ARPA Privacy Policy

THIS IS A LEGAL AGREEMENT BETWEEN YOU (referenced herein as “You/you” or “user” or with “your”) AND ARPA SCS  (referenced herein as “ARPA”), THAT APPLIES EACH TIME YOU ACCESS TO OUR WEB:

ARPA (“ARPA,” “we,” and “us”) respects the privacy of its users (“you”) and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy describes the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. We encourage you to read this Privacy Policy carefully when using our application or services or transacting business with us. By using our website, application or other online services (our “Service”), you are accepting the practices described in this Privacy Policy.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

General Data Protection Regulation

Privacy Data Introductory provisions Pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and on the non-application of Directive 95/46 / EC (Official Journal of the European Union L 119 , 4.5.2016, p. 1, hereinafter: the General Data Protection Regulation),

The privacy policy is based on the following principles of personal data processing: the principle of legality, transparency and best practices, the principle of limited processing and reduction of data, the principle of accuracy and completeness of personal data, the principle of limited storage, the principle of integrity and confidentiality of information, the principle of liability, trust and honest processing, the principle of opportuneness (processing purposes), the processing principle in an unnamed (anonymous) form. The Privacy Policy applies to all services offered by the Company, with the aim of the Policy in a clear and transparent way to familiarize users and / or customers with the processing of their personal data and their rights. First and foremost, users and / or customers may at any time contact the Company with a request to modify or update and / or update the data relating to them, as well as with the request for commenting on it for which purposes they want or do not want their data processed

The Company is responsible for processing personal data:

ARPA , Identification Number:BE0695575914, registered in Belgium,Address:Square des Nations, 1, Brussels (Belgium) (Croatia) C.P. 1000

Personal Data Protection Officer Contact Information:


ARPA May Collect all of the following information:

Information you provide. In order to register as a user with ARPA, you will be asked to sign in using your email address. You will also be asked to allow ARPA to collect your location information from your device when you download or use the Service. In addition, we may collect and store any personal information you provide while using our Service or in some other manner. This may include identifying information, such as your name, address, email address and telephone number, and if you transact business with us.

Specific Outline of information that may be requested:

  • name, address, phone number, name of the company

“Personal Information” means individually identifiable information that would allow us to determine the actual identity of, and contact, a specific living person.

Personal Information may be utilized by ARPA in the following ways:

  • to check to ensure you are the person you claim to be;
  • to send you e-mails or communications on a mobile device;
  • to contact you about new services;
  • to collect payments for our services;
  • to transmit communication and marketing materials;
  • to coordinate with the client; and
  • to submit and transmit payment.
  • to deliver and improve our products and services, and manage our business;
  • to manage your account and provide you with customer support;
  • to perform research and analysis about your use of, or interest in, our or others’ products, services, or content;
  • to develop, display, and track content and advertising tailored to your interests on our Service and other sites, including providing our advertisements to you when you visit other sites;
  • for website or mobile application analytics;

Choice of Information Provided

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Service because such information may be required in order for you to purchase products or services; participate in a contest, promotion, survey; ask a question, or initiate other transactions.

You can also control the information collected by cookies. You can delete or decline cookies by changing your browser settings. Click “help” in the toolbar of most browsers for instructions.

Job Applicants

If your Personal Information is submitted when applying for a position with our company, the information will be used solely in connection with considering and acting upon your application. We may retain your Personal Information, but only for the purpose of considering your application for current or future available positions. This information, which may include your name and contact information, prior education and experience, and other information you provide to us, may be shared with third-party service providers retained by us to collect, maintain and analyze candidate submissions for job postings.
In all circumstances, we may perform these functions directly or use a third-party vendor to perform these functions on our behalf who will be obligated to use your personal information only to perform services for us. Also, if you access our Service from a third party social platform, such as Facebook, we may share non-personal information with that platform to the extent permitted by your agreement with it and its privacy settings.

Third-Party Cookies

ARPA reserves the right and you grant ARPA the right to utilize cookies to provide an amazing experience for you. By your continued utilization of our website, you continue to agree to our cookies and third-party cookies.

If you are uncomfortable with our use of cookies, you may disable cookies but your user experience will be negatively impacted. If you decide to disable these cookies, the most effective way to do it will be in your web browser.

ARPA may utilize numerous platforms like GOOGLE ANALYTICS at any time, which is a very effective solution to help us make our platform better. Google or another platform’s cookies may track the time you spend on the site or pages you visit. We may even test new features and make subtle changes to the way this site is delivered from time to time as a result of these analytics platforms.

We may also embed pixel tags (also called web beacons or clear GIFs) on web pages, ads, and emails. These tiny, invisible graphics are used to access cookies and track user activities (such as how many times a page is viewed). We use pixel tags to measure the popularity of our features and services. Ad companies also use pixel tags to measure the number of ads displayed and their performance (such as how many people clicked on an ad).

You also grant us the right and we express our desire to work with third parties in the future. Subsequently, they may advertise on our website or even link you to their website as a result of this relationship. If we do engage with third parties, affiliate tracking cookies may also be utilized to simply allow us to see if our users have come to the site through partner sites or if they are going to partner sites.

We may allow service providers, advertising companies and ad networks, and other third parties to display advertisements on our Service and elsewhere. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements. We do not provide any non-masked or non-obscured personal information to third parties. We do not take responsibility for any outcome you experience from a third party website and you agree to indemnify us as a result of their connection with our website and/or services and to hold them personally responsible for any inconvenience you may experience.

How and which data do we collect

Some services provided by the Company require the collection of personal information of users and / or customers, where basic data is collected in the following ways:

  1. Directly by the users themselves and/or the buyers in such a way that the users and/or customers themselves deliver to the Company as a processing manager in a certain amount of information relevant to the provision of the corresponding services. For the purpose of providing the appropriate services, the user and/or customer is obliged to provide the Company with the following information that is necessary to establish a contractual relationship for the provision of a particular service and/or the sale of certain products from its range:
  2. a) email address
  3. Automatically by visiting our web pages and applications, with data associated with network identifiers (Internet Protocol Addresses and cookie identifiers, such as Google Analytics to track interactions between users and / or customers).

A cookie is a small data file that is stored on a computer or mobile device when visiting a particular web page. Cookies are used to provide a better user experience to each user and/or customer, saving user and/or customer preferences in order to make web pages more efficient, as well as to monitor and test usage of the web site of the Company. Cookies are also used to monitor the use of the Internet and create user profiles, and then display customized Internet ads based on user and / or customer preferences.

By shutting down and/or blocking cooking, the user and/or the customer can still browse the Company’s web pages. However, there is a likelihood that certain features and/or functionality of a web page will not be available to such user and/or buyer, that is, the time required to access individual web page functions will be longer than usual.

Subject network identifiers can leave traces that, in combination with other identifiers and information provided by Internet service providers, can serve to identify users and / or customers. Also, for the stated purpose, we collect and process the following data:

a) IP address information;
b) data on the use of individual applications;
c) information about the habits of users and/or buyers – we create the above data for the purpose of profiling users and/or customers.

The quantity or scope of personal data collected by the Company depends on the nature of the service provided by the Company to its users and / or customers, as well as on the legal basis on the basis of which it collects data. The Company continuously takes care of collecting only the necessary scope of personal data that is required to achieve the legally defined purpose in which data are processed.

For what purposes personal data is collected and processed further
Personal information is collected to provide, maintain, protect and improve its purchase-related services in order to understand the ways in which users and / or customers use the services provided and use the Company’s web site and to perform contractual obligations Company. Such information is collected by the Company on the basis of a claim made by the user and / or the buyer for one or more specific purposes, as well as in one of the following cases.

Who do we share your information with?

We will share information, including personal information, with third parties that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, ad tracking and analytics, member screenings, supporting our Service functionality, and supporting contests, surveys and other features offered through our Service. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.

We may also share it with third parties to develop and deliver targeted advertising on our Service and on websites or applications of third parties and to analyze and report on advertising you see. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated, non-personal information, or personal information in hashed, non-human readable form, with third parties, including advisors, advertisers, and investors, for the purpose of conducting a general business analysis, advertising, marketing, or other business purposes. For example, we may engage a data provider who may collect web log data from you (including IP address and information about your browser or operating system), or place or recognize a unique cookie on your browser to enable you to receive customized ads or content. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us (such as your email address), that we may share with a data provider solely in hashed, non-human readable form.

Execution of contractual obligations

The Company collects and continues to process user and / or customer personal information for the purpose of contract conclusion and delivery, delivery of ordered products, advice and assistance in product use, provision of appropriate additional and / or extended product warranties, customer and / or customer complaints and others actions that are related to the conclusion and execution of the contract in accordance with the relevant regulations. The legal basis for the processing of personal data of users and/or customers for the foregoing purposes is the necessity of entering into a contract, ie in the event that the user and/or buyer refuses to provide essential information, the Company will not be able to enter into a contract and/or undertake certain activities related to execution of the contract concluded.

Fulfillment of legal obligations

Company is obliged to provide access to personal data processed by them, correction of inaccurate personal data, deletion of personal data, or limitation of personal data processing, as well as to acquaint them on the basis of submitted written request of users and / or customers to the above address of the data protection officer with the possibility of complaints about personal data processing and the right to transfer data.

Time that personal data is kept and processed

Depending on the purpose and the legal basis on which the user and/or customer’s personal information is collected, the Company is in some cases obliged to keep personal data in the time period (period) that for a particular purpose are prescribed by applicable regulations or the termination of the purpose for which they were collected. Bypassing a statutory deadline binding on the Company for the custody of certain personal data or termination of the purpose, the same shall be deleted.

In cases where the basis for data collection and processing is legitimate interest of the Company or the beneficiary of the user and / or customer, the personal data is kept in the following time periods:

a) data on existing users and / or customers: during the contractual relationship and 6 months after termination;
b) data on potential customers and / or customers: 3 months;

Data processed on the legitimate interests of the Company and/or the beneficiaries of users and/or customers may be deleted even before the expiration of the time limit specified in this Policy, if such deletion is required by the user and/or the buyer, ie when the user and / or customer objects to such processing.

User / customer rights

The right to access personal information As a processing manager, the Company undertakes, on the basis of the submitted written request of the user and / or the customer, which request may also be in the form of electronic mail, to provide access to the personal data processed by them, to inform them about the purpose of processing the personal data in which they are processed, the data being processed, the recipients or recipient categories with which the personal data are disclosed or will be disclosed, the estimated timing of the processing or the criteria used to determine that period.

Right to correct inaccurate data

As a processing manager, the Company will allow for the correction of incorrect personal data in each individual case when it is determined that the personal data collected on the user and/or customer are incorrect or that the user and/or customer data has changed.

Right to delete personal data

The Company will delete the personal data of the user and/or customer in the following cases: a) when user and/or customer personal data are no longer necessary for the purpose of processing or termination of the processing purpose; b) when the user and/or customer withdraws the privation as a legal basis for the processing of data, and there is no other legal basis for data processing; c) when the user and/or the customer objects to the processing of the data (see the title Right to complain) d) when personal data is processed unlawfully; e) when the personal data have to be deleted in order to fulfill the legal obligations of the European Union law or the Member State to which the data processing manager is subject; f) when personal information is collected regarding the provision of information society services in relation to the child’s privation.
Right to Restrict Data Processing of personal data
Processing will be provided by the Company in cases where the user and/or customer disputes the accuracy of the data when the processing is illegal and the user and/or customer as opposed to the deletion of the data and instead requires a restriction on their use when the processing manager no longer needs personal data processing needs but the user and / or customer requests data for the fulfillment of legal requirements as well as when the user and / or customer objects to the processing of personal data based on the legitimate interests of the Company, including the user profile and / or customer profiles.

Right to Invoke Complaints

The user and / or customer has the right to file an objection to the processing of personal data relating to him if the data is processed for the legitimate interests of the processing manager. In this case, the Company will cease processing personal data as processing manager unless it demonstrates that there are convincing legitimate reasons for processing personal data in relation to the user and/or customer rights, that is, in case the processing of data serves to establish, exercise or defend legal requirements. If a customer and/or customer personal information is processed for direct marketing purposes, the user has the right at any time to file an objection to processing for direct marketing purposes, especially if the personal data are used for the purpose of creating a profile.

Where personal data is processed

The Company’s personal information is processed by the Company in the Republic of  Croatia and in the United States on 3rd party servers. Under what conditions personal data is passed on to third parties Personal information of users and / or customers are forwarded by the Company to third parties (including competent bodies) only in the following cases:

a) the beneficiary of the customer and / or customer; 
b) in order to fulfill the Company’s legal obligations; 
c) when such processing is necessary to protect key users and / or customers’ interests.

Managing the consent

The active role of the user and / or the customer in the protection of privacy is reflected in the granting of consent as a voluntary, especially informed and unequivocal expression of the wishes of the respondents who, by a statement or a clear affirmative action, consent to the processing of personal data. The management of the consents implies the possibility that the user and/or the buyer, through an active and unequivocal action, empowers the Company to collect and process individual personal data for one or more purposes (consenting to the respondents), that is, to withdraw in an equal manner the earlier given consent for the collection and processing of personal data one or more purpose

Who to talk to

In the event of any questions about the protection of personal data by the Company, users and / or customers may contact the Personal Data Protection Officer via email at the e-mail address specified in this Privacy Policy or in writing at the following address:
ARPA SCS , Identification Number:BE0695575914, registered in the Republic of Croatia, Address:  Square des Nations, 1 | 1000 – Brussels (Belgium)

Amendments to the Privacy Policy

The Company reserves the right to amend this Policy at any time without giving any special notice to the persons concerned. For this reason, it is recommended to all interested parties to regularly review the Web site content of the Company for information on the updated content of this Policy. In Zagreb, September 2019.