Privacy and Data Protection

This privacy notice sets out how the Arabant Group (AG) processes personal data and the rights individuals have under the data protection legislation within which AG operates. AG and all AG entities, the (Group) are covered by this Notice.

AG's processing of personal data is subject to the Act on the Protection of Personal Information (APPI) in Japan, the Brazilian General Data Protection Law (LGPD, English translation), the General Data Protection Regulation (GDPR) across Europe, the California Consumer Privacy Act (CCPA), and the California Privacy Rights Act (CPRA). AG's digital data, technology & Information Security  (DDTIS) contact details are set out at the end of this notice.

AG along with the entities operating under its purview shall at all times endeavour to operate and function in the pursuit of 'air tight' privacy. This, in part, relying on legislative expectations and safeguarding measures, our governing statutory framework, and Human Rights Act 1998 (HRA 1998).

The Group approaches its responsibility and accountability in relation to privacy and security with seriousness. Aligned and reflecting the highly sensitive nature of much of our interactions. The purposes for which we process personal data are determined in accordance with our statutory function.

The personal data that we process may be received in connection with the general work that we do, (under our statutory functions), including data received in the course of our purchasing, personnel / human resources, recruitment activities, and the normal administration of a membership- club and community, service provider, or intermediary.  Personal data may be received by us in several ways. For example: -

- individuals may contact the group directly;
- individuals may wish to attend one of our events;
- individuals may apply for a job with us;
- individuals may visit our premises;

- individuals may meet with a representative of the group;
- we may purchase goods or services from a supplier.

We may have CCTV or such-like coverage of our events, sites, interviews, and meetings and we may monitor activity in the vicinity for only security purposes.

We may also collect personal data when you visit our public and gated websites deriving from and including (www.arabantgroup.com).  Our websites contain a 'website privacy notice or policy' providing information on any personal data they collect. Should this not be apparent, the observer can rely upon or revert to this notice herein or contact our Group Information Officer.

We keep personal data only for as long as it is necessary for us to do so for the purposes for which the data is processed.

In the capacity of acting as an intermediary, it may be necessary to share certain personal data to support you in some way. Therefore, upon your approval [given in writing] in the process of becoming a member, holding a membership, or as part of any employment collaboration, vendor, supplier, or operational partner process we may share, or be required to share information necessary and proportionate for the proper discharge of our statutory functions or legal requirements.

As data controllers, we may also use third parties who provide various services to us to process personal data on our behalf. Such data processors are only permitted to process personal data strictly following our instructions. They are required to hold it securely and retain it only for the period we specify. We will only use data processors who will handle data in accordance with the compliance requirements of the APPI, CCPA, CPRA, DPA, GDPR, and LGPD.

We would only share information about an individual with third parties directly where we have your agreement to do so.

Arabant Group provides support and services to adults [defined in exceptions as age 18 but normally age 21] and does not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our service.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our policy by instructing their children never to provide Personal Information on our service without their permission.

If you have reason to believe that a child under the age of 13 has provided personal information to Arabant Group through any of our online services, please contact us, and we will use reasonable efforts to delete that information from our databases.

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the personal information categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect your personal information, where we obtain the personal information, and the third parties with whom we may share your personal information. 

We generally collect the following categories of personal information about you when you use our site or services: 

• identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices; 
• protected classifications, such as gender; 
• commercial information such as records of products or services purchased, obtained, or considered by you; 
• Internet or other electronic information regarding your browsing history, the webpage visited before you came to our site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
• audio recordings of your voice to the extent you call us, as permitted under applicable law; 
• professional or employment-related information.

We collect your personal information for the business purposes. The CCPA defines a “business purpose” as the use of personal information for the business’s operational purposes, or other notified purposes, provided the use of personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or another operational purpose that is compatible with the context in which the personal information was collected. 

Privacy Rights

If you are a California resident, you have rights in relation to your personal information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us or the security of our network systems.

• Right Against Discrimination - You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
• Right to Know - You have the right to request in writing: (i) a list of the categories of personal information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties' direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.
• Right to Delete - You have the right to request us to delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.

To assert your right to know or your right to delete your personal information, please contact us according to the “Contact Us” area of this site or the data protection team. To verify your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

As described in this Privacy Policy, in certain situations we may share your personal information with certain third parties to achieve the goal of providing services to you. To the extent such sharing is considered a “sale” under the CCPA, as a California resident you have the right to opt-out of such sharing. If you would like us to no longer share your personal information in this way, you can opt-out by notifying our data protection team or the Group Information Officer. If you opt-out, we may be unable to offer you some of our services which require sharing of personal information.

California consumers may also use the Digital Advertising Alliance’s tool to send requests under the California Consumer Privacy Act (“CCPA”) for a web browser to opt out of the sale of personal information by some or all of that framework’s participating companies by accessing the DAA’s tool here: https://www.privacyrights.info/, or by downloading the DAA’s AppChoices mobile application opt-out here:  https://www.privacyrights.info/appchoices.  

The AppChoices app is not limited to opt-outs for CCPA purposes and may be used by anyone to limit the collection of cross-app data for interest-based advertising purposes by participating DAA member companies.

In addition, under California Civil Code Sections 1798.83–1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.

If you are a California resident and would like a copy of this notice, please submit a written request to dpa@arabantgroup.com or the Group Information Officer ddtis@arabantgroup.com

Under the data protection legislation, individuals have certain rights over their personal data, as outlined in DPA. 

- The right of access (also known as a subject access request) provides that data subjects have the right to ask for copies of their personal data. The report is free and although we endeavour to provide the report without charge, administration in certain circumstances can attract a charge up to GBP £50 / USD $60 for each request.

- Automated decision making. Data subjects have the right to object to any decisions that have affected them significantly, if they consider these decisions to have been made without any meaningful human input.

- The right to object to processing provides that individuals have the right to ask us to restrict the processing of their personal data in certain circumstances.

- The right to rectification and erasure - individuals have the right to ask us to rectify or delete personal data that they can demonstrate is inaccurate.

In order to exercise the rights listed above (but subject to the exemption for safeguarding) individuals should contact the AG GIO.

If an individual feels we haven't handled their personal data appropriately or wish to lodge a complaint, they can contact the CIO at the address provided below.

To contact Arabant Group about any aspect of our data protection policy, you initially email: dpa@arabantgroup.com

To contact the Group Information Officer:

Online contact: gio@arabantgroup.com

We collect certain information or data about you when when you visit our public and gated websites deriving from and including (www.arabantgroup.com)

This includes:

• questions, queries or feedback you leave, including your email address if you send an email to our website
• your IP address from which you access our website, and details of which version of web browser and operating system you used
• the date and time of your visit
• clickstream data, which is information on how you use our website, using cookies and page tagging techniques to help us improve our website
• the website address of the website from which you accessed our website
• anonymised Google Analytics data that you may have offered to other sites, such as your age range or gender
• details to allow you to access AG Group offerings, e.g. an email address (you’ll always be told when this information is being collected, and it will only be used for the purpose you provide it for)

This helps us to:

• improve our website by monitoring how you use it
• respond to any feedback you send us, if you’ve asked us to

Unless you voluntarily submit personal information to us (for example, by completing the any of our forms or data collection points), we can’t personally identify you using your data.

The group operates under a 'paperless' regime. We store data digitally on secure servers. Your data can only be viewed by our staff. By submitting your data, you agree to this.

Transmitting information over the internet is generally not completely secure, and we can’t guarantee the security of your data in this regard.

Equally, any data you transmit to us is at your own risk.

We have procedures and security features in place to exercise due diligence in keeping your data secure once we receive it.

We won’t share your information with any other organisations for marketing, market research, or commercial purposes, and we don’t pass on your details to other websites. We may pass on your personal information if we have a legal obligation to do so, or if we have to enforce or apply our terms of use and other agreements. This includes exchanging information with other government departments for legal reasons.

Our website contains links to and from other websites. This privacy policy only applies to our website.

If you go to another website from this one, including any websites (including government websites) that we link to, you should read the privacy policy on that website to find out what it does with your information. If you go to another website from this one, as a function of being the digital data intermediary, personal information collected about you on our website may pass to the destination website.

If you come to our website from another website, we may receive personal information about you from the other website. You should read the privacy policy of the website you came from to find out more about this.