Privacy Policy & Legal Information

Ares Communication Group 
Privacy Notice 

Effective Date: October 9, 2023  

1. INTRODUCTION

This Privacy Notice explains how Ares Communication Group(“ACG”) and its media sites FintechWire.com and its subsites: BanktechWire, SecuritiestechWire and InsurtechWire (referred to collectively as the “Site”) collect, use and disclose personal data about you when you use our websites, mobile sites, applications (“apps”) or other online products and services that link to this Privacy Notice, and/or receive our newsletters or emails (collectively, the “ACG Services”). If there is a conflict between this Privacy Notice and an ACG services agreement, the ACG services agreement will take precedence.

By using the ACG Services, you acknowledge you have read and accept this Privacy Notice.

The ACG Services are intended for general audiences, and we do not knowingly collect personal data from minors under 16 years of age.

2. DATA WE COLLECT

ACG may obtain information about you from a variety of sources. This includes personal data you provide to us directly, data we obtain from other sources, and data we gather through automated means.

2.1 Data You Provide to Us

We collect personal data that you provide to us when you interact with the ACG Services, including the following:

· Contact or identifier data when you sign up for ACG Services, such as your name, postal address (including billing and shipping address), email address, telephone or mobile phone number;

· Information you provide when you register for an online event or conference, such as your occupation or interests;

· User-generated content when you submit any information that others can read or view, such as your LinkedIn links, profile picture, or other information;

· Information you provide when you create a profile, participate in any interaction, such as your areas of interest, areas of expertise or gender;

· Information you provide when you use an interactive feature (such as text, chat, chat bot or article sharing options) such as your mobile phone number; and

· Customer service information, such as messages and other information you address to us through online forms, text, chat, by email, over the phone or by postal mail.

2.2 Data We May Receive from Other Sources

We may receive personal data about you in connection with the ACG Services from publicly and commercially available sources and business partners (such as social networking services with which you engage). Such personal data may include:

· Purchasing data, including information about your transactions and purchase history, membership in loyalty programs or information about advertisements you have seen or acted upon, including your interaction with advertisers’ products and services;

· Demographic data, such as gender, age range, educational level, household income range;

· Occupational data, such as profession, position, title and industry;

· Preferences and shopping interests;

· Geolocation data; and

· Your activities on other Internet sites or mobile apps, such as information about content, products, services or advertisements you have seen or interacted with, including the content, products or services of our advertisers.

2.3 Data Collected by Automated Means Through Our Services

We gather by automated means (such as cookies, web beacons, web server logs and similar technologies) certain information through the ACG Services. Such data may include:

· Your IP address;

· Device information, such as unique identifier and connection information, including mobile device advertising IDs (e.g., Apple IDFA or Google AAID);

· Your device type and settings, software used, browser type and operating system;

· Language preferences;

· Viewing behavior, including the content you view and for how long;

· Web pages and advertisements you view and links you click on within, and search queries you may have run on, the ACG Services;

· Other usage data, such as the websites or other services you visited before visiting the ACG Services (referring URL), access times and other details about your use and interactions on our Services;

· Location information, including the city, state and zip code associated with your IP address, information derived through wifi triangulation, and precise location information from GPS-based functionality on your mobile apps, with your consent; and

· Your phone number and mobile carrier details in connection with some of our mobile apps.

Cookies A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. As part of offering and providing customizable and personalized services, we may use cookies to store and sometimes track information about you. Cookies which may be utilized by ACG are within the following four primary categories or uses:

1. Business cookies which operate as a quality control and verification mechanism in connection with the survey process;

2. Performance cookies so that traffic patterns and uses on the website may be measured and optimized;

3. User cookies so that user information may be recorded so as to enhance performance and user experience on the website;

4. Targeting cookies that measure web-viewing for market research purposes.

3. HOW WE USE THE DATA WE OBTAIN

We may use the personal data we collect from and/or about you for the purposes set forth below.

3.1 To Provide and Manage the ACG Services

This may include to:

· Provide our products and services or monitor and improve the performance of such services;

· Create and manage online accounts;

· Provide customer support, including via online chat or chat bot, and to respond to inquiries;

· Send information about your relationship or transactions with us;

· Provide technical support;

· Deliver relevant content and suggestions (e.g., if you use multiple products, we may use your reading history or activity to personalize the content delivered to you across products);

· Conduct research for potential articles if you choose to respond to a journalism survey;

· Communicate about, and administer participation in, online games, sweepstakes, contests, promotions, special events, rewards programs, surveys or other interactive activities;

· Send promotional materials, alerts regarding available offers, product or service information, events, and other communications, including via text/SMS messages if you provide your mobile phone number and opted in to receive such messages (“Text Messages”). Your consent to receive Text Messages is not required to purchase goods or services from us.

3.2 To Measure and Improve Our Products and Services

This may include to:

· Operate, evaluate and improve our business (including developing, enhancing, analyzing and improving our Services; managing our communications, performing data and statistical analytics, and performing accounting, auditing and other internal functions); and

· Monitor, and analyze, the extent of your use of the ACG Services, to inform modifications, enhancements, or updates to the ACG Services.

3.3 To Deliver Interest-Based Advertising (aka Targeted Advertising)

As described in this Privacy Notice, we, as well as our third-party service providers, may obtain information about your online activity to provide you with advertising about products and services tailored to your individual interests. We also engage third party online advertising companies, advertisers, and ad networks to help target our messaging to visitors through interest-based and contextual means. These third parties may collect information about your activities on our ACG Services and on other websites or apps including offline purchases, for such purposes. The networks use this information to show you advertisements on the ACG Services or other third-party websites and apps that may be tailored to your individual interests. This information also helps us track the effectiveness of our marketing efforts. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising. To learn how to opt out of online interest-based advertising (or, as it may be called in some jurisdictions, targeted advertising), please follow the instructions in the Your Choices and Rights section below.

3.4 To Protect the Rights of ACG and Others

ACG may use your personal data as we believe to be necessary or appropriate in order to:

· Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;

· Secure, protect and defend the privacy, safety or property of the ACG Services, and our employees and agents, or users;

· Comply with and enforce legal requirements, including laws outside your country of residence, relevant industry standards, contractual obligations, and our terms of service and other policies; and

· Respond to inquiries from third parties, including inquiries from law enforcement authorities.

We may combine information we obtain about you for the purposes identified in this Section 3. We may use information we collect from you in other ways for which we provide specific privacy notices at the time of collection.

4. DATA SHARING

We may share your personal data with:

4.1 Our Service Providers

We may share some or all of your personal data identified above, as necessary for the specific services, with our service providers, who provide services to us or to you on our behalf (e.g., sending email or Text Messages on our behalf, processing payments, fulfilling orders or delivering subscriptions or improving or customizing the ACG Services). These third-party service providers are not authorized to use it for any other purpose than the specific service they are providing to us or to you on our behalf.

4.2 Our Business Partners

We may share your data with business partners to provide you with co-branded services or features that you participate in, such as conferences, events, contests, sweepstakes or other promotions (“Co-Branded Services”). These Co-Branded Services may be hosted by ACG Services or on the third party’s service. The business partner’s use of your information will be governed by its privacy notice.

4.3 For Legal Requirements and Proceedings

We may disclose your personal data to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other government measures, and to comply with other legal obligations. We may also disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraud or illegal activity.

4.4 With Other Third Parties to Complete A Corporate Transaction

We may disclose information we have about you in the event we sell or transfer all or part of our business or assets (including in the event of a merger, reorganization, dissolution, or liquidation) to the third party or its advisors involved in such corporate transaction.

4.5 With Third Parties for the Protection of the Services and Our Users

We may disclose your personal data to protect and defend the rights, interests and safety of the Services and our users and our employees, contractors and agents; and to protect the security of our Services, including when we believe necessary or appropriate

to prevent physical harm or financial loss. 4.6 Non-Personally Identifiable Information May Be Shared with Clients as Part of Their Services

We may disclose limited non-personally identifiable information (e.g., Title and Company only, or aggregated data by demographic category) to help clients understand the type and frequency of those viewing their articles/posts.

5. YOUR CHOICES AND RIGHTS

5.1 Your Choices

We offer you many choices and you may have certain rights in connection with the personal data we collect about you.

5.1.1 Email Communications

You may ask us to remove your information from our marketing mailing lists by opting-out of any mailing lists via the “Unsubscribe” link found in our emails or by contacting us at info@arescommgroup.com and notifying us that you wish to be removed from all lists and/or databases. Even if you unsubscribe from our marketing communications, we may still need to send you communications related to your use of the ACG Services.

5.1.2 Push Notifications and Text Messages

If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app. You can opt out of text message alerts at any time by following the instructions in the text message you receive.

5.1.3 Browser Controls

You have choices about whether cookies or similar technologies are placed on your computer or mobile device. You may also choose to opt out of our use of data that we or our third-party service providers collect about your activities to provide you with tailored advertising about products or services of interest to you. Please contact us at info@arescommgroup.com to opt-out. Please be advised that future use of our services may grant consent once again.

5.1.4 To Change Mobile App Privacy Settings

You may change the privacy settings for ACG apps by accessing and updating privacy settings and permissions within the mobile app or on your mobile device.

5.2 Your Rights

Subject to applicable law, you may have certain rights to access, review, update, correct inaccuracies in or delete your personal data in our custody and control by submitting a request to info@arescommgroup.com.

For security purposes, we will seek to verify your identity – in part by requesting certain information from you – as part of our process. For instance, you may need to provide your name and email address. For certain types of requests, we may also need to ask you for additional information to verify your identity. Once we have verified your identity, we will respond to your request as appropriate.

5.2.1 The right to access and rectification or correction

You may have the right to access, correct or update your personal data at any time. Please contact us at info@arescommgroup.com for any corrections or to ask us for such information. When you have provided your consent for our use of your personal data, you have the right to withdraw your consent and we will apply your preferences going forward.

5.2.2 The right to deletion

Under certain circumstances, you may have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with applicable legal requirements. Certain data may be exempt from such requests under applicable law. We may also need to retain certain types of data so that we can provide the ACG Services to you. If you ask us to delete your data, you may no longer be able to access or use our Services.

5.3 For California Residents This CA Section 5.3 for California Residents applies solely to individuals, visitors, users, and others who are natural persons and residents of the State of California (“consumers” or “you”). THIS CA SECTION 5.3 OF THE PRIVACY NOTICE DOES NOT APPLY TO USERS WHO ARE NOT NATURAL PERSONS AND NOT CALIFORNIA RESIDENTS.

This Section 5.3 describes our policies and practices regarding the personal information we collect, use, and disclose about you, including personal information you submit, or we obtain when you access our website, as well as when you:

Use our mobile Site or applications,

Call or email us,

Interact with us on social media, or

View our online advertisements.

This Section 5.3 does not apply to third-party websites accessible through our Site. This Section 5.3 is adopted in part to comply with the California Consumer Privacy Act (“CCPA”). Any terms defined within the CCPA have the same meaning when utilized within Section 5.3. The other provisions of the Privacy Notice continue to apply except as modified in this Section 5.3.

1. Information We Collect:

We may collect or have collected in the preceding 12 months the following categories of personal information (“PI”).

Identifiers. Examples include the real name, postal address, online identifier, Internet Protocol internet protocol address, and email address or other similar identifiers.

Other elements. Examples include name, signature, characteristics or description, address, telephone number, bank account number, credit card number, other financial information.

Geolocation data. This might include location information while using our apps.

2. Purposes for Which We Collect Your Information:

Set forth below are the business or commercial purposes for which we have collected your PI.

To provide you with information, products, or services that you request from us.

To contact you and/or provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.

To engage in marketing activities, including to help design products and services appropriate for our clients.

To communicate with you on social media concerning our products and services.

To carry out our obligations and enforce our rights including those arising from any contracts entered between you and us, including for billing, payment, and collections.

To review, improve, and monitor our Site, applications, online services, and overall client experience, including to provide customization to meet the specific needs, ensure a consistent experience, and to assess trends, interests, and the demands of clients.

To provide customer service and engage in quality control activities concerning our products and services.

3. Sources of Personal Information

The categories of sources of PI are described below. The examples provided are for illustration purposes and are not exhaustive.

Examples of when we collect that information include:

During a Site visit, or when you contact us online or through email, phone or in-person events:

If you upload or share information, submit a request, submit information, or post other digital content through one of our Site, applications or via social media interactions on third-party websites like Facebook or Twitter.

In connection with your interactions with us as a registered user of our Site or online services.

4. Sharing Information

Of the categories of PI noted above, during the past 12 months, we shared the following:

Third parties as directed by you.

Third parties who perform services on our behalf (e.g., google analytics, email service providers, customer relationship management systems vendors, etc.).

Successors to all or portions of our business. If all or part of our business is sold, we may disclose PI in preparation for or as part of that transaction.

5. Selling Personal Information

We do not sell your PI and have not sold any PI in the preceding 12 months, including any information concerning minors under age 16. Except as otherwise noted, we do not track your activities online over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals.

6. Consumer Rights

Pursuant to the CCPA, and as detailed below, consumers have various rights with respect to their PI.

7. Request to Delete

You have the right to request that we delete your PI from our records and direct any service providers to delete your PI from their records, subject to certain exceptions.

Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers to delete your PI from our records.

We are not required to comply with your request to delete your PI if it is necessary for us (or our service provider) to maintain your PI to:

Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise fulfil a contract between us and you.

Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

Debug to identify and repair errors that impair existing intended functionality.

Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

Comply with a legal obligation.

Otherwise use your PI, internally, in a lawful manner that is compatible with the context in which you provided the information.

8. Request to Know

You have the right to request that we disclose the following to you as it relates to the 12-month period preceding our receipt of your verifiable consumer request:

The categories of PI We have collected about you.

The business or commercial purpose for collecting PI.

The categories of sources from which the PI is collected.

The categories of PI we disclose about you for a business purpose.

The categories of third parties with whom we share PI.

The specific pieces of PI We have about you.

Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to your request for information.

9. Nondiscrimination

We will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights. For example, we generally will not provide you with a different level or quality of goods or services if you exercise your rights under the CCPA.

10. Submitting Consumer Rights Requests

To submit any of the Consumer Rights requests as outlined above, please contact us at info@arescommgroup.com. We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is: i) the consumer who is the subject of the request, ii) a consumer on behalf of the consumer’s minor child, or iii) by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.

If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer. In general, we may ask you to provide identifying information that we already maintain about you, or we may use a third-party verification service. In either event, we will

information to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request in sufficient detail to allow us to review, understand, assess, and respond. PI collected from an individual to determine whether a request is a verifiable consumer request may not be used for any other purpose. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension. 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 receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period. You may authorize a natural person, or a business registered with the California Secretary of State to act on your behalf with respect to the rights under this CA Policy. When you submit a Request to Know or a Request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with Us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

11. Questions

If you have questions about this CA Addendum, please contact us as described above in the Privacy Notice.

5.4 For Colorado, Connecticut & Virginia Residents

The Colorado Privacy Act, Connecticut Data Privacy Act and Virginia Consumer Data Protection Act each provide certain rights to residents in the states of Colorado, Connecticut, and Virginia, respectively. This section of the Privacy Notice applies if you are a natural person who is resident of any of these states and use the ACG Services (each and all of whom shall be referred to collectively as “Consumer”). This notice supplements the information in the Privacy Notice. Certain terms below have the meanings given to them in the respective laws.

In addition to your rights of access, correction, and deletion as described in the Privacy Notice, Consumers have additional rights in connection with the personal data we collect about you, many of which are subject to exceptions under applicable law.

The right to non-discrimination. We will not deny, charge different prices for, or provide a different level of quality of goods and services if you choose to exercise your rights.

The right to data portability. You have, subject to certain exceptions, the right to obtain a copy of your personal data in a portable and readily usable format.

Opt-out of “Sale” or other processing of your personal data. You have the right to opt out of the sale of your data to a third party or the processing of your personal data for the following purposes: (i) targeted advertising and (ii) profiling. You may request to opt out of targeted advertising by going to the home page of the ACG Services you use and clicking on the “Do Not Sell or Share My Personal Information” link in the footer of the site or in the settings, profile, or menu of the apps. Virginia residents may also see a link to limit the use of their sensitive personal data in the footer of the site and may request to do so by clicking on the link.

You may request to opt out of profiling, obtain a portable copy of your personal data or exercise certain other rights with respect to your personal data by submitting a request to info@arescommgroup.com or by calling us at 508-480-8500.

Additionally, you may have the right to appeal a decision by contacting us as specified in the “Contact Us” section in our Privacy Notice.

5.5 For Nevada Residents

This section of the Privacy Notice applies if you are a natural person who is resident of Nevada and use the ACG Services (each and all of whom shall be referred to collectively as “Consumer”). This notice supplements the information in the Privacy Notice. Certain terms below have the meanings given to them in the respective laws.

If you are a resident of Nevada, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. If you have sought or acquired, by purchase or lease, any goods or services for personal, family, or household purposes from our us, you may ask us to disclose whether we have sold (for monetary consideration) certain information about you (including your first and last name, physical address, email address, telephone number, social security number, an identifier that allows you to be contacted either physically or online, or other contact information that allows us to identify you personally).

As a Nevada resident, you may also request to opt out of us sharing such information about you. To make this inquiry, please submit a request in writing to info@arescommgroup.com with “Nevada Privacy Rights” in the subject line. You must include your full name, email address, account number and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out. We will respond to your request within 60 days or let you know if we need additional time. We may require additional information to verify your identity before we can respond.

5.6 For Residents of the European Economic Area and the United Kingdom

This section of the Privacy Notice applies if you are in the United Kingdom or in a country that is a member of the EU/EEA and supplements the Privacy Notice.

ACG is the data controller of your personal data as defined under the UK Data Protection Act of 2018 and the EU GDPR.

Legal Basis for Data Processing:

In addition to the purposes for which we collect and process your Personal Data as set out in the Privacy Notice, we do so under the following legal basis:

We process your personal data as necessary to fulfil a contract that we have with you and/or to provide complimentary services that you have opt-ed in to on our Site. For example, we need to process your personal data to deliver a product or service you bought, to allow you to take part in one of our sweepstakes, competitions, or promotions.

We process your personal data for certain purposes with your consent; for example, to select personalized ads. Please see the section of this notice titled Third Party Online Advertising below. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.

We sometimes use your personal data on the grounds that there is a legitimate reason to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you. We only rely on legitimate interests if the reason for using your information is fair and lawful. Our legitimate interests in processing personal data include:

• To support a free press, including journalistic activities of societal importance;

• To support individual and societal rights to receive information;

• To develop, deliver and maintain relevant and engaging products, services and some aspects of advertising;

• To understand when our audiences engage with us or other organizations;

• To build a clearer understanding of who our audiences are in order to better serve them;

• To protect the safety and interests of ACG(including our employees and journalists) from harm or threats of harm; and

• To carry on the business of a commercial organization.

We also process your personal data when we have a legal or regulatory obligation or to defend claims.

UK/EU/EEA Data Subject Rights

In addition to the rights of access, correction or rectification and deletion or erasure, as described in this Privacy Notice, UK and EU/EEA data subjects have other rights over how their personal data is processed and can exercise these rights at any point in time. Below is an overview of these rights, many of which are subject to exceptions under applicable law. You can exercise your rights at any point in time by submitting a request through the following email at info@arescommgroup.com.

The right to object to or restrict processing. Under certain circumstances, you have the right to object to or restrict our processing of your personal data. For example, where we process personal data based on our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your personal data. However, you have an absolute right to object to our processing of your personal data for direct marketing purposes, and no exception applies to such a request.

The right to data portability. You have, subject to certain exceptions, the right to obtain a copy of your personal data in a structured, machine-readable format, and to ask us to share this data to another controller.

The right to withdraw consent. If you have given your consent to process your personal data, you have the right to withdraw that consent at any time by taking the actions explained in the “Your Choices” section of this Privacy Notice. This will not affect the lawfulness of the processing based on your consent before its withdrawal.

The right to lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint directly with the relevant Supervisory Authority about how we process your personal data.

Retention of Personal Data:

We will keep your personal data for as long as we need it to fulfill the purposes set out in this Privacy Notice, or while there is a legitimate reason for doing so, and as otherwise required or permitted by applicable law, such as in relation to our record retention obligations.

International Data Transfers:

As the Services are hosted in the United States, the personal data of our UK/EU/EEA users is hosted in the United States, and we may further transfer such personal data to countries that may not have data protection rules that require the same level of protection as in the UK/EU/EEA, however, we will put in place appropriate mechanisms and controls to protect your data. This may include data transfer agreements, a copy of which you may obtain by submitting a request through the following email: info@arescommgroup.com. We may use these data transfer mechanisms – and not consent – as the legal basis for our own transfers of personal data from within the UK and EEA (even when other aspects of our handling of personal data take place based on consent).

Third Party Online Advertising:

We enable certain third-party advertising exchanges to place advertisements on our sites, as further described in our Cookie Policy. With your consent, those advertising exchanges collect your IP address and/or a unique advertising ID that is used by the advertising exchange to identify you across the internet.

The European Digital Advertising Alliance (“EDAA”) has developed a guide to online behavioral advertising and has developed an opt-out page to manage online behavioral advertising preferences with EDAA member companies available at www.YourOnlineChoices.eu.

6. HOW WE PROTECT PERSONAL DATA

ACG uses a combination of administrative, technical, organizational, and physical measures to safeguard personal data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, considering the costs of implementation and nature of the processing of personal data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us as set forth in the Contact Us section below.

7. OTHER IMPORTANT INFORMATION

7.1 Do Not Track Disclosure

Some browsers or other tools include “Do Not Track” (DNT) features which, when turned on, send a signal to websites you visit indicating you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, ACG does not currently respond to DNT signals.

7.2 Transfers of Personal Data

Your personal data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside your country of residence, including the United States, and may have different data protection laws than in the country in which you initially provided the data. Applicable laws in the United States and/or other countries may allow the courts, law enforcement and national security authorities to access your personal data when in such country.

If you are a user located outside the United States or the country to which your information may be transferred, you understand (and, as permitted under applicable law, consent to) having any personal data processed in the United States or such country. When we transfer your data, we will protect that data as described in this Privacy Notice.

7.3 Collection of Personal Financial Information by a Payment Service

In some cases, we may use an unaffiliated payment service to allow you to purchase a product or service or make payments (“Payment Service”). If you wish to purchase a product or service or make a payment, in such a case, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy notice, rather than this Privacy Notice. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.

7.4 Links to Affiliates and Third-Party Sites or Apps

The ACG Services may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality, games, or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third party Linked Services may use automated means to collect information about you and your use of these features. Some of these third-party sites may be co-branded with an ACG owned logo, even though they are not operated or maintained by us.

ACG is not responsible for the privacy practices of such third parties, and once you leave the ACG Services or click an advertisement, or sign up for a special offer, you should check the applicable third-party privacy notice.

7.5 Updates to Privacy Notice

ACG may periodically update this Privacy Notice without prior notice to reflect changes in our privacy practices and the ACG Services. If we modify the Privacy Notice, we will update the Effective Date and the changes will become effective as of the date we post such Notice. We will notify you of any material changes by posting a prominent notice on the ACG Services’ Site(s) indicating we have updated this Privacy Notice.

8. CONTACT US

If you have questions about this Privacy Notice or how we or our service providers handle your personal data, please contact our privacy team at info@arescommgroup.com.

Or you may write to: Attention: Privacy Ares Communications Group, Inc. 201 Boston Post Road West, Suite 300 Marlborough, MA 01752

If you are in the EU/EEA or UK, the entity responsible for the collection and processing of personal data in connection with ACG Services is Ares Communications Group, Inc. (U.S.) (contact information provided above).