In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Idea Colosseum LLC (“Arena”, “we”, “our” or “us”) use, collect and store personal information that we collect or receive from or about you (“you”) in connection with https://getarena.app/ (the “Website”), the Arena mobile application (the “App”; collectively, the “Platform”), and the services provided therein (the “Services”).

Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal information. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement. 

Table of contents:

1. What personal information we collect, why we collect it, and how it is used

2. How we protect and retain your personal information

3. How we share your personal information

4. Your privacy rights 

5. International transfers of personal information

6. Use by children

7. Interaction with third party products

8. Analytic tools/ Cookies

9. Specific provisions applicable under California privacy law

10. Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement material changes in the way we use your personal information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Platform or by other means and take any additional steps as required by applicable law.

1. WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

1. We Process the Following Personal Information: 

1. Personal Information Provided Through the Platform. We collect personal information that you voluntarily provide, including your email address, password and country, as well as any other personal information that you decide to provide us. We also collect User Generated Content that is posted on the platform, including your posts, direct messages and profile information.

2. Personal Information Automatically Collected. We automatically collect certain information through your use of the Platform, such as cookie, pixels, tracking technologies and similar identifiers (“Technologies”), your Internet protocol (IP) address, and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other personal information about actions taken through the use of the Platform.

3. Personal Information From Other Sources. Arena also may obtain personal information about you from other sources, including publicly - or commercially - available information, and through third-party data platforms, partners and service providers.  

4. Personal Information We Collect From Online Interactions. For example, if you contact us via social media or otherwise interact with our business, including as a representative of a current / prospective customer, supplier or partner, we track and make a record of those interactions, which may contain your contact details, such as full name, email address, messages and any other personal information that you decide to provide us with. 

1. We process personal information for the following purposes: 

1. To allow you to make use of our Platform and to provide you with the Services. We will use the personal information, including, without limitation, for the following purposes: (i) allow you to create an account; (ii) to provide you with the Services and to process your requests; (iii) communicate with you about your use of the Services and the Platform and for support and marketing purposes, and to offer relevant offers to you[; (iv) fulfill any instruction and/or request made by you in the context of the Services; (v) send you push notifications and/or emails and notifications regarding your account or certain features of the Services, including, updates related to the Services; (vi) to personalize and customize your experience with our Services; (vii) to allow you to communicate with other users on the Platform; (viii) to generally administer and improve the Services; (ix) to analyze your use of our Platform and to improve our Platform; (x) for internal quality control purposes; and (xi) to generally administer the Services and to improve the Platform and Services.

2. Security purposes. Some of the personal information mentioned in this Privacy Policy will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Personal information may also be used to comply with applicable laws, with investigations carried out by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.

3. De-identified and Aggregated Information Use. In certain cases, we may or will anonymize, aggregate and/or de-identify part or all of your personal information. This data may be used for both internal and external purposes, such as analyzing, enhancing, testing, training and improving Arena Services (including through the use of artificial intelligence) and for research and development purposes. We may also share this aggregated information and/or disclose it to third parties without restrictions.

4. Cookies and Similar Technologies. We use Technologies to automatically collect information through the Platform and Services, which in certain cases could be considered personal information. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Platform and Services. If you would like to opt out of the cookies and similar technologies, we employ on the Platform and Services, you may do so by blocking, deleting, or disabling them as your browser or device permits or by changing your setting and preferences here.

1. The lawful bases we rely on for processing personal information are (if and when applicable): 

1. The data subject has given consent to the processing of his or her personal information;

2. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; 

3. processing is necessary for compliance with a legal obligation to which the controller is subject; and/or

4. Processing is necessary for the purposes of legitimate interest.

1. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION

1. Security. We implement and maintain industry-standard technical, organizational and security measures designed to protect your personal information. However, please note that we cannot guarantee that the personal information will not be compromised as a result of unauthorized penetration of our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

2. Retention of your personal information. Your personal information will be stored until we proactively delete it from our records, or until you send a valid deletion request. Please note that in some circumstances we store your personal information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your personal information or dealings. 

1. HOW WE SHARE YOUR PERSONAL INFORMATION 

We may share your personal information as follows: 

1. Your User Generated Content is public, and the Service allows you to share personal information, messages or interact with other users.

2. The personal information Arena gathers may be shared with our affiliated companies. 

3. We use third party service providers to process your personal information for the purposes outlined above, including, without limitation: 

   1. With cloud service providers for hosting purposes, currently Amazon Web Services;

   2. With websites and web content creation platforms in order to help us manage our Platform;

   3. With email providers, marketing, CRM, other similar tool providers; 

and

1. With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy.

2. To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Arena, our Services, customers, employees, property, and the public. We may use or disclose the personal information we collect in order to ensure that our users are complying with all applicable aspects of our policies.

3. We may disclose personal information with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;

4. We may use or disclose personal information to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;

5. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal information in connection with the foregoing events.

6. Where you have otherwise provided your consent to us for sharing or transferring your personal information.

1. YOUR PRIVACY RIGHTS

1. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

1. You have the right to withdraw consent to the processing, where consent is the basis of processing. 

2. You have the right to request access to your personal information held by us, along with details on how it is processed, subject to certain conditions. 

3. You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect.

4. You have the right to object to unlawful data processing under certain conditions.

5. You have the right to the erasure of past personal information about you (your “right to be forgotten”) under certain conditions.

6. You have the right to demand that we restrict the processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal information is inaccurate.

7. You have the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.

8. You also have a right to request certain details of the basis on which your personal information is transferred outside the European Economic Area.

9. You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place of work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We encourage you to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

1. You can exercise your rights by contacting us at support@getarena.app. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent with written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, it would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

1. Deleting your account: Should you ever decide to delete your account, you may do so by emailing support@getarena.app. If you terminate your account, any association between your account and personal information we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public. 

1. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

In order to run our business and provide our Website and Services to you, we transfer personal information to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your personal information may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever personal information is transferred internationally, we ensure it is protected by using standard contractual clauses or other lawful mechanisms:

1. making sure the destination country has been deemed by the European Commission to provide an adequate level of protection for personal information; and/or

2. by executing data onward transfer instruments such as data processing and protection agreements.

1. USE BY CHILDREN

We do not offer our products or Services for use by children and, therefore, we do not knowingly collect personal information from, and/or about children under 16. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provided personal information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at support@getarena.app.

1. INTERACTION WITH THIRD PARTY PRODUCTS. 

We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect personal information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

1. ANALYTIC TOOLS/COOKIES

• Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. 

• Through our Services we may allow third party advertising partners to set technologies and other tracking tools to collect information, which in certain cases could be considered personal information, regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such personal information and other personal information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this personal information (and similar information collected from other websites) for the purpose of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you.  

• We use log files. We use such personal information to analyze trends, administer the Platform, track user movement around the Platform, and gather demographic information.

• We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.

1. SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

1. California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain personal information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to Californiaprivacy@getarena.app. Please note that we are only required to respond to one request per customer each year.

1. Deletion Of Content From California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. To remove, please send an email to Californiaprivacy@getarena.app. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

1. Our California Do Not Track Notice: 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.

1. CONTACT US. 

For any questions, concerns, or to exercise your privacy rights, please contact us at: support@getarena.app.

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