Privacy Policy

This Privacy Policy discloses the privacy practices for the Arkett Solutions, Inc. (“Company”), (https://arkettsolutions.com) website and various related services including mobile applications, etc. (together referred to as the “Site”). Arkett Solutions, Inc., the provider of the Services (referred to as “us ” or “we”), is committed to protecting your privacy online. Please read the information below to learn the following regarding your use of our Services. You acknowledge that this Privacy Policy is part of our Terms of Use, and by accessing or using our services, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or use our Services.

Types of Collected Information

Arkett Solutions, Inc. (“Company”) may receive, collect and store any information User enters on Company’s website or provide us in any other way. In addition, Company may collect the Internet protocol (IP) address used to connect User’s computer or other electronic device to the Internet; login; e-mail address; password; computer and connection information and purchase history. User acknowledges Company’s minimum age requirements and certifies they are at least 18 years of age. Company may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page or the mobile app. Company may also collect personally identifiable information (including name, email, password, communications); payment details (including credit card information), comments, feedback, recommendations, and personal profile.

Methods of Collection

When Users conduct a transaction on Company’s website, their personal information including User’s name, address and email address is collected. Reasons for information collection are described in the following section.

Reason for Collection of Information

Company collects such Non-personal and Personal Information for the following purposes:

1. To provide and operate the Services;
To provide Company’s Users with ongoing customer assistance and technical support;
To be able to contact Company’s Users with general or personalized service-related
notices and promotional messages;
To create aggregated statistical data and other aggregated and/or inferred Non-personal
Information, which Company or Company’s business partners may use to provide and
improve Company’s respective services;
To comply with any applicable laws and regulations.

Security and Storage of User and Visitor Information

Users refer to all individuals that utilize the Site with login information, while visitors refers to anyone who visits the site, regardless of having a login. Company shall make use of technical and organizational measures specifically designed to protect User and Visitor information that is under Company’s control. Employees are aware of and shall follow all of Company’s data privacy policies and procedures. Company shall make use of firewalls designed to protect against intruders and test for network vulnerabilities. However, no method of transmission over the internet or method of electronic storage is completely secure and Company shall not be liable for any data breach that occurs.

Communication with Site Users

Company may contact User for notifications regarding User’s account, to troubleshoot problems with User’s account, to resolve a dispute, to collect fees or monies owed, to poll User’s opinions through surveys or questionnaires, to send updates about Company, or as otherwise necessary to contact User to enforce Company’s User Agreement, applicable national laws, and any agreement Company may have with User. For these purposes, Company may contact User via email, telephone, text messages, and postal mail.

Usage of cookies and Similar Tracking Tools

When you use our Site, we may store cookies on your device in order to facilitate and customize your use of our Site. A cookie is a small data text file, which a website stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the country where you are located, and your first name to welcome you back to our Site. The cookies make your use of the Site easier, make the Site run more smoothly and help us to maintain a secure Site. You are always free to decline our cookies if your browser permits, but some parts of our Site may not work properly in that case. We will collect and use Non-Personally Identifiable Information about you, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server. Company shall not be liable for the placement of third party cookies or utilization of other tracking technologies. Users, through their usage of Site, agree to release the Company from any liability regarding third party cookies. Data usage fees may apply, and shall be the sole responsibility of User.

Withdrawal of Consent

If User no longer wishes Company to process User’s data, please contact us at privacy@arkettsolutions.com or send us mail to: PO BOX 8434, Round Rock, Texas 78683.

Control your Data

You are in control of your data and when you close your Koiino account, all your personal information and all the data created by you is permanently deleted, Koiino will no longer have access to your data and the data cannot be recovered.

If you no longer have access to your account and cannot recover access to your account, you can request to delete your account by emailing support at support@koiino.app and provide the necessary proof of ownership to process the request.

For more information about how to close your account, go to https://help.koiino.app/help/close-your-account/.

Privacy Policy Updates

Company reserves the right to modify this privacy policy at any time for any reason. It is User’s sole responsibility to check these policies so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. Should the

Company make material changes to this policy, Company will notify User here that it has been updated, so that User is aware of what information Company collects and how it is used.

Policy Scope

This Privacy Policy shall not apply to information that User has provided to third parties. Company’s platform may direct User to a third-party service; however, disclosure of information to these third parties shall be subject to the relevant third party’s privacy policy. Company accepts no responsibility for the third-party’s content, procedure or privacy policy.

California Privacy Statement

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

Publicly available information from government records. • De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

Directly from our Consumers or Service Providers.
Indirectly from our Consumers. For example, through information we collect from our Consumers in the course of providing services to them.
Directly and indirectly from activity within our Site. For example, from submissions through our Site or Site usage details collected automatically.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided.
To provide you with information, products or services that you request from us.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
To improve our Site and present its contents to you.
For testing, research, analysis and product or service development.
As necessary or appropriate to protect the rights, property or safety of us, our Consumers,
Service Providers or others.
To respond to law enforcement requests and as required by applicable law, court order, or
governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in
the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information
Category G: Geolocation data

We disclose your personal information for a business purpose to the following categories of third parties:

Our affiliates.
Consumers and Service Providers.
Third parties to whom you or your agents authorize us to disclose your personal
information in connection with products or services we provide to you.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists
disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose or identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable
consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us through our Site.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12- month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our Site.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us through the Site using “ATTENTION: PRIVACY COMPLIANCE OFFICER” in the message.

Your General Data Protection Regulation (“GDPR”) Rights

If you are a citizen of the European Union (“EU”), you are entitled to certain rights under the GDPR. You have the right to:

Know how long we’ll keep your information. We’ll keep your personal information until the earlier of: (1) you either ask us to delete your information or (2) the Company decides it no longer needs the data and the cost of retaining it outweighs the value to keeping it.
Access, rectify or erase your personal information.
Withdraw your consent to the Company’s processing of your data, which shall have no effect on the lawfulness of the processing of your personal information prior to your withdrawal.
Lodge a complaint with a supervisory authority that has jurisdiction over GDPR issues.
Provide only your personal information which is reasonably required to enter into a contract with us. The Company will not ask for your consent to provide unnecessary personal information on the condition of entering into a contractual relationship with the Company.