document: title: privacy policy
text: This Privacy Policy describes how AspenCore, our parent, its subsidiaries and/or affiliates (collectively, “we”“us” or “our”) collect, use, and share information about you and applies to your use of any website that posts a link to this Privacy Policy (“Service”). This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below or at the time of collection).

By using our Service, you agree to our Terms of Use. By consenting to this Privacy Policy, you consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, please discontinue use of the Service.

* ### COLLECTION OF INFORMATION

  1. #### Information You Provide To Us

We collect information you provide directly to us via the Service. For example, we collect information when you use or register for our Service, subscribe to our magazines or newsletters, create a resume, post on our Service, follow other users, participate in promotional activities, enter a sweepstakes or contest, complete a survey, or communicate with us through the Service.

Information we collect may include Personal Information: “Personal Information” is information, whether true or not, that can be used to identify you (whether alone or in combination), including your first and last name, e-mail address, billing address, shipping address, phone number, and fax number. You may choose to voluntarily submit certain other information to us through the Service, including Personal Information, but you are solely responsible for your own Personal Information in instances where we have not collected such information or requested that you submit such information to us.

Personal Information once “de-identified” may not be subject to this Privacy Policy and we and our Service Providers (defined below) may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

  2. #### Information We Collect Automatically

We and our agents, vendors, consultants, marketing service providers, and other service providers (collectively, “Service Providers”) may automatically collect certain information about you when you access or use our Service (“Usage Information”). Usage Information may include IP address, device identifier, Ad ID, browser type and version, operating system characteristics, information about your use of our Service, and data regarding network connected hardware (e.g., computer or mobile device). To the extent that Usage Information is Personal Information under applicable law or is combined with Personal Information, we will treat the combined information as Personal Information under this Privacy Policy.

The methods that we and our Service Providers may use to collect Usage Information include:

    * Log Information: We collect information about your use of our Service, such as IP address, browser type and version, internet service provider, referring/exit pages, operating system, cookies that may uniquely identify your browser or your account, and related data, and store it in log files.
    * Information Collected by Cookies and Other Tracking Technologies: We and our partners may use cookies, web beacons, embedded scripts, location-identifying technologies, third party flash cookies, or other tracking technologies now and hereafter developed (“Tracking Technologies”) to collect information about interactions with our Service or e-mails, including information about your browsing and purchasing behavior. Further information about how we use cookies and tracking technologies, and how you can refuse them, is set out in Section 12 below.
  3. #### Information from Other Sources

We may also obtain information about you from other sources and combine that with information we collect about you. To the extent we combine such information with Personal Information we collect directly from you on the Service, we will treat the combined information as Personal Information under this Privacy Policy. We are not responsible for the accuracy of the information provided by third parties or third party practices, although we will take reasonable measures to ensure that such information is accurate.



* ### USE OF INFORMATION

We may use information about you for any purposes not inconsistent with our statements under this Privacy Policy or prohibited by applicable law, including to:

  * Facilitate, manage, personalize and improve your online experience;
  * Transact with you, respond to your comments, questions and requests, provide customer service, and send you informational notices;
  * Prevent and address fraud, breach of policies or terms and threats or harm; and
  * Send you newsletters and advertisements and communicate with you about products, services, offers, promotions, rewards, and events we think may be of interest to you.



If you are a user from the U.S., we may use your Personal Information for direct marketing purposes. If you are a user from outside the U.S., we will not use your Personal Information for direct marketing purposes unless we have received your express consent. You have the right to opt-out from direct marketing and can require us to cease to use the data at any time for direct marketing purpose at no cost.

Please see Section 12 for more information about how to manage our communications with you.

* ### SHARING OF INFORMATION

Please note that by using our Service, you agree to share your Personal Information and Usage Information, as described in this section.

  1. #### With Service Providers

Our Service Providers may receive, or be given access to your information, including Personal Information and Usage Information, in connection with their work on our behalf. These Service Providers may be located in countries other than your country of residence. These Service Providers are prohibited from using your Personal Information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes. We may also share information about you with our Service Providers as follows:

    * To comply with the law, law enforcement or other legal process, and except as prohibited by applicable law, in response to a government request;
    * To protect the rights, property, life, health, security and safety of us, the Service or any third party;
    * With our affiliates for internal business purposes (for example, processing your orders, fulfilling your requests, providing customer service, and improving the Service);
    * With our subsidiaries, affiliates, business partners, and other third parties for their own business purposes (for example, improving their products and services); and
    * In connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company.

Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.

  2. #### With Third Parties for Direct Marketing Purposes

We may share your Personal Information with third parties for direct marketing purposes as set forth in Section 2. California residents have further rights, as set out in Section 13.

Direct marketing purposes may include, but are not limited to, the following:

    * Sharing your Personal Information with third parties, including when you click on advertisements or articles on our Service or in emails we send to you;
    * Rental of email lists to third parties for marketing use;
    * Marketing emails sent by third parties; and
    * Emails sent by us sponsored by third parties.


* ### SWEEPSTAKES, CONTESTS, AND PROMOTIONS

We may offer sweepstakes, contests, and other promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your Personal Information may be disclosed to third parties for administrative purposes, marketing purposes, and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion (see Terms of Use for rules governing giveaway Promotions), and may, except where prohibited by applicable law, allow the Promotion sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.

* ### INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS

The Service may permit you to post or submit written content, user profiles, resumes, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Information (collectively, “User Content”). If you choose to submit User Content to any public area of our Service, your User Content will be considered “public” and will be accessible by anyone, including us, not subject to this Privacy Policy and may be used to the fullest extent permitted by applicable law. We encourage you to exercise caution when making decisions about what you disclose in such public areas. California minors should see Section 10 regarding potential removal of certain posted content.

Additionally, the Service may offer you the option to send a communication to a friend. If so, we rely on you to only send to people that have given you permission to do so. By sending a communication to a friend, you represent that you have permission to provide your friend’s e-mail address. The friend’s information you provide (e.g., name, e-mail address) will be used to send the communication and not used by us for any other marketing purpose unless we obtain consent from that person. Your contact information and message may be included in the communication.

* ### THIRD PARTY SERVICES AND SOCIAL FEATURES

Our Service includes hyperlinks to websites, locations, platforms, or services operated by third parties (“Third Party Services”). These Third Party Services may use their own cookies, web beacons and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.

Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third Party Services, such as third party social networks (“Social Features”). Examples of Social Features include “liking” or “sharing” our content and otherwise connecting our Service to a Third Party Service. If you use Social Features, and potentially other Third Party Services, information you post or provide access to may be publicly displayed on our Service or by the Third Party Service that you use. Similarly, if you post information on a Third Party Service that references our Service (e.g., by using a hashtag associated with us in a tweet or status update), your post may be used on or in connection with our Service. Also, both we and the third party may have access to certain information about you and your use of our Service and the Third Party Service. To the extent we combine information from Third Party Services with Personal Information we collect directly from you on the Service, we will treat the combined information as Personal Information under this Privacy Policy.

The information collected and stored by third parties remains subject to their privacy practices, including whether they continue to share information with us, the types of information shared, and your choices on what is visible to others on Third Party Services. We are not responsible for and make no representations regarding the policies or business practices of any third parties or Third Party Services and encourage you to familiarize yourself with and consult their privacy policies and terms of use.

* ### ADVERTISING, ANALYTICS SERVICES, AND ONLINE TRACKING

We may engage and work with third parties to serve advertisements on our behalf on the Service and/or on Third Party Services and to provide analytics services about the use of our Service and the performance of our ads and content on Third Party Services. In addition, we may participate in online advertising networks and exchanges that display relevant advertisements to our Service visitors, on our Service and on Third Party Services and off of our Service, based on their interests as reflected in their browsing of the Service and certain Third Party Services. These entities may use cookies and other Tracking Technologies to automatically collect information about you and your activities, such as registering a unique identifier for your device and tying that to your online activities on and off of our Service. We may use this information to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Service and Third Party Services and better understand your online activity.

Some information about your browsing of the Service and certain Third Party Services may be collected across time and services and shared with third parties to deliver ads and/or other content to you on the Service and certain Third Party Services. We may receive information about Third Party Services that you have visited and use it for marketing purposes—a practice sometimes termed “(re)-targeting,” “interest-based advertising,” and “online behavioral advertising.”

We are not responsible for third parties or Third Party Services associated with advertising and analytics services, and related tracking activities. Please consult their privacy policies and notices for information on their practices and see Section 12 regarding certain choices some of them may offer you. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” visit http://www.allaboutdnt.com.

* ### DATA SECURITY

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. In addition, we will not keep your Personal Information for longer than necessary for the purposes set out in this policy. Nevertheless, transmission via the Internet is not completely secure and we cannot guarantee the security of your information collected through our Service.

Your Personal Information is stored on servers maintained with the assistance of a third party data storage provider. To help protect the privacy of data and personal information we collect and hold, our data storage provider maintains physical, technical, and administrative safeguards which are monitored, tested, and updated on an ongoing basis.

When we engage third-party service providers and when disclosure of Personal Information to such providers is necessary for the provision of such service, we ensure that such providers protect Personal Information in a manner consistent with this Privacy Policy and, where applicable, are responsible for ensuring that such third parties process EU Personal Information in a manner consistent with the Privacy Shield Principles discussed below.

* ### INTERNATIONAL TRANSFER

We are based in the U.S. and the information we collect from the U.S. is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S. Your Personal Information may also be transferred to, processed, stored and used in other jurisdictions in which we have affiliates or Service Providers. Data protection laws in these jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information, including Personal Information, in these jurisdictions, as set forth in this Privacy Policy.

We comply with the Privacy Shield Framework, as set forth by the U.S. Department of Commerce in consultation with the European Commission, regarding the collection, use and retention of Personal Information received from the European Union. As we are a U.S. company, we have voluntarily decided to comply with the EU – U.S. Privacy Shield Framework and we are subject to the investigatory and enforcement powers of the Federal Trade Commission. We annually certify our adherence to the Privacy Shield Principles of notice; choice; accountability for onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability. To learn more about the EU – U.S. Privacy Shield Framework, please visit https://www.privacyshield.gov/EU-US-Framework. To view Arrow’s certification, please visit https://www.privacyshield.gov/list.

* ### CHILDREN’S PRIVACY

Our Service is not intended for children and is not targeted to children under the age of thirteen (13). If you are a child under the age of thirteen (13), you are not permitted to use the Service and should not send any information about yourself to us through the Service.

We do not knowingly collect any personal information from children under the age of 13 and, if we learn that we have received information from a user under the age of 13, we will delete this information in accordance with the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us at privacy@aspencore.com.

If you are a user in South Korea and you are aged under fourteen (14), you are not permitted to use the Service without the consent of your parent or legal guardian. You should not send any information about yourself to us through the Service unless your parent or legal guardian has given his or her consent. We do not knowingly collect any Personal Information from children in South Korea under the age of 14 without consent from a parent or legal guardian and, if we learn that we have received information from a user in South Korea under the age of 14 without requisite consent, we will delete this information. If you are a parent or legal guardian in South Korea and you believe that your child under the age of fourteen (14) has provided us with Personal Information without your consent, please contact us at privacy@aspencore.com.

Any California residents under the age of eighteen (18) who have registered to use the Service, and who have posted content or information on the Service, can request removal by contacting us at privacy@aspencore.com or by sending a letter to AspenCore, Inc., 1455 NW Irving Street, Suite 200, Portland, OR 97209, with information detailing where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that we do not control.

* ### ACCESSING AND CHANGING INFORMATION

We will provide web pages or other mechanisms allowing you to correct or update some of the Personal Information you have provided us.

Users from the EU, Singapore, Hong Kong, Japan, New Zealand, Mexico, and Australia have a right to access their Personal Information, request corrections and/or deletions, and oppose the use of their Personal Information for specific purposes, subject to exceptions allowed by law. Such users are also entitled to request information on the origin of their Personal Information, the recipients or types of recipients to whom their Personal Information is provided, the reason for which their Personal Information is being stored, and the ways in which their Personal Information has been or may have been used or disclosed by us within a year before the date of the request. If you would like to do so, please send your request in writing by sending an email to privacy@aspencore.com or by sending a letter to AspenCore, Inc., 1455 NW Irving Street, Suite 200, Portland, OR 97209. To protect your privacy and the privacy of others, we will need evidence of your identity before we can grant you access to information about you or change it, including your username and password, if applicable. You will not be charged for compliance with such a request.

EU persons may request access to their Personal Information under this policy to the full extent required by applicable law in the home country of the person making the request. Such persons may request the correction, amendment, or deletion of their Personal Information that is inaccurate or has been processed in violation of the Privacy Shield Principles. We will reasonably fulfill such requests to the extent required by applicable law.

We will make good faith efforts to make requested changes in our then-active databases as soon as practicable (but may retain prior information for records to the extent not prohibited by applicable law). Please note that it is not always possible to completely remove or delete all of your information or public postings from our databases (California minors see Section 10) and that residual data may remain on backup media or for other reasons. We also may retain cached or archived copies of information about you for a certain period of time.

* ### CHOICES: TRACKING AND COMMUNICATIONS OPTIONS

  1. #### Tracking Technologies Generally

Our Service uses cookies to distinguish you from other users of our Service. This helps us to provide you with a good experience when you use our Service and also allows us to improve our Service. By continuing to use our Service, you are agreeing to our use of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive.

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove cookies some parts of our Service may not work and that when you revisit our Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

When you are using our Service, you may notice that there is content from other websites which we add from time to time to improve the user experience. As a result, you may be sent cookies from these other websites. We do not control these cookies and we suggest you check these third-party websites for more information about the cookies they use and how you can manage them.

With respect to our mobile applications, you can stop all collection of information by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling location identifying services, by adjusting the permissions in your mobile device.

  2. #### Analytics and Interest-Based Advertising

Certain companies may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for interest-based ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com and its opt-out program for mobile applications at http://www.aboutads.info/appchoices. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt-out of certain targeted advertising delivered by NAI members’ ad networks. To learn more about opting out of targeted advertising or to use the NAI tool, visit http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt-out of certain kinds of targeted advertising, you will continue to receive non-targeted ads. We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. However, we support the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (http://www.iab.net/media/file/ven-principles-07-01-09.pdf) and expect that ad networks we directly engage to serve you interest-based ads will do so as well, though we cannot guarantee their compliance.

  3. #### Communications

You can opt-out of receiving promotional communications (e-mails or text messages) from us at any time by (i) for promotional e-mails, following the instructions as provided in e-mails to click on the unsubscribe link or changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions as provided in text messages from us to text the word, “STOP”. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscriptions may continue. Even if you opt-out of receiving promotional communications, we may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or our ongoing business relations.

Our mobile applications may send you notifications that may include alerts, sounds, and icon badges. These push notifications or in-app messages may include both operational messages and promotional messages regarding products, services and offers that may be of interest to you. These can be configured in Settings. As with e-mails, even if you opt-out of receiving promotional communications, we may continue to send you non-promotional push notifications, such as those about your use of the applications or our ongoing business relations.



* ### YOUR CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under that law, a business must either provide California customers certain information upon request or permit California customers to opt-in to, or opt-out of, this type of sharing.

For our U.S. users, we may from time to time elect to share certain information about you collected by us on the Service with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. If you are a California resident, you may opt-out of such future sharing by contacting us at privacy@aspencore.com or by sending a letter to AspenCore, Inc., 1455 NW Irving Street, Suite 200, Portland, OR 97209. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address or mail address.

* ### PRIVACY RIGHTS IN NON-U.S. JURISDICTIONS

Users from outside the U.S. have the right to ask us not to process their Personal Information for marketing purposes. You can exercise your right to prevent such processing by unsubscribing from the emails you receive from us and any third parties. You can also exercise the right at any time by contacting us at privacy@aspencore.com or by sending a letter to AspenCore, Inc., 1455 NW Irving Street, Suite 200, Portland, OR 97209.

Users from outside the U.S. also have the right to revoke their given consent regarding the use and sharing of their Personal Information. However, it is important to note that in some cases such request may not be immediately or fully executed because it is possible that we have a legal obligation to keep using your Personal Information. Also, you must consider that for certain purposes, the revocation of consent means that we cannot continue providing the services you requested. You can revoke your consent at any time by contacting us at privacy@aspencore.com or by sending a letter to AspenCore, Inc., 1455 NW Irving Street, Suite 200, Portland, OR 97209.

Any EU person who is not satisfied with our compliance with the EU – U.S. Privacy Shield may contact us to resolve such complaints at compliance@arrow.com or by sending a letter to the addresses set forth below. If any EU person believes that such a complaint has not been resolved, he or she agrees first to try and settle the dispute by mediation, administered by the International Centre for Dispute Resolution under its Mediation Rules, before resorting to arbitration, litigation, or some other dispute resolution procedure. The rules governing these procedures and information regarding how to file a claim free of charge can be found here: http://info.adr.org/safeharbor/.

Any EU person who remains dissatisfied may contact his or her national Data Protection Authority in the country where the person resides. We have agreed to cooperate and comply with appropriate EU Data Protection Authorities and the Department of Commerce in resolving such disputes. If an EU person remains dissatisfied and meets the pre-arbitration requirements of Annex I Part C of the EU – U.S. Privacy Shield Framework, the person may invoke binding arbitration pursuant to procedures in Annex I of the EU – U.S. Privacy Shield Framework Principles found here: https://www.privacyshield.gov/EU-US-Framework.

* ### CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Subject to applicable law, your continued use of our Service indicates your consent to the privacy policy posted. If the changes are material, we may provide you additional notice, to your e-mail address.

* ### CONTACT US

For any requests relating to your Personal Information, or if you have any questions about this Privacy Policy posted at www.aspencore.com, please contact us at:

AspenCore, Inc.  
1455 NW Irving Street, Suite 200,  
Portland, OR 97209  
privacy@aspencore.com

9201 East Dry Creek Road  
Centennial, CO 80112  
(Attention: Legal Counsel)

European users can contact us at:

Frankfurter Straße 211  
63263 Neu-Isenburg  
Germany  
(Attention: Legal Counsel)