Privacy Policy - Arena Financial Services

Last Updated and Effective: March 23, 2023

NOTICE TO CALIFORNIA RESIDENTS

You are visiting a website owned and operated by ARENA and its subsidiaries (collectively, “ARENA ”, “us”, “we”, or “our”) are committed to maintaining your confidence and trust as it relates to the privacy and usage of your information. Please read below and learn how we collect, protect, share, and use your information as part of our technology platforms, and all of our products and services.

This privacy policy applies to https://Arenapay.io, https://Arenacfo.com, and all websites owned and operated by ARENA on which this privacy policy is displayed (such websites referred to hereafter as the “Website(s)” or “Site(s)”, whether individually or collectively) as well as ARENA affiliates.

Information We Collect

Identifying Information: We collect information that could identify you such as your name, address, telephone number, mobile number, email address, and Social Security Number. We may also collect this type of information from you about others, such as co-borrowers.
Other Information: We also collect information such as demographic data, data about your online activity, and other information that is not used to identify you.

How We Collect Information

Information provided by you: We collect information from you when you enter it or otherwise provide it in connection with an inquiry into our Services. This information could be provided via an online form, over the phone, or via other means in which you interact with our Services.
Information from service providers: Information is collected from third-party service providers, such as credit bureaus and service providers who may have data on your financial profile, home, or other demographic information
Information from cookies and other tracking technologies: We use cookies, web beacons, and similar technologies to record your preferences, track the use of our Site and collect Information. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of our Site may not function properly.

How We Use Information

We may use collected information to:

Deliver the products and services you requested
Improve customer service
Improve our Site
Personalize your user experience
Communicate with you about products or services that may be of interest to you
Manage our business

Who Do We Share Your Information With?

ARENA affiliates: We may share information about you or provided by you with the ARENA affiliates.

Network Partners: In submitting an inquiry or using another other Service provided through the Website, you agree that ARENA may share information about you or provided by you with lenders and other third parties which provide services to our consumers in our network (collectively, “Network Partners”) to deliver the products and services you requested. PLEASE NOTE: The Network Partners that interact with you may retain or use your information whether or not you use their services. You should contact these Network Partners directly concerning their privacy and information sharing practices. Pursuant to the contracts between ARENA and its Network Partners, if you select a Network Partner through a ARENA website, ARENA may also receive information about you from that Network Partner including, but not limited to, the amount or disposition of your Loan. ARENA and its Network Partners may exchange information about you, your loan terms, and your accounts for the purpose of providing you with information about financial services and products. ARENA may maintain this information to assist with litigation, regulatory request(s), law enforcement requests, internal analytics, marketing purposes, and any other legally permissible purpose.

ARENA Service Providers: We may share information with Service Providers that perform certain services on our behalf including, but not limited to, credit bureaus, marketing partners, or entities providing business analysis and/or website or product support.

Other Situations: We may also disclose information about you or provided by you at our sole discretion:

In response to a subpoena or similar investigative demand, a court order, a request for cooperation from a law enforcement agency, self-regulatory body, or other governmental agency; to establish or exercise our legal rights; to defend against legal claims; or as we reasonably believe is required by law. In such cases, we may raise or waiveany legal objection or right available to us.
When we believe disclosure is appropriate in order to investigate, prevent, or take action regarding actual or suspected illegal activity or other wrongdoing; to protect and defend the rights, property, or safety of the ARENA Business, our users, our employees, or others; or to enforce our Site’s terms and condition or other agreements or policies.
In connection with a substantial corporate transaction involving the ARENA Business, such as a sale of ARENA or any entity, brand or division thereof, a divestiture, merger, consolidation, asset sale, or bankruptcy.
In connection with state and/or federal licensing requirements regarding the reporting of information contained in the loan inquiries we receive from you. You authorize ARENA to obtain any and all required information from the Network Partners that have interacted with you in order for ARENA to comply with current laws and regulations as well as with any requests from state or federal regulators. This information could include, but is not necessarily limited to, the loan you selected and the terms of the loan you selected.
We may share information with third parties that is not personally identifying, such as aggregated or anonymized data, in our discretion, where not prohibited by law.

Cookies and Do Not Track

We may use cookies and other technologies such as web beacons and pixels to collect information about your online activities over time and across third-party websites or online services or which may allow a third party to track your online activities over time and across different sites when you use the Websites.
The Websites do not support Do Not Track browser settings and we do not participate in any frameworks that respond to Do Not Track signals.

Marketing and Communications

Communications: You may adjust your communications preferences through your My ARENA profile. You may also modify your preferences by clicking on an unsubscribe link at the bottom of certain emails sent from ARENA .
Advertising on third party sites: We may use third-party tracking technology. This technology allows targeted advertisements to you from ARENA Businesses. Some of these advertising companies may be networks that are members of the Network Advertising Initiative which offers a single location to opt out of ad targeting from member companies. The opt-out is available at http://optout.networkadvertising.org/#!/

Updating and Accessing Your Information

The appropriate method(s) for accessing your information, if any, will depend on which Site or services you have used. Depending on the respective Site or service, you may have the ability to view or edit some of your information online using the respective Site or service’s interface. If you have submitted a loan request through us, you can update your information by contacting us at support@arenacfo.com. Our address is Arena 4023 Chain Bridge Rd Suite 6, Fairfax, VA 22030.

How We Protect Your Information

We follow industry standard security measures (including physical, electronic, and procedural measures) to help safeguard your information from unauthorized access and disclosure. We also require employees to comply with information security safeguards, we use encryption in the transmission of your information between your system and ours, and we use firewalls and other intrusion detection and prevention controls to help prevent unauthorized persons from gaining access to your information.
No system can be completely secure. Therefore, although we take steps to secure your information, we cannot guarantee that your information, searches, or other communication will always remain secure.

Changes to this Privacy Policy

ARENA has the discretion to update this privacy policy at any time. When we do, we will revise the date at the top of this page. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Visiting our Websites From Outside the United States

The Site is governed by the laws of the United States and is intended for the enjoyment of individuals connected to the internet from a physical location within the United States only. We make no representation that the Site is governed by or operated in accordance with the laws of any other nation.

Compliance with Children’s Online Privacy Protection Rule

This Website and App are not intended for individuals under 18 years of age, and we do not knowingly collect personal information from individuals under 18. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete the information. If you believe we might have any information from or about a person under 18; please contact us at 1 (800) 555-8733.

Online Tracking Opt-Out Guide

Like many companies online, we use services provided by Google, Facebook and other companies that use tracking technology. These services rely on tracking technologies – such as cookies and web beacons – to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet. There are a number of ways to opt out of having your online activity and device data collected through these services, which we have summarized below:

Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.

Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:

Google: https://adssettings.google.com
Facebook: https://www.facebook.com/about/ads
Twitter: https://twitter.com/personalization

Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

Digital Advertising Alliance: http://optout.aboutads.info
Network Advertising Initiative: http://optout.networkadvertising.org/?c=1

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

How to Contact Us

If you have any questions about this privacy policy, the practices of any ARENA, or your dealings with a ARENA, please contact us at:

Compliance Officer

ARENA

4023 Chain Bridge Rd, Suite 6

Fairfax, VA 22030

support@arenacfo.com

NOTICE TO CALIFORNIA RESIDENTS

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal Information, and of the rights and choices we offer California residents regarding our handling of their personal information (the “Notice”).

CCPA Scope and Exclusions

The description in this Notice of our Privacy Practices and your Privacy Rights apply only to California residents whose interactions with us are limited to:

Visiting our consumer websites,
Signing up for email alerts,
Commenting on or contributing to our blogs
Establishing an account that does not include financial products or services

The description in this Notice of our Privacy Practices and CCPA Privacy Rights do not apply to the personal information we collect, use or disclose about:

Consumers who initiate or complete the process of applying for financial products or services. This is because this information is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and implementing regulations, or the California Financial Information Privacy Act (“FIPA”).
Consumers who initiate or complete the process of applying for financial products or services. This is because this information is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and implementing regulations, or the California Financial Information Privacy Act (“FIPA”).

Your Rights and Choices

As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information. In addition, please note these other California-specific rights:

Exercising the right to know: You have a right to request additional information about the categories of personal information collected, sold, disclosed, or shared; purposes for which this personal information was collected, sold, or shared; categories of sources of personal information; and categories of third parties with whom we disclosed or shared this personal information.
Exercising the right to opt-out from a sale: We do not sell “Personal Information” as defined by the CCPA and have not done so in the past 12 months.
Exercising the right to limit the use or sharing of Sensitive Personal Information: we do not sell or share Sensitive Personal Information as defined by the CCPA and have not done so in the past 12 months.
Right to opt-out of sharing email: support@arenacfo.com.

Privacy Practices

We do not sell personal information. As we explain in our Privacy Policy: We use cookies and other tracking technologies to analyze website traffic and facilitate advertising. If you would like to learn how you may opt out of our (and our third party advertising partners’) use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide. Through our services – for example, by opening an account or initiating an application for financial product or services – you direct us to disclose your information to companies that provide the services in which you are interested.

How you interact with us	Personal information collection	CCPA-defined categories	Sources of personal information	Purposes for which we may collect and use the personal information	Sharing
Sign up for email alerts; Interact with our blogs; Establish an account	Name or alias; Email address	Identifiers; Online Identifiers	You	Operations; Communications; Research and development; Marketing	Shared with service providers; Made public at your direction
Visit our websites; Receive and respond to marketing emails	Device data; Online activity data; Information derived from device data and online activity data	Identifiers; Inferences; Internet or Network Information; Online Identifiers	Automatic collection	Operations; Communications; Marketing; Advertising; Research and development	Collected directly by or shared with our service providers; Collected directly by advertising partners
Apply for our open positions on our website	Contact information; Professional credentials and skills; Educational and work history; Other resume data you provide; Diversity information you voluntarily provide; Disability information where necessary	Identifiers; Online identifiers; Educational information; Professional or employment information; Protected classification characteristics	You; References; Background check and/or drug testing companies; Employment agencies or recruiters	Facilitate recruitment activities; Process employment applications; Monitoring recruitment statistics	Shared with service providers; Collected directly by or shared with background check and drug testing companies

Please note that we may also disclose all personal information (a) to comply with federal, state, or local laws; (b) to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (c) to cooperate with law enforcement agencies concerning conduct or activity that we believe may violate federal, state, or local law, (d) when we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction), or (e) to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Privacy Rights

The CCPA grants individuals the following rights:

Information. You can request information about how we have collected, used and shared your Personal Information during the past 12 months.

Access. You can request a copy of the personal information that we maintain about you.

Deletion. You can ask us to delete the personal information that we collected or maintain about you. Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. We will also respond to requests for information and access only to the extent we are able to associate with a reasonable effort the information we maintain with the identifying details you provide in your request. If we deny your request, we will communicate our decision to you.

You are entitled to exercise the rights described above free from discrimination.

How to Submit a Request

To request access to or deletion of personal information: Email: support@arenacfo.com.

Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We will ask you to verify your identity when you submit a request.

Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.