PRIVACY POLICY

Last Updated: May 25, 2021

WP Company LLC (“The Washington Post,” “we,” “us,” or “our”) owns and operates Arc XP (“Arc”). We recognize the importance of protecting the privacy of your personal information, and we have prepared this Privacy Policy to provide you with important information about our privacy practices. This Privacy Policy applies when you use the services made available through Arc, including the website at www.arcxp.com, Arc mobile applications, and other online services that include a link to this Privacy Policy (collectively, the “Services”). It does not govern or apply to information collected or used by The Washington Post through other means, such as information we collect in your capacity as a subscriber to our news publications. It also does not apply to data collected by third-party websites and online services developed using our Services, such as information collected by Arc customers from their subscribers.

Your use of the Services may be subject to an underlying agreement between The Washington Post and your employer or the entity who authorized you to use the Services (“Customer”). If so, in the event of any direct conflict between a term of this Privacy Policy and that underlying agreement, the underlying agreement controls to the extent of the conflict. The Arc Customer controls its instance of the Service and is the data controller of the information collected through the Service from or about its users.

Table of Contents

  • Information We Collect
  • How We Use Information
  • Sharing of Information
  • Embedded Content and Links to Third-Party Sites and Services
  • Data Security
  • Children’s Privacy
  • Online Tracking & Advertising
  • International Transfers
  • Users in the EEA, United Kingdom and Switzerland

1. Information We Collect

We may collect personal information about our users in various ways. For example, we may collect information that you provide to us, information that we collect through your use of the Services, and information that we collect from publicly available sources or third parties.

a. Information You Provide to Us

When you register or otherwise interact with the Services, you may be invited to provide personal information to us. For example, you may provide us with information when you:

· Inquire about the Services or Arc more generally;

· Use the Services, including when you register for an account or an account is created on your behalf by the Customer;

· Participate in surveys or fill out forms;

· Subscribe to newsletters;

· Request customer support and/or technical assistance; and

· Otherwise communicate with us through the Services.

The information you provide directly to us may concern you or others and may include, but is not limited to:

· Account Information: When you create an account, you may be asked for and provide to us certain information such as your name, email address, job title, phone number, employer, and employer address.

· Inquiry Information: You may also provide us certain information when you may an inquiry on our website, such as your name, email, and employer.

You are not required to provide us with such information, but certain features of the Services may not be accessible or available, absent the provision of the requested information.

If you apply for a job with us, you may also provide us with information in that application process, such as contact information, job history, education history, and other information in your resume or C.V.

Any information collected from you through the Customer’s instance of the Services, including all associated attachments, files, videos, other content submitted through the Services (“Customer Content”) is subject to the Customer’s control and privacy practices and is not subject to this Privacy Policy. Please contact the Customer whose instance of the Services you use if you have questions about Customer Content. The Customer is the data controller with respect to the processing of your Customer Content and Arc is the data processor, meaning that we collect and process such information solely on behalf of the Customer.

b. Automatically Collected Information

In addition to the information you provide to us directly, we may collect information about your use of the Services or your device. As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use cookies, web beacons, and other technologies, as detailed in the Online Tracking and Advertising section below, to assist in collecting this information.

For example, we may collect:

· Device Information—such as your hardware model, IP address, other unique device identifiers, operating system version, browser type and settings, such as language and available font settings, and settings of the device you use to access the Services.

· Usage Information—such as information about the Services you use, the time and duration of your use of the Services and other information about your interaction with content offered through a Service, and any information stored using cookies, mobile ad identifiers, and similar technologies that we have set on your device.

· Location Information—such as your computer’s IP address, your mobile device’s GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain Services.

c. Information from Third-Party Sources

We may receive information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. For example, we may receive information about you from LinkedIn, and we may obtain employment and other information about you from data resellers. We may combine information that we collect from you through the Services with information that we obtain from such third parties and information derived from other products or services we provide.

d. Other Information We Collect

We also may collect other information about you, your device, or your use of the services in ways that we describe to you at the point of collection or otherwise with your consent. You may choose not to provide us with certain types of information but doing so may affect your ability to use some of the Services.

2. How We Use Information

We use your information for various business and commercial purposes, such as:

· To provide you with the Services, including to register you for an account;

· To respond to your questions or inquiries, including to provide customer support and troubleshooting assistance;

· To communicate with you, including to send you emails about products and services that may interest you;

· To manage and remember your preferences and personalize the Services;

· To analyze and improve the Services or any other products and services we provide;

· To verify your identity;

· To comply with our legal obligations or as permitted by law;

· To protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services;

· To prevent fraud and enforce our legal terms; and

· To administer and troubleshoot the Services.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also share such data with any third parties, including without limitation, advertisers, promotional partners, sponsors, event promoters, and/or others.

3. Sharing of Information

The following provides information about entities with which we may share information. Our practices vary depending on the type of information.

· Affiliates. We may share information within our family of affiliated companies.

· Service Providers. We may share information with vendors providing contractual services to us, such as hosting vendors.

· Other Parties When Required by Law or As Necessary to Protect Our Users and Services. We may share your personal information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, our employees or agents or users or to comply with applicable law or legal process, including responding to requests from public and government authorities.

· Business Transfer. We may share or disclose certain information, in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

· Otherwise with Your Consent/At Your Direction. In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing.

We also may share other information with third parties in a manner that does not identify particular users or entities, including, for example, aggregated data about how users are using our Services.

4. Embedded Content and Links to Third-Party Sites and Services

Our Services may embed content from, or link to, third-party websites and services, including social media platforms, that are outside of our control. We are not responsible for the security or privacy of any information collected by other websites or other services. This Privacy Policy does not govern these third party’s content or services, and we encourage you to review the privacy statements applicable to the third-party websites and services you use.

5. Data Security

We have in place physical, electronic and managerial procedures to protect the information we collect online. However, as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet.

6. Children’s Privacy

We do not knowingly collect any personal information from children under the age of 16 without parental consent, unless permitted by law. If we learn that a child under the age of 16 has provided us with personal information, we will delete it in accordance with applicable law.

7. Online Tracking & Advertising

We, our service providers, and third parties that provide content, advertising, or functionality may use cookies, web beacons, mobile ad identifiers, and similar technologies to facilitate administration and navigation on the Site, to better understand and improve our Services, to determine and/or improve the advertising shown to you, and to provide you with a customized online experience.

You may choose whether to receive some forms of targeted advertising from many ad networks, audience segment providers, ad serving vendors, and other service providers by visiting websites operated by the Network Advertising Initiative and Digital Advertising Alliance.

Due to differences between using apps and websites on mobile devices, you may need to take additional steps to disable tracking technologies in mobile apps. Many mobile devices allow you to opt-out of targeted advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our apps using the standard uninstall process available on your mobile device or app marketplace.

8. International Transfers

The Services are headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Services may be collected in your country and subsequently transferred to the United States or to another country in accordance with applicable law. By using the Services, you consent to the collection, international transfer, storage, and processing of your information.

9. Users in the EEA, United Kingdom, and Switzerland

If you are a user in the EEA or Switzerland, the following information applies with respect to personal data collected through your use of our Services. Under applicable law, The Washington Post is considered the “data controller” of the personal information we handle under this Policy. In other words, The Washington Post is responsible for deciding how to collect, use and disclose the information collected pursuant to this Privacy Policy, subject to applicable law. Our contact information appears at the end of this Policy. For avoidance of doubt, Customer Content is not subject to this Policy and Arc is a data processor of such Customer Content.

Purposes of processing and legal basis for processing. We process personal data consistent with our disclosures in this Privacy Policy. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services to you; (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy; and (4) as necessary for us to comply with our legal obligations.

Laws of the EEA, United Kingdom, or Switzerland may permit you to request that we:

· provide access to and/or a copy of certain information we hold about you;

· prevent the processing of your information for direct-marketing purposes; (including any direct marketing processing based on profiling)

· update information which is out of date or incorrect;

· delete certain information that we are holding about you;

· restrict the way that we process and disclose certain of your information;

· transfer your information to a third-party provider of services; and

· revoke your consent for the processing of your information.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

To exercise any of these rights, please contact us as described in the “Contact Us” section below. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

10. Changes to Our Privacy Policy

We may modify this Privacy Policy from time to time. We will notify you of changes by posting changes here, or by other appropriate means. Any changes to the Privacy Policy will become effective when the updated policy is posted on the Services. Your use of the Services or your provision of personal information to use the Services following such changes indicates your acceptance of the revised Privacy Policy.

11. Contact Us

If you have any questions about this Privacy Policy or the Services, please contact us at privacy@arcxp.com.