Privacy Policy

This Privacy Policy (Policy) describes the information collected by or on behalf of Project Aging, Inc. d/b/a Arlow when you visit our websites located at https://www.arlow.ai/ and its subdomains (Sites) or use our mobile application (App) and how the information is used and shared. If you have questions or concerns about this Policy, please contact us as set forth below.

We may modify this Policy at any time. All changes will be effective immediately upon posting to the Sites. Changes that we, in our sole discretion, determine are material will be conspicuously posted on the Sites or otherwise communicated to you.

We do not collect or process health information in a manner regulated by the Health Insurance Portability and Accountability Act (HIPAA), but we may collect certain Personal Information that is classified as “Consumer Health Data” under laws enacted in the states of Washington and Nevada. If you are a resident of Washington or Nevada, please refer to our Consumer Health Data Privacy Policy to learn more about what Consumer Health Data we may collect and our privacy practices with respect to such data.

1. Information We Collect

We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you (Personal Information) when you use our Sites, our App, or otherwise interact with us. The Personal Information we collect falls into the following categories: (i) information you provide to us; (ii) information we collect through automated methods when you use our Sites or App; and (iii) information we collect from third-party sources.  

Personal Information is required to use certain features of our Sites or App. In such circumstances, such features may be unavailable to you unless you provide your Personal Information.  

   A. Information You Provide to Us

We collect Personal Information that you provide directly to us. If you elect to provide data that personally identifies you such as your name, gender, age, email address, mailing address, phone number, health care records, or any other similar information, we will collect, use, and share such Personal Information pursuant to this Policy and applicable law. This may occur in the following ways:  

• Through the App or the Sites. We collect Personal Information that you may submit to us when using the App or the Sites, such as why you contact us to provide feedback or request customer service, create your account, or otherwise use our services.  

• Accounts. When you create an account, you will be required to submit your name, email address, and to make a password to create an account. We will also collect certain demographic information about you that may include, but is not limited to your relationship status, gender, work status, racial background, spiritual practices, hobbies, and pets. We will also collect information about your health conditions, medications, tobacco usage, and other health-related information. This data is used to populate a profile within your account. In addition, when you are logged into your account, we will collect additional data about how you use our services and learn from our interactions with you to tailor our recommendations to your preferences. This information will be linked to your account.

• Communications with Us. If you communicate with us through our website forms, the App, phone calls, emails, or other direct communications, we will collect any Personal Information that you elect to provide to use during, or as a result of, those communications, such as name, phone number, email address, and message content.  

• Payment and Transaction Data. When you purchase a subscription to our services, we use a third-party payment processor to facilitate your payment. We do not store full payment card numbers and we do not receive your credit card, debit card, or other financial information. We will receive only limited transaction-related information necessary to complete and record your purchase. If you are logged into your online account, your purchase history will be linked to your account.

• ArlowAI Conversational AI Interactions. We have integrated a conversational artificial intelligence (AI) tool on our App to enhance user experience by providing personalized search and assistance functionalities. The conversational AI will collect any information that you submit to it to tailor its responses and will use that information to further train and refine the AI with a goal to improve its accuracy over time. We will link the information obtained through your interactions to your account.

    B. Data Automatically Collected

We may use automated technologies to collect Personal Information from your computer system or mobile device when you use our Sites or the App. This may include the following:

• Site Activity. We may collect Personal Information about how you use our Sites. We may combine this Personal Information automatically collected from you with other Personal Information.  

• Tracking Technologies. Our Sites  may use Tracking Technologies (e.g., cookies, web beacons, pixel tags and other tracking technologies). A cookie is a small text file that our Sites save onto your computer or device when you use the Sites that provides us certain information about your activities. Cookies allow the Sites to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.

Most browsers automatically accept Tracking Technologies. You can disable this function by changing your browser settings but disabling certain Tracking Technologies may impact your use and enjoyment of the Sites. Not all features or functions of the Sites may work properly if you disable Tracking Technologies. You cannot disable all Tracking Technologies, such as Tracking Technologies that are essential to the functioning of the Sites.

The Tracking Technologies on our Sites and the App may collect information such as:

• IP addresses assigned to the computers and other devices you use;

• your internet service provider;

• device ID number

• approximate geographic location;

• browser type;

• Site pages visited;  

• websites you access before and after visiting the Sites, and  

• data related to how and when you use the Sites and the App;

• device information including device type, software version, display resolution, and audio capabilities

   C. Data From Third-Party Sources

We obtain Personal Information about individuals from various third-party sources. For example, we may receive information from:

• Referral or Invitation Services. When someone uses a feature to invite you to use our services, we may receive your name, phone number, email address, or other contact details from that person or the service facilitating the invitation.

• Business Partners and Service Providers. Partners who help us deliver or improve our services may share information about you, such as demographic details or engagement metrics.

• Publicly Available Sources. We may collect information from publicly accessible websites or social media platforms where you have made such information available.

We use this information to provide and improve our services, communicate with you, and for other purposes described in this Policy.

2. How We Use Your Information.  

We use Personal Information that we collect for the following purposes:

• As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.  

• Administration. We use Personal Information for administrative purposes, such as to inform our business strategies and to understand demographics and user preferences.

• Site Management. We use Personal Information for Site management, such as troubleshooting problems, improving the content and functionality, to perform statistical and other analyses, and to customize the Sites to our users.  

• App Management. We use Personal Information to manage and optimize the App experience. This includes troubleshooting technical issues, improving performance and functionality, conducting statistical and usage analyses, and customizing features and content to better serve our users.

• Communications. We may use Personal Information to notify you of new services, products, or programs, to notify you of new features of our Site and App, to notify you of changes to our terms or this Policy, and for other similar communications.

• To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our services, or to other users of the services. We may also use Personal Information to seek business, financial, or legal advice, and to respond to other legal requests.  

• To Receive Feedback and Improve User Experience. We may collect feedback from you through surveys and other formats. We may use all such information that we collect to improve user experience, our products, and our services.

• How We Use Data Collected by Tracking Technologies. We use Tracking Technologies to: (i) make our Sites and the App function properly; (ii) provide personalized experiences; (iii) tailor our interactions with you; and (iv) provide us with valuable data and statistics about the usage and effectiveness of our Sites and the App and to help us improve our Sites and the App.  

• Google Analytics.  We use Google Analytics to collect and process information about your use of the Site. Google sets Tracking Technologies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Site. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google’s “Google Analytics Cookie Usage on Websites” page. Google Analytics is not required for the Sites or App to function.

3. Disclosure of Personal Information

We do not sell, rent or lease Personal Information to any third party or share your Personal Information with third parties for advertising purposes. We may disclose Personal Information to the following categories of parties, in compliance with applicable laws:

• Affiliates. We may disclose Personal Information with our affiliates who have a need to know the information for our business purposes.

• Service Providers and Vendors. We may disclose Personal Information with service providers that provide services for us. For example, we may disclose Personal Information to service providers to help us host and manage the Sites and the App, improve the content and functionality of the Sites or the App, perform data analysis and statistical analysis, troubleshoot problems with the Sites or the App, and support or provide the security of the Sites and the App.  

• Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information:  (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact, or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Arlow or any other party.

• Professional Advisors. We may disclose Personal Information to our professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to Arlow.  

• Legal Proceedings and Protection of Rights. We may use Personal Information and disclose it to third parties if we believe doing so is necessary to provide you the contemplated Site or to protect our rights or the rights of others, including disclosing information necessary to identify, contact, or bring legal action in the event of a violation of our contracts, terms, or policies.

• Change in Ownership. We may transfer your Personal Information to a successor entity or an operator upon a merger, consolidation, acquisition, bankruptcy, dissolution, liquidation, or other corporate reorganization, to a purchaser of all or a portion of our assets, or pursuant to a financing arrangement or co-promotional agreement. The Personal Information we have about you may be transferred to parties to the transaction.

• Other. We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

4. Use and Disclosure of Deidentified or Aggregated Information

Deidentified information is data that has been processed to remove or obscure any details that could reasonably identify or be linked to an individual and therefore does not qualify as Personal Information under applicable privacy laws and is not subject to this Policy. We may collect, use, disclose, share, create, transfer, and otherwise process deidentified and aggregated information for any lawful purpose, including for research, analytics, service improvements, and business operations. We may share aggregated or deidentified data with third parties without restriction.

5. Retention of Personal Information

We will retain your Personal Information in accordance with our record retention requirements and our internal policies, which reflect our business and legal considerations. Your Personal Information may be retained longer if required or permitted by applicable law.  

6. Children's Information.  

We do not knowingly collect or solicit Personal Information directly from anyone under the age of eighteen (18). If you are under eighteen (18), please do not share any Personal Information about yourself with us. If you are a parent or guardian and become aware that your child has provided us with personal information, please contact us and we will work with you to address this issue.

7. Data Security

We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach consistent with applicable law.

You understand that no data transmission over the internet or device can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide Personal Information at your own risk.

8. Third-Party Websites

The Sites and the App may contain links to websites not controlled by us. We are not responsible for third parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

9. Access from Outside the United States

Our Sites and the App are solely intended for use within the United States. If you access the Sites or the App from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.

10. Contact Us

If you have questions or concerns regarding this Policy, you may contact us:

By email at: privacy@arlow.ai

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