Legal & Policy

Privacy
Policy

Array privacy notice

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1. Introduction

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1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this notice we explain how we will handle your personal data.

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1.2 This notice applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.

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1.3 In this notice, "we", "us" and "our" refer to Launchcloud LLC dba Array.

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1.4 You can contact us by writing to Launchcloud LLC, 16192 Coastal Hwy, Lewes, DE 19958, USA.

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2. How we use your personal data

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2.1 In this Section 2 we have set out:

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(a) the general categories of personal data that we may process;

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(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

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(d) the legal bases of the processing.

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Category	Details	Source	Purposes	Legal basis
Usage data	Data about your use of our website and services, which may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.	Our analytics tracking systems	Analysing the use of the website and services	Our legitimate interests, namely monitoring and improving our website and services
Customer relationship data	Information relating to our customer relationships, which may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer.	You or your employer	Managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers	Our legitimate interests, namely the proper management of our customer relationships
Transaction data	Information relating to transactions, including purchases of services, that you enter into with us; this may include your contact details, your card details and the transaction details.	You	Supplying the purchased services and keeping proper records of transactions	Our legitimate interests, namely the proper administration of our business
Notification data	Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters.	You	Sending you and managing relevant notifications and/or newsletters	Consent or our legitimate interest in promoting our business

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2.2 We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

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2.3 We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

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2.4 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject (including meeting national security or law enforcement requirements) or in order to protect your vital interests or the vital interests of another natural person.

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3. Providing your personal data to others

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3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

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3.2 We may disclose your personal data to our suppliers or subcontractors identified in the table below insofar as reasonably necessary for enabling the provision of their services to us.

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Category	Purposes	Current providers
Hosting services providers	Hosting our websites and software applications	Amazon Web Services, Inc
Communications, support and CRM services providers	Communications with our users and customers, providing support, managing customer relationships and marketing	monday.com Ltd Hubspot, Inc Intercom See: https://monday.com/terms/privacy https://legal.hubspot.com/privacy-policy https://www.intercom.com/terms-and-policies#privacy
Analytics services providers	Analysis of the use of our websites and software applications	Google, Inc; Lucky Orange See: https://www.google.com/policies/privacy/ https://help.luckyorange.com/article/173-what-cookies-does-lucky-orange-set
Payment services providers	As necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.	Stripe, Inc See: https://stripe.com/privacy

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3.3 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

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3.4 Where we disclosure your personal data to a sub-processor, we may be liable to you with respect to any breach of your data protection rights by that sub-processor.

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4. International transfers

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4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred internationally.

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4.2 We and our other group companies have offices and facilities in the United States of America and the United Kingdom.

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4.3 Our services providers identified in Section 3 above have offices and facilities in the United States of America and/or other locations around the world.

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4.4 All transfers from within the European Economic Area (EEA) to a location outside the EEA, where that location does not benefit from an adequacy decision regarding data protection by the European Commission, will be protected by appropriate safeguards, namely the use of the standard data protection clauses adopted or approved by the European Commission (a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).

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5. Retaining and deleting personal data

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5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

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5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

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(a) save to the extent that we agree otherwise with a relevant customer, usage date will be retained for a minimum period of 1 year following the date of collection, and for a maximum period of 5 years following that date;

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(b) customer relationship data will be retained for a minimum period of 6 years following the end of the relevant relationship, and for a maximum period of 7 years following that date;

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(c) transaction data will be retained for a minimum period of 10 years following the date of the relevant transaction, and for a maximum period of 11 years following that date; and

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(d) notification data will be retained for a minimum period of 3 months following the date that the relevant person unsubscribes from the applicable service, and for a maximum period of 6 months following that date.

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5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

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6. Amendments

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6.1 We may update this notice from time to time by publishing a new version on our website.

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6.2 You should check this page occasionally to ensure you are happy with any changes to this notice.

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7. Your rights

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7.1 S‌ee our data protection policy for information about your rights under data protection law.

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8. Third party websites

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8.1 Our website includes hyperlinks to, and details of, third party websites.

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8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

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9. Updating information

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9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

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10. About cookies

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10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

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10.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

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10.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

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11. Cookies

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11.1 We and our services providers use cookies, as detailed in the following table.

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Person responsible	Purpose	Details
Array	Identification, session tracking and analytics	We use cookies to identify you when you visit our website and to track your session as you navigate our website, including tracking the use of promotional codes.
Array	Personalisation	We use cookies to store information about your preferences in relation to the personalisation of our website for you.
Google and Lucky Orange	Analytics	These services providers gather information about website and service use by means of cookies. The information gathered is used to create reports about the use of our website and services.
Intercom	Communications	Intercom use cookies to facilitate the provision of communications-related services.

12. Managing cookies

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12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

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(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

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(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

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(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

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(e) https://support.apple.com/kb/PH21411 (Safari); and

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(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

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12.2 Blocking all cookies will have a negative impact upon the usability of many websites.