Arrow International (“Arrow,” “our,” “us” or “we”) respects your privacy and recognizes the importance of your personal information and is committed to protecting your personal information through our compliance with this Arrow Players Club Privacy Policy (the “Privacy Policy”). 

This Privacy Policy describes the types of information we may collect when visitors, users, and others (“consumers” or “you”) visit our Arrow Players Club website located at www.arrowplayersclub.com, use our Arrow Players Club mobile application, interact with one of our guest services team members via one of our Arrow Players Club kiosks, or otherwise register for our loyalty rewards program (collectively, our “Services”) and our practices for using, maintaining, protecting and disclosing that information.

We adopt this notice to provide you with notice regarding the processing and use of certain information we may receive or collect and to comply with applicable laws, which may include the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”), the California Shine the Light Law of 2003, the Virginia Consumer Data Protection Act (“VCDPA”) and other relevant privacy laws.  Any terms defined in the CCPA and/or the CPRA have the same meaning when used in this Privacy Policy. 

Information We Collect

We collect information that identifies, relates to, describes, references, is associated or linked or is capable of being associated or linked, directly or indirectly, with an identified or identifiable natural person or a particular consumer, household or device (“personal information” or “personal data”). In particular, we have collected within the last twelve (12) months and plan to collect hereafter the following categories of personal information from consumers: 

Category A – Identifiers Examples: Name, postal address, Internet Protocol address, and email address.

Category B – Personal information categories (as listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e)) Examples: Name, signature, Social Security number, address, telephone number, fax number, passport number, driver’s license or state identification card number, employment, bank account number, credit card number, debit card number, or any other financial information, disability status.

Category C – Protected classification characteristics under California or federal law Examples: Age, ethnicity, citizenship, religion or creed, marital status, physical illness, mental illness or disabilities, gender, veteran status.

Category F – Internet or other similar network activity. Examples: Access history and information on your interaction with our application.

Category G – Geolocation data. Examples: Arrow Players Club Participating Locations

Exhibit I – Professional or employment-related information Examples: Access history and information on your interaction with our application.

 

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

• Directly from you. For example, through information we ask from you when you subscribe to or receive our Services.
• Directly and indirectly from you when using our Services or visiting our website. For example, usage details collected automatically in the course of your interaction with our platform or website.

Use of Personal Information

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

• For the purpose you provided it, such as to present the Website, Services and content to you.
• To notify you about other Arrow activities, events or services.
• To enhance your experience by building a player profile that will allow us to create and identify offers, incentives, and other opportunities for you.
• For or the purpose of aggregated statistical analysis regarding how you and others use our Website and Services. 
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As expressly described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

For any other use, we will attempt first to notify you. 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 further notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. Except as otherwise provided, when we disclose personal information to a third party for a business purpose, we will 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 and at any point since January 1, 2022, we have disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.
• Category B: Personal information categories (as listed in California Customer Records statute).
• Category C: Protected classification characteristics under California or federal law.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data
• Category I: Professional or employment-related information.

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

• Our clients or their agents with which you have engaged in a business contract.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with our Services. 

Neither in the preceding twelve (12) months nor at any point since January 1, 2022, have we sold, rented, or leased any personal information or processed personal information for purposes of targeted advertising.

Your Rights and Choices

A number of states’ laws provide consumers resident in those states with certain rights regarding their personal information. This section describes such rights and explains how to exercise them.

            Opt-Out Rights

You have the right to opt out of any future contacts from us by contacting us at mailto:[email protected].

            Access to Specific Information and Data Portability Rights

You have the right to request certain information about our collection and use of your personal information,  including the following:

• The categories and/or specific pieces of personal information we collected about you.
• The categories of sources from which the personal information is collected.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• A copy of the personal information we collected about you in a portable and readily usable format (sometimes called a data portability request) 

Once we receive and confirm your verifiable consumer request for one of the foregoing, we will provide same to you.

            Correction and Deletion Request Rights

You have the right to request that we correct inaccuracies in personal information about you in our possession.

You have the right to request that we delete any of your personal information we collected, 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:

1. 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with applicable law (like, e.g., the California Electronic Communications Privacy Act, Cal. Penal Code § 1546 seq.).
6. 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.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with an  inquiry, investigation, subpoena, or summons by federal, state, local, or other governmental authorities or other legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

            Exercising Access, Data Portability, Correction and Deletion Rights

To exercise the access, data portability, correction and deletion rights described above, please submit a verifiable consumer request to us by email at [email protected].

Only you or a person duly designated and authorized 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.

A verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we possess personal information or an authorized representative thereof.
• 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 the registered email associated with the account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Except as otherwise required, any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable consumer request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. If we do not comply with your verifiable consumer request, you may appeal such refusal and we will inform you of any action taken or not taken in response, including the reasons for same.   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 will provide information in response to a verifiable consumer request free of charge, up to twice annually per consumer. 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 rights under this Privacy Policy. Unless permitted by applicable law, we will not:

• Deny you use of our Services.
• Provide you a different level or quality of Services.

Security

We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted via our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in the Services. 

Changes to This Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. The date this Privacy Policy was last updated is identified at the bottom of this page. You are responsible for periodically visiting the Website and this Privacy Policy to check for any changes.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights hereunder or under applicable law, you may contact us via email at [email protected]

This Privacy Policy was last updated on September 18, 2022.