Privacy Policy: Digital Platforms

Effective Date: 09/23/2021

Last Updated on: 09/16/2022

Introduction

Arival Pte. Ltd. ("Company" or "we" or “us”) and it’s subsidiaries respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes our practices for collecting, using, maintaining, protecting, and disclosing information that we collect from you or that you may provide when you visit or use our digital platforms (“Digital Platforms”):

Arival Bank webpage (arival.com)
Arival Bank Mobile App
ArivalOS Online (app.arival.com)
A.ID Online (auth.a-id.co)
Our Arival Bank Branded social media sites or pages, and
E-mail sent through the Digital Platforms.

This policy DOES NOT apply to information that:

You provide to or are collected by any third party (see Third-Party Information). For example, the information you provide to websites linked to the Digital Platforms. These other third parties have their own privacy policies, which we encourage you to read before providing information on or through them
Intercom, Osano, Google and AWS (Amazon Web Services).

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. “You” refers to the natural person using the Digital Platform as a client of Arival Bank International Corp or visitor of the Digital Platforms for personal purposes. If you do not agree with our policies and practices, do not download, register with, or use our Digital Platforms. By downloading, registering with, or using our Digital Platforms, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy). Your continued use of our Digital Platforms after we revise this policy means you accept those changes, so please check the policy periodically for updates.

If you have a financial product or service with us for personal, family or household use, we would also have delivered to you a U.S. Customer Privacy Notice that explains how we collect, use and share nonpublic personal information about you, and offers you certain choices with respect to the use and sharing of your nonpublic personal information.

Children Under the Age of 13

Our Digital Platforms are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@ariv.al.

1. What Information Do We Collect and How Do We Collect It?

We collect information from and about users of our Digital Platforms:

Directly from you when you provide it to us.
Automatically when you use the Digital Platforms.
Cookies and session information.

We collect two types of information:

Personal Information - Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Personal Information includes Personally Identifiable Information (as that term is defined by U.S. law), Protected Health Information (as that term is defined by the U.S. Health Insurance Portability and Accountability Act) and Sensitive Personal Information, (as that term is defined by the E.U. General Data Protection Regulation). Does not include your information or data made publicly available by the government.
Non-Personal Information - Other information that does not identify you or your household, such as information that has been de-identified or aggregated, and anonymous data

More specifically:

	Information we collect in relation to each Digital Platform source:
Arival Bank Webpage	*Information you provide to us: Information that identifies you as an individual or relates to identifying information about you, such as name, residential or mailing address, email address, and telephone number (“Basic Contact Information”); your search queries, and other information you enter in the Webpage. Automatic information collection and tracking: Our Web Pages and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain webpage content and verifying system and server integrity). Business purpose for collecting this information*: intake of possible new customers; improving our Webpage, performing research and business analytics, and identifying usage trends; tailoring marketing communications from our affiliates as well as from selected third parties; managing our business effectively; and developing new products and services.
ArivalOS and A.ID Online	*Information you provide to us: Basic Contact Information, date of birth, social security number, education, employment, identification cards (e.g. driver’s license, green card, national ID, passport)(“ID cards”), your Online user ID and access credentials (PIN, passwords, security codes, access codes, security questions) (“Access Credentials”); Geolocation via IP; your search queries, and other information you enter in the Online Service. If you have an account with us: we also collect account numbers, debit/credit card numbers, and other account information including: account holder name, account Access Credentials, legal documents, assets, transaction data/history, merchant information, and Financial documents. Automatic information collection and tracking: When you visit, access, and use our Online service, it may use technology to automatically collect: Usage Details. Details of your access to and use of the Online service, including session data, location data, usage logs and other communication data and the resources that you access and use on or through the Online service. Device Information. Information about your computer device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, and session details. These tracking technologies include internet cookies, flash cookies, web beacons, and device fingerprinting to collect from you various attributes associated with your device (such as IP address, installed fonts, language and browser settings, and time zone) in order to create a device identifier so that we can recognize your device, along with the time of your visit and the page(s) visited. Business purpose for collecting this information:* intake of possible new customers; reviewing and processing applications; reviewing, setting-up and processing the instructions provided by you for the product/services you are using; account maintenance and servicing; engaging in fraud monitoring and prevention; compliance with applicable laws and regulations; protecting our business and our customers against illegal activity; performing audits; improving our Online service, performing research and business analytics, and identifying usage trends; tailoring marketing communications from our affiliates as well as from selected third parties; managing our business effectively; and 4 developing new products and services. We also may use these automatic and tracking technologies to collect information about your activities over time and across third-party websites, apps, or other online services (session tracking).
Arival Bank branded social media sites or pages	Personal information that you share on Arival Bank -managed social media pages, such as Facebook, Instagram, Linkedin and Twitter, are subject to the privacy policies and terms of use of those platforms. Please refer to those policies before posting any content to those pages. You should NEVER provide personal information to Arival Bank through public social media pages. The information you share in such sites, pages or areas may be viewed by any user of such sites, pages or areas.
Third-Party Informat ion Collection	We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Information We Collect from Third Parties	We may collect information about you from certain third-party sources, including, for example, financial institutions and government sources. This information may include, for example, account identifiers used in transfers of funds, credit histories, credit scores, credit reports, and information from a death certificate. *Business purpose for collecting this information*: reviewing and processing applications for our product and services; intake of new customers; engaging in fraud monitoring and prevention; compliance with applicable laws and regulations; managing our business effectively; account maintenance and servicing.

2. How Do We Use Your Information We Collect?

We use information that we collect about you or that you provide to us, including any personal information, to:

Provide you with the Digital Platforms and their contents, and any other information, products or services that you request from us.
Processing applications and transactions.Verifying your identity.
Fulfill any other purpose for which you provide it.
Give you notices about your account and request your feedback.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Notify you when Digital Platform updates are available, and of changes to any products or services we offer or provide through it.
For our business purposes, and any other purposes or ways as required or permitted by law or with your consent; such as the security of your account and digital services; performing analytics concerning your use of our online services, including your responses to our emails and the pages and advertisements you view; providing you tailored content and marketing messages; operating, evaluating and improving our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions); advertise and market our products and services, and those of our business partners.

The usage information we collect helps us to improve our Digital Platform and to deliver a better and more personalized experience by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Digital Platform according to your individual interests.
Speed up your searches.
Recognize you when you use the Digital Platform.

We use location information we collect for security, fraud prevention, and to tailor marketing communications from our affiliates as well as from selected third parties.

We may use the information we collect to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information

3. How Do We Share Your Information?

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.In addition, we may disclose personal information that we collect or you provide:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business.
To a successor in the event of a corporate transaction (such as merger, sale, consolidation, or other sale or transfer of some or all of Arival’s assets or business, whether as a going concern 6 or as part of bankruptcy, liquidation, or similar proceeding) in which personal information held by Arival about our App users is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, regulatory or legal process, including to respond to any government, regulatory or law enforcement request.
To enforce our rights arising from any contracts entered into between you and us, including our Terms and Conditions, and for billing and collection.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Arival, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

4. Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures over your information.

Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can choose whether or not to allow the Digital Platforms/Webpage/App/Online Service to collect information through other tracking technologies by opting out with the cookie logo at the left bottom corner of our webpage. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Digital Platform may then be inaccessible or not function properly.
Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the App may become inaccessible or not function properly.
Promotion by the Company. If you do not want us to use your email address or contact information to promote our own or third parties' products or services, you can opt-out by filling out this form. You can also always opt-out by logging into the Digital Platform and adjusting your user preferences in your account profile by filling out the form under privacy settings.
U.S. Customer Privacy Notice. Where appropriate, for U.S. individuals that have financial product or service with us for personal, family or household use with us, we will limit sharing of your personal information in accordance with the choices you have provided us in response to our U.S. Customer Privacy Notice(s) pursuant to your Contract for Financial Services with us.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website, and from members of the Digital Advertising Alliance (“DAA”), on the DAA’s website.

5. Accessing and Correcting Your Personal Information

To change or correct your personal information, you may log into the Digital Platform and visit your account profile page. You may also request access to, correct, or delete any personal information that you have provided to us filling out this form. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

6. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any card or account transactions and Personal Information will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password or other Access Credentials for access to certain parts of our Digital Platforms, you are responsible for keeping these Access Credentials confidential. We ask you not to share your Access Credentials with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Digital Platforms. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

7. Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on our Digital Platforms with a notice that the privacy policy has been updated and notify you by email to the primary email address specified in your account or via an in-App alert the first time you use the App after we make the change.The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:Please contact us with any questions or concerns regarding our policy.

Arival Bank International Corp
c/o Privacy
1250 Ponce de León Ave, Ste 504 San Juan, PR, 00907-3914
San Juan, PR, 00907
Tel. +1 787 342 0043
Email: privacy@arival.com

To register a complaint or concern, please refer to our Digital Platforms please fill out this form.

US Consumer Privacy Notice