Privacy Policy

Agreement to terms

Thank you for choosing Arpeggio ("Arpeggio," "we," "us," or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at privacy@cognitionads.com.

This privacy notice describes how we might use your information if you:

• Visit our website
• Engage with us in other related ways ― including any sales, marketing, or events

The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

What information do we collect?

We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include names; phone numbers; email addresses; and other similar information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

How do we use your information?

We use personal information collected via our Website for a variety of business purposes. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We use the information we collect or receive to:

• Fulfill and manage your orders, payments, returns, and exchanges.
• Deliver and facilitate delivery of services to the user.
• Send you marketing and promotional communications, in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.
• Deliver targeted advertising to you by developing and displaying personalized content and advertising tailored to your interests and/or location, and to measure its effectiveness.

Will your information be shared with anyone?

We may process or share your data that we hold based on consent, legitimate interests, performance of a contract, legal obligations, or vital interests. More specifically, we may need to process your data or share your personal information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, we will securely store your personal information and isolate it from any further processing until deletion is possible.

How do we keep your information safe?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security. You should only access the Website within a secure environment.

Do we collect information from minors?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Website. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@cognitionads.com.

What are your privacy rights?

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. If you have questions or comments about your privacy rights, you may email us at privacy@cognitionads.com.

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Do California residents have specific privacy rights?

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes. Arpeggio has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months and will not sell personal information in the future belonging to website visitors, users and other consumers.

Do Quebec residents have specific privacy rights?

Yes, Arpeggio fully complies with Quebec's Law 25.

In compliance with Quebec's Law 25, the collection, use, and disclosure of personal information (PII) will be based on explicit, informed consent from the individual. For users accessing our services from Quebec, the default setting for data tracking and collection is set to opt-out. Users must explicitly opt-in to allow tracking and collection of their personal information.

Arpeggio has appointed its CEO as the Data Protection Officer (DPO) responsible for ensuring compliance with data protection regulations, including Quebec's Law 25. For any queries, complaints, or data-related concerns, our DPO can be reached at:

Carson Henry
privacy@cognitionads.com
830 A1A N STE 13-180, Ponte Vedra Beach, FL 32082

Arpeggio respects and upholds all data subject rights under Quebec's Law 25, including consent, transparency, privacy impact assessments, the right to erasure and rectification, data portability, and breach notification. Further details on our security measures can be found in our SOC 2 report and Incident Response Plan (IRP), which can be requested by contacting our DPO.

Data security and third-party protection

Arpeggio has implemented robust data security measures to protect personal information, particularly when working with third-party partners. These measures include data encryption during transmission and storage, access control based on the principle of least privilege, security protocol best practices including regular audits and monitoring, and limited use and retention of data shared with third-party partners.

Your rights with respect to your personal data

You can ask for the deletion of your personal information, subject to certain exceptions provided by law. Depending on the circumstances, you also have a right to know whether we collect and use your personal information, the categories of personal information that we collect, and the purposes for which it is used. We will not discriminate against you if you exercise your privacy rights. To exercise these rights, you can contact us by email at sales@cognitionads.com.

Do we make updates to this notice?

Yes, we will update this notice as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible.

How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at privacy@cognitionads.com or by post to:

Arpeggio
830 A1A North
Ponte Vedra Beach, FL 32082
United States
Email: sales@cognitionads.com