PRIVACY POLICY

Effective Date: August 24, 2023

GENERAL

This Privacy Policy describes the types of information gathered by Arivo Entertainment, LLC d/b/a FTWin360 (hereinafter “Arivo”, “we,” “our,” or “us”) in the process of providing this website, mobile application, “over-the-top” (OTT) and any online service location that posts a link to this Privacy Policy, and the data, services, information, tools, functionality, updates and similar materials that we own, control, and which are delivered or provided thereby (collectively, the “Service”), how we use it, and with whom the information may be shared.

By viewing any content or otherwise using the Service, you agree to our Terms of Use and hereby consent to allow us to collect and use information from or about you in accordance with this Privacy Policy.   If you do not agree and consent to the collection and use of information from or about you in accordance with this Privacy Policy, then you must discontinue use of the Service.   This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection).

This policy is subject to change at any time. If our information retention or usage practices change, we will let you know by posting the revised Privacy Policy on the Service and/or otherwise making you aware of the changes. Please refer to the “Effective Date” above to see when this Privacy Policy was last updated.   Any changes will be effective immediately upon posting of the revised Privacy Policy or such later date as may be specified in the notice of the updated Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice, to the last e-mail address you provided us.

TERRITORIALITY

Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY USING THE SERVICE OR PROVIDING ANY INFORMATION TO US, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE TRANSFER TO AND FROM, COLLECTION, PROCESSING, USAGE, SHARING AND STORAGE IN THE UNITED STATES OF YOUR INFORMATION, AND THAT U.S. LAW GOVERNS ANY SUCH TRANSFER, COLLECTION, PROCESSING, USAGE, SHARING, AND STORAGE OF YOUR INFORMATION.

CONSUMER PRIVACY AND DATA PROTECTION LAWS

Under the California Consumer Privacy Act of 2018 (“ CCPA ”) and other similar consumer privacy and data protection laws, individuals are given certain rights in relation to their personal data. Accordingly, we have implemented additional transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

  Right of Access – the right to be informed of and request access to the personal data we process about you;

  Right to Rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;

  Right to Erasure – the right to request that we delete your personal data;

  Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;

  Right to Object – the right, at any time, to object to us processing your personal data on grounds relating to your particular situation, and the right to object to your personal data being processed for direct marketing purposes;

  Right to Data Portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and

  Right not to be Subject to Automated Decision-Making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

If you have any questions about your privacy, your rights, or how to exercise them, please contact us by emailing us at support@FTWin360.com.   We will respond to your request within a reasonable period of time.

INFORMATION COLLECTED

We collect three types of information about and from persons who use the Service: voluntarily provided information, automatically collected information, and information about persons who use the Service from other sources.

Information You Provide

We and our Service Providers (defined below) may collect information you provide directly via the Service. For example, we collect information when you register an account, provide your e-mail address and mobile phone number to receive communications from us, access other content available on the Service, or otherwise communicate or transact with us through the Service.

The information we collect may include certain Personal Information that identifies you personally (whether alone or in combination), which may include one or more of the following:

  •   Name

  •   Postal Address

  •   Phone number

  •   Credit card

  •   Username

  •   Device identifier

  •   Location information

  •   Email Address

Although it may appear that we collect payment card numbers, we process payments through a third-party and do not have access to your card numbers.

You may choose to voluntarily submit certain other information to us through the Service, including Personal Information, but you are solely responsible for your own Personal Information in instances where we have not requested that you submit such information to us.

Non-Personal Information is non-personally identifiable or anonymous information about you, including but not limited to age, gender, links, referring sites, materials posted, the type of device you used and its operating system, the pages accessed most frequently, how areas of the Service are used, applications downloaded, search terms entered, and similar non-personal data.   Personal Information once de-identified is not subject to this Privacy Policy and we and our Service Providers may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

Information Collected Automatically

We and our Service Providers may automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, data regarding network connected hardware, and information about your use of the Service. To the extent that we combine Usage Information with your Personal Information, we will treat the combined information as Personal Information under this Privacy Policy.

The methods that may be used on the Service to collect Usage Information include:

  Log Information : Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.

  Information Collected by Tracking Technologies : Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, in-channel tracking methods, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about your interactions with the Service or e-mails, including information about your browsing and activity behavior.

  Cookies : A cookie is a small text file that is stored on a user’s device, which may be a session ID cookie or tracking cookie. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies help in understanding how you use the Service, and remain longer. The Service may associate some or all of these types of cookies with your devices. Cookies may remain on your device for extended periods of time.

  Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.

  Embedded Scripts : An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your device from our web server or a third-party with whom we work, is active only while you are connected to the Service, and deleted or deactivated thereafter.

  Location-identifying Technologies : Location-aware technologies locate your device for purposes such as verifying your location within a zip code or DMA and delivering or restricting relevant content based on your location.

  In-App Tracking Methods : There are a variety of tracking technologies that may be included in mobile apps, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps.

Some information about your use of the Service and certain Third-Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third-Party Services.

For further information on Tracking Technologies and your choices regarding them, please see “Third-Party Services, Features, and Devices” and “Your Choices” below.

Information from Other Sources

We may obtain information from other sources, including Service Providers and Third-Party Services (such as Facebook), and combine such information with information we have collected. To the extent we combine such third-party sourced information with Personal Information we have collected on the Service, we will treat the combined information as Personal Information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third-party policies or practices.

USE OF INFORMATION

Internal Use of Information

We may use information collected, including Personal Information, for any purposes consistent with our statements under this Privacy Policy or as permitted by applicable law, including to:

  • Manage and provide our Service, including registration, account, and other content;

  • Respond to comments, questions, and requests, and provide customer service;

  • Send technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;

  • Prevent and address fraud, breach of policies or terms, and threats or harm;

  • Monitor and analyze trends, usage, and activities;

  • Conduct research, including focus groups and surveys;

  • Improve the Service or other Arivo applications, websites, marketing efforts, products and services;

  • Develop and display content, features, and advertising tailored to your interests on our Service as well as on other platforms and services;

  • Send advertisements and communications regarding our and third-party products, services, offers, promotions, rewards and events we think you may be interested in (for information about how to manage these communications and marketing efforts, please see “Your Rights and Choices” below); and

  • Fulfill any other purpose disclosed at the time you provide Personal Information.

Sharing Collected Information

Our agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to anonymized information, including Personal Information and Usage Information, in connection with their work on our behalf. These Service Providers are prohibited from using Personal Information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.

We may also share information with third parties for any purposes consistent with our statements under this Privacy Policy or as permitted by applicable law, including as follows:

  • To comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;

  • To protect the rights, property, life, health, security and safety of us, the Service or any third-party;

  • In connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business;

  • With payment processors and/or platforms, such as Stripe, PayPal and Venmo, to process and store payment card information when you transact with us;

  • With e-mail marketing platforms, such as MailChimp, for purposes of communicating with you;

  • With third-party platform providers, such as Apple or Google, for purposes of providing the Service;

  • With our affiliates for internal business purposes;

  • With our affiliates, business partners, and other third parties for their own business purposes, including direct marketing purposes (California residents have certain rights set forth in “California Privacy Rights” below);

  • For purposes disclosed at the time you provide Personal Information; and

  • With your consent or at your direction.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.

THIRD-PARTY SERVICES, FEATURES, AND DEVICES

Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third-Party Services”). In addition, our Service contains features that allow you to interact with, connect to, or access our Service through certain Third-Party Services and third-party devices (“Third-Party Features”). For example, you may use a Third-Party Service when you connect and interact with a social media platform through our Service. Remember that third parties often use Tracking Technologies to independently collect information about you and may solicit Personal Information. Also, if you use a Third-Party Feature, both we and the applicable third-party may have access to and use information associated with your use of the Third-Party Feature. If you publicly reference our Service on a Third-Party Service (e.g., by using a hashtag associated with Arivo in a tweet or post), we may use your reference on or in connection with our Service.

Our Service also contains Tracking Technologies operated by third parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Service to help us analyze your use of the Service, compile statistical reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Similarly, ad serving services, advertisers, and other third parties may use Tracking Technologies on our Service and Third-Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third-Party Service or third-party device after you have left the Service (“Interest-based Advertising”).

The information collected and stored by third parties, whether through our Service, a Third-Party Service, a Third-Party Feature, or a third-party device, remains subject to their own policies and practices, including what information they share with us, your choices on their services and devices, and whether they store information in the U.S. or elsewhere. We are not responsible for and make no representations regarding third-party policies and practices and encourage you to familiarize yourself with and consult their privacy policies and terms of use. To the extent we combine information we receive from third parties with Personal Information we collect directly from you on the Service, we will treat the combined information as Personal Information under this Privacy Policy.

YOUR RIGHTS AND CHOICES

Accessing Your Information

You may access, update, or remove certain account information that you have voluntarily submitted to us through the Service by emailing us at support@FTWIN360.com. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Tracking Technologies Generally

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings.   Browsers offer different functionalities and options so you may need to set them separately. With respect to our mobile apps, you can stop all collection of information via an app by uninstalling the app.   Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device.

Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not work as intended and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit.   Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms.   For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Analytics and Advertising Tracking Technologies

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

You can opt-out of receiving certain promotional communications (e-mails and push notifications) from us at any time by (i) for e-mails or electronic newsletters, following the instructions as provided in each e-mail and electronic newsletter, or contacting us at support@FTWin360.com   with the word UNSUBSCRIBE in the subject field of the e-mail; and (ii) for push notifications or in-app messages, adjusting the permissions in your mobile device. Please note that your opt-out is limited to the e-mail address and device used and will not affect non-promotional communications, such as those about your account, transactions, servicing, or Arivo’s ongoing business relations.

SECURITY

We employ procedural and technical safeguards to secure personal information against loss, theft, alteration, and unauthorized access, use and disclosure. We also employ security procedures to protect information from unauthorized access by users inside and outside the company.

Regardless of the precautions we take, no transmission of data over the Internet is completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect personal information, we cannot ensure or warrant the security of any information you transmit to us.

CHILDREN AND PRIVACY

The Service is intended for a general audience and not directed to children under seventeen (17) years of age. Arivo does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe Arivo has collected such information in a manner not permitted by COPPA, please e-mail us at legal@FTWin360.com and we will remove such data to the extent required by COPPA.

CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt-in to, or opt-out of, this type of sharing.

Arivo may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please e-mail us at legal@FTWin360.com. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Arivo is not required to respond to requests made by means other than through the provided e-mail address.

Any California residents under the age of eighteen (18) who have registered to use the Service and posted content or information on the Service, can request that such information be removed from the Service by sending an e-mail to us at legal@FTWin360.com. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.

CONTACT INFORMATION

If you have any questions or suggestions regarding our Privacy Policy, please contact us via e-mail at legal@FTWin360.com.