclosed and to whom;
To access your Personal Information;
To delete the Personal Information you have provided to us, with certain exceptions;
To correct your Personal Information;
To opt out of the sale of Personal Information;
To know if Sensitive Personal Information (“SPI”) is being collected about you, the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;
To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and
Not to be discriminated against, even if you exercise your privacy rights.

Request for Information, Correction or Deletion

California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding twelve months:

The categories of Personal Information collected about you;
The categories of sources from which the Personal Information is collected;
The business or commercial purpose for collecting, selling or sharing Personal Information;
The categories of third parties to whom the business discloses Personal Information; and
The specific pieces of Personal Information collected about you.

Please note that, if we collected information about you for a one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information, such as if you have an existing account or transaction with us, or if we have a legitimate business reason to keep your information.

Notice at Collection – Personal Information Collected, Sold and Shared

The information we have collected from consumers within the last twelve months, as well as the categories of third parties with whom we have shared this information, are described in the table below:

Category of Personal Information	Categories of Third Parties to Whom Personal Information Is Disclosed for a Business Purpose	Category of Third Parties to Whom Personal Information Is Sold and/or Shared
Identifiers (Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)	Service and data analytics providers; advertising partners (online identifiers only)	Advertising partners, data analytics providers, marketing
Personal information described in California Civil Code § 1798.80(e) (name, address, telephone number, education, employment, employment history, credit card number, debit card number, and any other financial information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state or local government records. Some Personal Information included in this category may overlap with other categories)	Service providers (including payment processors), data analytics providers	Data analytics providers
Characteristics of protected classifications under California or federal law (Age (40 years or older), national origin, citizenship, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status)	Not collected	N/A
Commercial information (Records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies)	Service, advertising, marketing and analytics providers	Marketing and analytics
Biometric information	Not collected	N/A
Internet or other electronic network activity information (Browsing and search history; information on a consumer’s interaction with an internet website, application or advertisement)	Service, advertising, marketing and analytics providers	Marketing and analytics
Geolocation data	Service, advertising, marketing and analytics providers	Marketing and analytics
Sensory data	Not Collected	N/A
Professional or employment-related information	Not Collected	N/A
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99)	Not Collected	N/A
Inferences drawn from other Personal Information	Service, advertising, marketing and analytics providers	Advertising, Marketing and analytics
Sensitive Personal Information	Not collected	N/A

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

Do Not Sell My Personal Information

As a California resident, you also have the right at any time to tell us not to sell Personal Information. This is called the “right to opt out” of the sale of Personal Information. We do not sell your Personal Information for monetary compensation, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt out of this, please use opt out tools we have provided, or use the information in our Contact Us section below.

Right to Limit Use of Sensitive Personal Information

California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third party partner. Currently, we do not collect or provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you, and only with your express consent at the time of providing the information.

Right Not to Be Discriminated Against

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Notice of Financial Incentives

We do not provide financial incentives in exchange for your Personal Information.

Third Party Marketing

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not currently disclose Personal Information protected under this section to third parties for their own direct marketing purposes.

Exercising Your California Privacy Rights

You or your authorized agent may make a request to access, correct or delete your Personal Information; opt out of the sale of your Personal Information; or limit the use of your Sensitive Personal Information by contacting us as follows:

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We may also require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a twelve month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name and email address, and attest to the fact that you are a California resident. We will acknowledge your request within ten days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the applicable time period.

16. Your Privacy Rights under Other U.S. State Laws

If you live in certain other U.S. states, such as Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah or Virginia, you may have rights under applicable privacy laws once those laws have become effective.

Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information:

To confirm whether a controller is processing your personal data, and to access such personal data;
To know the categories of Personal Information we collect about you, the purposes for the collection, how long we retain your Personal Information, and whether that information is sold or shared or disclosed and to whom;
To correct inaccuracies in your personal data;
To delete your personal data;
To obtain a copy of your personal data that you previously provided to us in a portable and, if technically feasible, readily usable format, if processing is carried out by automated means; and
To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To exercise any of these rights, you may make a request to confirm, access, correct, delete, obtain a copy of, or opt out of the processing of your personal data for targeted advertising, sale or profiling by using the link in our footer or contacting us using the information in the Contact Us section below. Please include your state of residence.

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name and email address, and attest to the state in which you are a resident.

We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the applicable time period.

Right to Opt Out

You may have the right to opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. To exercise your right, please click on our Cookie options on the bottom of the webpage where your information is being collected.

Opt Out Preference Signals

Some browsers and browser extensions support opt out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt out of certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

Appeals of Our Decisions

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.

If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and how to make a complaint to your state Attorney General.

This section of the Policy applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this section.

Under applicable law, we are considered the “data controller” of the Personal Information we handle under this Policy. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law.

We want to ensure that the Personal Information we possess is always accurate and, therefore, we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise with respect to the processing of your Personal Information, subject to applicable law. We take reasonable steps to ensure that the Personal Information that we process is limited to the Personal Information that is required in connection with the purposes set out in this Policy.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

The right to access, update or delete the information we have collected from you;
The right to have your information rectified if that information is inaccurate or incomplete;
The right to object to our processing of your Personal Information;
The right to request that we restrict the processing of your Personal Information;
The right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format; and
The right to withdraw your consent at any time if we relied on your consent to process your Personal Information.

Legal Bases for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

Contract: To conclude or perform a contract with you; for example:
- To manage and fulfill orders, facilitate delivery, and provide support or other Services;
- To manage our accounts and records; and
- To handle your inquiries and requests.
Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:
- To respond to your customer service inquiries and requests for information;
- To maintain, improve and analyze our Site, Apps, ads and Services;
- To conduct marketing activities;
- To detect, prevent or investigate security breaches or fraud; and
- To facilitate the functionality of our Site and Apps.
Legal Compliance: To comply with our legal obligations; for example:
- To maintain appropriate records for internal administrative purposes and as required by applicable law.
Consent: We will send you information by email on our Services or other promotions only with your consent or if you otherwise opt in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time, as described below.

How to Exercise Your Rights under the GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us using the details in the Contact Us section below. You may make a request related to your Personal Information or on behalf of someone for whom you have authorization. You must include your full name and email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and legal standing for the request, as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; we hope, however, that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as set forth in the Contact Us section below.

If you are based in the United Kingdom, the following provisions also apply:

If we share your personal data within ARC or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the UK International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018. If you are a client of ours, these provisions are included in our separate Consulting Agreement.

You have the same data subject rights as those for the EU listed above, except that references to the “GDPR” should be read as references to the “UK GDPR,” and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.

19. Your Canada Privacy Rights

Canadian laws provide specific privacy rights to our Canadian customers. If you are a resident of Canada, this section applies in addition to all other applicable rights and information contained in this Policy.

Where applicable, we follow applicable Canadian federal and provincial privacy laws (“Canadian Privacy Law”), including:

The Personal Information Protection and Electronic Documents Act (PIPEDA);
Alberta’s Personal Information Protection Act (Alberta PIPA);
British Columbia’s Personal Information Protection Act (BC PIPA); and
Québec’s Act respecting the protection of Personal Information in the private sector (Québec Act).

Consent

In most cases, we rely on implied consent to collect, use, or disclose your Personal Information. In some circumstances, including those involving sensitive Personal Information, we obtain express consent. Where you have provided your consent to the collection, use and transfer of your Personal Information (whether orally, in writing, or electronically), you may have the legal right to withdraw your consent under certain circumstances. In addition to the methods described above with respect to your privacy choices, you may withdraw your consent by submitting a request using the information in the “Contact Us” section below. Please note that, if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time of your request to help you with your decision.

Use of Your Personal Information

We will not collect, use or disclose Personal Information except for the identified purposes identified above, unless we have received additional consent or the processing is authorized without consent. Where we engage service providers who utilize the Personal Information we provide to them, those relationships are governed by a written agreement regarding the confidentiality of your information.

Canadian Access and Challenge Rights

Canadian Privacy Law provides the right to receive information about the existence, use and disclosure of your Personal Information and be provided access to that information. You may also challenge the accuracy and completeness of your Personal Information and have it amended, as appropriate. Depending on the nature of the challenged information, amendment may involve the correction, deletion or addition of information.

Exercising Your Canadian Privacy Rights

If you have an account with us, you may view and update your account information (as noted above) directly by logging into your account. To submit a request for access to information not contained within your account, or to challenge the accuracy or completeness of your Personal Information, you may also submit a written request using the information in the “Contact Us” section below. When submitting a request, we also may require you to confirm your identity and your residency to obtain the information. For emails, please include “Canadian Privacy Rights” as the subject line. You must include your full name and email address, attest to the fact that you are a Canadian resident, and provide your province of residence. We will begin processing your request once you have completed the verification process, and will respond within the timeframe required by law.

If we cannot substantively respond to your request in a timely manner, we will notify you and state the reason for the delay. Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or where your request involves disproportionate cost or effort. We will, however, respond to your request within a reasonable time, as required by law, and provide an explanation.

Additional information about how to exercise your rights under Canadian Privacy Law can be found here:

Office of the Privacy Commissioner of Canada
Website
Phone: 1-800-282-1376
Office of the Information and Privacy Commissioner of Alberta
Website
Phone: 1-888-878-4044
Edmonton office: (780) 422-6860
Calgary office: (403) 297-2728
Office of the Information and Privacy Commissioner of British Columbia
Website
Vancouver: (604) 660-2421
Elsewhere in BC: (800) 663-7867
Commission d’accès à l’information du Québec
Website
Phone: 1-888-528-7741

20. Changes to This Privacy Policy

We may change this Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified Policy’s effective date. We, therefore, encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy policy. If required by applicable law, we will notify you of the changes.

By continuing to use the Services or providing us with information following such a replacement Policy being uploaded, you agree that you will be bound by the Policy as changed.

21. Contact Us

If you have any questions or suggestions regarding this Policy, please contact us as follows:

Webform: Contact us
Email Address: contact@alrafayconsulting.com
Telephone Number: 630-946-7863

Our Privacy Policy