Our Commitment to Privacy ARPM, LLC (“ARPM”, “we” or “us”) is committed to
respecting and protecting your privacy. This Privacy Policy applies to all linked pages owned and operated
by ARPM and the ARPM Service (“Services”). This Privacy Policy (or
“Policy”) describes the Personal Data we collect and how we use, maintain, and sometime share
the Personal Data.
“Personal Data” includes any information that enables us to identify you, directly or
indirectly, by reference to any identifiers such as name, identification number, location data, online
identifier or one or more factors specific to you.
ARPM is the “controller” and is responsible for deciding how Personal Data is used. We are
a limited liability company organized under the laws of New York.
By accessing or using the ARPM website (the “Website”), or by providing Personal Data
to us on or through the Website, you acknowledge that you have read and understood the policies and
procedures in this Privacy Policy. This Policy is referenced in, and is an integral part of, the Terms of
Service governing ARPM.
Please read our Privacy Policy below to understand:
When ARPM collects Personal Data from you We collect Personal Data from you when you do any of the following:
Online: • When you visit our Website, our web servers identify various elements about your access, including the IP
address of your computer, type of browser, operating system, etc.
• When you complete a form, download software, sign up for a mailing list, etc.
• When you register for an ARPM account.
• When you use the ARPM cloud or community, including blog comments and user feedback.
• When you submit content through web-based sites/services.
• When you use email or other means for technical support or other help requests.
• When you attend an online training course/seminar. Go to Addendum 1 of this Privacy
Policy for our specific privacy notice on on-line lecture recordings.
• When you use web-service-accessing commands in a desktop product.
• When you interact with our automated AI-powered website chatbot.
In Purchases: • When you purchase a product or service, including but not limited to licenses to electronic books,
courses, or other content.
• When you access products via a site associated with your organization or institution.
On the Phone: • When you call us for support, information, sales or other general questions about our company.
In Person: • When we host or participate in seminars, webinars, conferences, training sessions, and other in-person
events. We may ask you to complete a form if you are interested in hearing more about what ARPM has to
offer.
What Personal Data ARPM collects We only collect and store the Personal Data necessary to provide you with your desired services or
products. Depending on the circumstances, the following are the types of Personal Data you might provide
us:
• Name and contact information for you as an individual or organization/institution, including email
addresses.
• Account information, such as your ARPM ID and password but we only store hashed passwords. We also may
store account information that you may choose to provide to us relating to your accounts with third-party
service providers.
• License and subscription information, such as the ARPM products and services you have purchased and the
licensed users and devices for those products.
• Usage information, such as which ARPM products and services you use, when and how you access or use our
products and services, error reports, web analytics (cookies) and performance data.
• Device and network information, such as your IP address and operating system.
• The content of your communications to us, such as feedback and technical support requests.
• Chatbot transcripts, including the text of your conversations, queries, and any feedback or reports you
submit regarding the chatbot's answers.
• Other information that you submit to ARPM, such as information requests, use of ARPM online data upload
and storage, or submissions to community or other websites.
How ARPM uses the Personal Data collected • To provide products, services and support requested by you or on your behalf.
• To process and ship orders that you place with us or that are placed on your behalf, and to provide you
with documentation or other material in support of such orders.
• To enable registration or to authenticate an ARPM ID.
• To provide you with secure use of our Website, products and services.
• To manage licenses or subscriptions and the use of our products and services.
• To administer and improve our products, Website and services.
• To enable delivery of training or other services.
• To provide responsive and accurate information in conjunction with an order for products or services.
• To respond to or record an application for the ARPM bootcamp, seminar, conference or other event.
• To obtain feedback measuring your satisfaction with ARPM products, services and events.
• To notify you of new products, updates and other information about ARPM products or services.
• To provide information regarding the renewal of agreements, version upgrades and other notifications
about products and services that you license or use.
• To send promotional material about our company, products, services and events. You may opt out.
• To show ads to you across the internet, including on the Google Content Network (GCN), and various social
media platforms such as LinkedIn and Facebook.
• To allow you to integrate ARPM products and services with third-party services at your request.
• To fulfill our agreements or comply with obligations imposed by applicable laws or law enforcement.
• To create anonymous data (without personally identifiable information) which we may use to improve the
functionality of our Website.
• To respond to your inquiries via our website chatbot, and to allow human supervision and review of reported
chatbot interactions for quality assurance.
Why ARPM retains some Personal Data Consent: You have given us clear consent to process your Personal Data for specific purposes.
Contract: Some Personal Data is necessary if we have a contract with you or to complete specific
steps before entering into a contract with you.
Legal obligations: ARPM may be sometimes required to process Personal Data for non-contract based
legal requirements.
Legitimate interests: The processing of your Personal Data is necessary for ARPM's legitimate
interests.
How long and where ARPM retains and stores Personal Data We retain the Personal Data collected on our Website as long as necessary to provide the services, products,
and information associated with their use, to fulfill the purposes outlined in this Privacy Policy, or as permitted
by applicable law. For instance, we may retain and use your Personal Data as necessary to comply with our legal
obligations, resolve disputes, prevent fraud and abuse, and fulfill and enforce our agreements.
Specifically, for interactions with our website chatbot, ARPM retains chat transcripts for 12 months for
quality assurance and customer support review, after which they are securely deleted. Additionally, you can delete
your conversations at any time by clicking the designated button directly within the chatbot interface. Finally,
as noted, our chatbot provider (OpenAI) retains API data for only 30 days.
All Personal Data supplied to ARPM is logged on our servers, which may be hosted by a third-party provider.
This data is stored on strong and reliable systems that are continually monitored and updated as per the latest
security practices for data protection.
How ARPM secures Personal Data We utilize encryption/security software to safeguard the confidentiality of Personal Data we collect from
unauthorized access or disclosure and accidental loss, alteration, or destruction. To the extent permitted
by applicable law, we cannot be held responsible for any unauthorized person illegally obtaining that
information.
When ARPM shares Personal Data with third parties We will not share, rent, sell or otherwise disclose Personal Data, except in the following situations:
• You request or consent to the release of your Personal Data.
• We will disclose your Personal Data to third-party contractors and payment processors who perform
services for us in connection with our Website, or to complete or confirm a transaction or series of
transactions that you conduct with us.
• We will disclose your Personal Data to service providers or suppliers where the disclosure will enable
that party to perform business, professional or technical support for us.
• Third-party vendors, including Google, LinkedIn, and Facebook, whose services we use, will place cookies
on web browsers to serve ads based on past visits to our website.
• Where you have provided your consent, which can be withdrawn at any time, we will provide your Personal
Data to other select third parties approved by ARPM as offering products or services relevant and useful to
you. The use by and/or content of communications from any third party will be pre-approved by ARPM.
• We may disclose Personal Data you have provided to comply with the law, applicable regulations,
governmental and quasi-governmental requests, court orders or subpoenas, or to enforce our Terms of Service
or other agreements; or to protect our rights, property or safety or the rights, property or safety of our
users or others.
• We share your chat inputs to OpenAI via their API when you interact with the chatbot. OpenAI retains these
inputs on their servers for a maximum of 30 days strictly for abuse and misuse monitoring purposes, and does not
use your data to train their models.
We reserve the right to release information that we collect to law enforcement or other
government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.
We also may share aggregated or anonymous information with third parties. For example, we may disclose the
number of visitors to our Website or the number of people who have downloaded a particular document.
Your rights with respect to Personal Data ARPM processes and retains For European residents only. Under European data protection law, you have rights to make certain requests about your Personal Data as
noted below in certain circumstances. Your rights include, but are not limited to:
• The right to request access to your Personal Data.
• The right to correct your Personal Data so that it is accurate and updated.
• The right to request your Personal Data be restricted or removed.
• The right to data portability, allowing you to move, copy or transfer Personal Data.
• The right to withdraw consent to processing of your Personal Data.
Please note that in some cases, we may not be able to fully comply with your requests. For example, even if
you request that we delete your Personal Data, we may need to retain your data for legal reasons. In these
cases, we will explain the extent to which we were able to comply. If you wish, you can request to receive
Personal Data in possession of ARPM that concern you in a format readable by electronic devices and, where
technically possible, we can transfer your data directly to a third party indicated by you.
Contacting ARPM regarding your Personal Data and your rights By emailing us at info [AT] arpm.co. or writing us at:
ARPM, LLC
Attn: Compliance Department
PO Box 21079
New York, NY 10023
you can exercise various rights as outlined herein. The actions we are able to take depend on the specific
Personal Data and the lawful basis under which we are processing it. If you do not wish to receive
marketing information from ARPM or wish to opt out of future email promotions from ARPM, please email or
write us. Please note that all promotional email messages you receive from ARPM will include an option to
opt out of future email communications.
California Residents California law permits California residents to request certain information regarding disclosure of your
Personal Data to third parties for their direct marketing purposes. To make such a request, please send an
email to info@arpm.co specifying that you seek your “California Customer Choice Notice” in
the subject line.
Links to Other Sites We are not responsible for the practices employed by websites linked to or from our Website, nor the
information or content contained therein. Often links to other websites are provided solely as pointers to
information on topics that may be useful to the users of our Website. Please remember that when you use a
link to go from our Website to another website, our Privacy Policy is no longer in effect. Your browsing
and interaction on any other website, including websites which have a link to our Website, is subject to
that website’s own rules and policies. Please read over those rules and policies before proceeding.
Messages, conversations with AI, and Other Communications Communication with other members of the ARPM community is one of the Website’s features. Communications in the
form of highlights, notes, comments, posts, chats, answers, votes, or other inputs that you share with other users
are considered to be publicly disclosed to those users. Always use caution when giving out any personally
identifying information about yourself through the act of discussions, chats, or other communication channels.
Similarly, when interacting with our automated chatbot, please exercise caution and avoid sharing sensitive
personally identifying information. To the extent permitted by applicable law, ARPM is not responsible for the
Personal Data you choose to share within these messages or through the channels provided as a service of the
Website.
Child Privacy If you are under the age of majority in your home jurisdiction, please do not use or access the Website. It
is not our intention to collect or use Personal Data from anyone under the age of majority, and we will not
knowingly do so. If we are made aware that we have collected any Personal Data from minors, and are asked
to delete such information from our databases, we will promptly do so.
Policy Changes We may amend this Privacy Policy and our data collection and management practices. We reserve the right to
make changes to this Privacy Policy at any time. The use of your information is subject to the Privacy
Policy and Terms of Service at the time of use. The provisions contained in this Privacy Policy supersede
all previous notices or policies regarding our privacy practices with respect to the Website. Please check
the “Last Modified” legend on the first page to see when this Privacy Policy was last revised. We encourage
you to check frequently to see the current Privacy Policy to be informed of how we are committed to
protecting your information and providing you with improved content on our Website.
Access from Outside the United States If you access a Website from outside of the United States, information that we collect about you will be
transferred to servers inside the United States, which may involve the transfer of information out of your
country of origin. By allowing us to collect Personal Data about you, you consent to such transfer and
processing of your Personal Data.
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If you have questions or wish to send us comments about this Privacy Policy, please send an email with
your questions or comments to info [AT] arpm.co, or write to us at:
ARPM, LLC
Attn: Compliance Department
PO Box 21079
New York, NY 10023
Addendum 1 Data Protection Notice for Zoom Online Lecture Recordings
ARPM uses “Zoom” to conduct online-classes. Zoom is a service of Zoom Video Communications,
Inc. which is based in the U.S.
Date Controller ARPM is the data controller for conducting online classes.
Zoom is a cloud-based service which means that the data required for the use of the conference service are
processed on Zoom servers. If you visit the Zoom website, Zoom is responsible for data processing. However,
you do not need to register with Zoom. You only need to visit the Zoom website to download the Zoom
software. You can use the service without having a Zoom account or being a registered user. If you register
with Zoom, the terms and conditions and data protection policy of Zoom apply.
ARPM has entered into a data processing agreement with Zoom with EU standard contractual clauses, which
complies with Article 28 GDPR.
Type of data processed
Different personal data may be processed such as the following.
User data: prename, surname, phone number (optional), email address, password (if
“single-sign-on” is not used), profile picture (optional), department
(optional)
Meeting metadata: topic, description (optional), participant IP address,
device/hardware information
If being recorded: MP4 files of all video, audio and presentation recordings; m4a files
of all audio recordings; text files of the online-meeting chats
Phone dial: entries of incoming and outgoing phone number, country name, start and end
time, in some cases further connection details like IP address of the device
may be stored
Text, audio and video data: You potentially have the possibility to use chat, Q&A and
polls during the online meeting. The data entered there is processed for the
purpose of making it visible and possible to protocol. To enable the display
of video and the rendering of audio, corresponding data will be collected
from the microphone of you device and any video cameras of your device for
the duration of the meeting. You can turn off the camera or microphone in
the “Zoom” application at any point of the session.
Why are teaching sessions recorded?
Live teaching sessions are conducted during business hours, North American and European time zones. ARPM
sometimes records the online teaching sessions to allow students in Asian time zones to view them.
How do I know if the teaching session is being recorded?
To participate in the live teaching session, you will need to click a video meeting button to connect to the
Zoom video session. You will see a notice near the video button that the video session will be recorded.
Once you connect to the Zoom session, you will see another notice that the session is being recorded, as
follows:
You can either (i) consent to be recorded and click “Continue” to join the session, or (ii) click “Leave
Meeting” to end the session. If you click “Continue” to join the session, you will see a red circle and the
red text “Recording” on your computer screen. If you have phoned into Zoom, instead of using the software,
the Zoom-voice will state “This meeting is being recorded”.
What is the lawful basis of processing personal data in the recorded lecture?
The lawful basis for processing this personal data is legitimate interests. Legitimate interest applies when
the data processing is not required by law but is of a clear benefit to a company or individual, there is
limited privacy impact on you as the individual, and we think you would reasonably expect us to use the
personal data in the way that we wish to.
I opt out of having my personal data recorded?
You have the option of muting your microphone and turning off your webcam. You also can choose the name
displayed in your Zoom account and Zoom call. Although we prefer you use your real name so the instructor
and other students know who you are, you do not need to show your full or real name. If you are phoning into
the Zoom teaching session, instead of using the Zoom software the name of your phone or phone number may
show up in Zoom for other participants to see. If you do not want this to show up, you may be able to hide
your number by entering a prefix for blocking caller ID before entering the phone number. This prefix
depends on the country/region your voice number is from. For example, if your voice number is from the U.S.,
then the prefix *67 typically works though it is not guaranteed.
How are the recordings stored and shared?
ARPM may permit students located in the Asian time zones, who are registered for the course, to view
recorded teaching sessions. For these students only, a link to the recorded session may be made available
for one time viewing approximately 12 hours after the live recorded session has ended. The link will not
allow students to download the recordings and students are prohibited from downloading or otherwise copying,
sharing or editing the recordings. The recording will be stored on Zoom cloud for the one time viewing by
these students, following which the recording will be permanently deleted shortly thereafter.
