Arrow Up Partners, LLC. and its subsidiaries including CEO360 (collectively “CEO360”) are committed to protecting your privacy and providing you with a positive experience on our website and while using our services (“Solutions”).

This Privacy Statement applies to CEO360 website and Solutions that link to or reference this Privacy Statement and describes how we handle Personal Data and the choices available to you regarding collection, use, access, and how to update and correct your Personal Data. Additional information on our Personal Data practices with respect to CEO360 Solutions may be provided in Solution specific privacy data sheets and maps, offer descriptions, or other notices provided prior to or at the time of data collection. Certain CEO360 websites and Solutions may have their own privacy documentation describing how we handle Personal Data for those websites or Solutions specifically. To the extent a specific notice for a website or Solution differs from this Privacy Statement, the specific notice will take precedent. If there is a difference in translated, non-English versions of this Privacy Statement, the U.S.-English version will take precedent.

What is Personal Data?

“Personal Data” is any information that can reasonably be used to identify an individual, or otherwise make an individual identifiable, and may include name, address, email address, phone number, login information (such as account number and password), social media account information, or payment card number.

The types of Personal Data we may process depends on the business context and the purposes for which it was collected. It may include:

• Contact, subscription, and account/registration details, as well as online identifiers
• Login credentials where we require an account be made
• Communications content (such as audio, video, text), social media and discussion forum, or other communications details when you interact with CEO360
• Financial Information (such as bank account details or credit card information)
• Details of an individual’s business and other interests and opinions (such as information held in a Customer Relationship Management database)
• Information about the user and usage of our website and Solutions, including System Information such as device identifiers and telemetry (such as IP or MAC address) when such data is linked or tied to a specific individual’s device
• If we link other data with your Personal Data, we will treat that linked data as Personal Data.

Collection and use of your Personal Data

We may collect data, including Personal Data, about you as you use our websites and Solutions and interact with us. We also acquire Personal Data from trusted third-party sources and engage third parties to collect Personal Data on our behalf, in accordance with applicable laws.

We may use your Personal Data for the purposes of operating and helping to ensure the security of our business; delivering, improving, and customizing our website and Solutions; sending notices, marketing, and other communications; and for other legitimate purposes permitted by applicable law.

• We collect Personal Data for a variety of business reasons, such as:
• Customer relationship management and administration
• Order processing, including billing and payment
• Creating and managing user accounts
• Analyzing, personalizing, improving accuracy, and enhancing user experience, communications, and interactions
• Sending communications to you, including for marketing or customer satisfaction purposes directly from CEO360
• Managing communications preferences. You can modify your communication preferences at any time. See Your choices and selecting your communication preferences below
• Contract performance, Solution delivery, and customer service
• Briefing professional trusted advisors who will work on the client’s account. Trusted advisor relationships are covered by non-Disclosure agreements and Master Service agreements containing non-disclosure language
• Facilitating conferences, meetings, webinars, and other events
• Protecting CEO360, our users, websites and Solutions, and others
• If you choose to provide CEO360 with a third party’s Personal Data (such as name, email, and phone number), you represent that you have the third party’s permission to do so. Examples include forwarding reference or marketing material to a friend or sending job referrals. Third parties may unsubscribe from any future communication following the link provided in the initial message or by submitting a Privacy Request.

Your privacy rights

We need your help to keep your Personal Data accurate and up to date. We provide options to access, correct, suppress, or delete your Personal Data:

When CEO360 is acting as a “data controller,” you can exercise your rights of access and request corrections, suppression, objection and deletion under applicable data protection laws directly with CEO360 as described in the specific website and Solution documentation or by submitting a request through the Privacy Request form.

If you need additional assistance, or help with accessing, correcting, suppressing, or deleting your Personal Data, please feel free to contact us directly. We will respond to your request within 30 days or as appropriate under applicable data protection laws. If we are unable to honor your request or need more time, we will provide you with an explanation.

Your choices and selecting your communication preferences

We give you the option to receive a variety of information related to our business, programs, website, and Solutions. You can manage your communication preferences at any time through the following methods:

• By following the instructions included in each promotional email from us to unsubscribe from that mailing
• By completing and submitting this form or by contacting us via mail at: CEO360 Privacy Department, 2681 West Canyon Ave. #545, San Diego, CA 92123, USA. Please be sure to include your name, email address, the communication received, method of delivery (such as post, email, phone call, text), and any additional information about the material you no longer wish to receive.

These choices do not apply to service notifications or other required communications that are considered part of certain programs, website, and Solutions which you may receive periodically unless you cancel or stop use in accordance with its terms and conditions. With your permission, your Personal data may be shared with third parties (such as CEO360 trusted advisors) so that they may inform you about websites, programs, products, or services that may be of interest to you. To opt-out of with third parties for their marketing purposes, please submit a Privacy Request.

By using or engaging with our website, Solutions, or otherwise providing Personal Data to us, you agree that we may communicate with you regarding security, privacy, and administrative issues relating to your use. For example, if we learn of a security system’s breach, we may attempt to notify you by posting a notice on our websites, sending an email, or otherwise contacting you.

Disclosing your Personal Data

Personal Data may be processed by third parties for the purposes of operating our business; delivering, analyzing, improving, securing, and customizing our websites and Solutions; sending marketing and other communications related to our business; and for other legitimate purposes permitted by applicable law(s); or otherwise with your consent.

Personal Data may be disclosed in the following ways:

Within CEO360 for the purposes of data processing, such as marketing, business operations, compliance, security, website or Solution functionality, or storage

With trusted advisors to provide a requested website, Solution, service, or transaction. Examples include processing of orders and credit card transactions, hosting websites, hosting seminar registration, assisting with sales-related efforts or pre/post-sales support, and providing customer support.

• With CEO360 trusted advisors, so that they may share information with you about their products or services. To opt-out of CEO360 sharing with third parties for their marketing purposes, please submit a Privacy Request.
• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company
• In response to a request for information by a competent authority or third party if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process
• With law enforcement officials, government authorities, or other third parties as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of CEO360, our business partners, you, or others; or as otherwise required by applicable law
• In aggregated, anonymized, and/or de-identified form that cannot reasonably be used to identify you
• If we otherwise notify you and you consent to the sharing.

 
Security of your Personal Data

We take reasonable and appropriate steps to protect the Personal Data entrusted to us and treat it securely in accordance with this Privacy Statement. CEO360 implements physical, technical, and organizational safeguards designed to protect your Personal Data from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. We also contractually require that our trusted advisors and suppliers protect such information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

Retention and disposal of Personal Data

We will retain your Personal Data as needed to fulfill the purposes for which it was collected.

We will retain and use your Personal Data as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our rights and agreements.

We will not retain Personal Data in identifiable form when the purpose(s) for which the Personal Data was collected have been achieved and there is no legal or business need to retain such Personal Data. Thereafter, the data will either be destroyed, deleted, anonymized, and/or removed from our systems.

Use of cookies and similar technologies

CEO360 uses automatic data collection tools, such as cookies, embedded web links, pixels, tags, and web beacons. These tools collect certain standard information that your browser sends to us (such as Internet Protocol (IP) address, MAC address, clickstream behavior, and telemetry).

These tools help make your visit to our website and Solutions easier, more efficient, and personalized. We also use the information to improve our website and Solutions, provide greater service and value, better understand your potential interest in our websites and Solutions, and provide you with more relevant ads and other content.

For more information, or if you would like to opt out of interest-based advertising, see How CEO360 Uses Data Collection Tools.

To update your cookie preferences, click the “Cookies” link at the bottom of any page on this website. Additionally, you may be able to use other tools to control cookies and similar technologies. For example, you may have controls in your internet browser to limit how the websites you visit are able to use cookies.

Linked websites

We may provide links to other third-party websites and services that are outside CEO360’s control and governed by the respective third-party’s privacy policy, not by this Privacy Statement. We encourage you to review the privacy statements posted on the websites you visit and in the applications you use.

Children’s privacy

CEO360 encourages parents and guardians to take an active role in their children’s online activities. CEO360 does not knowingly collect Personal Data from children without appropriate parental or guardian consent. If you believe that we may have collected Personal Data from someone under the applicable age of consent in your country without proper consent, please let us know using the methods described in the Questions, comments, and how to contact us section and we will take appropriate measures to investigate and address the issue promptly.

CEO360 is responsible for the processing of Personal Data it receives and subsequently transfers to a third party acting as an agent on its behalf. CEO360 complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, the United Kingdom, and Switzerland (for examples of such transfers, see Disclosing your Personal Data above) including the onward transfer liability provisions. In certain situations, CEO360-U.S. may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

CEO360 is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

To learn more about these Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield site.

Complaint resolution

In compliance with the Privacy Shield Principles, CEO360 commits to resolve complaints about your privacy and our collection or use of your Personal Data transferred to the United States. Individuals from the European Union, United Kingdom, and Switzerland with Privacy Shield inquiries or complaints should first contact CEO360 via the Privacy Request Form.

Your California privacy rights

California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)

For business purposes in the last 12 months, CEO360 may have collected, used, and shared Personal Data about you as described in this Privacy Statement. Each category of data that may be used by CEO360 or shared with third parties is categorically outlined in this Privacy Statement.

California consumers have a right to: (1) request access, correction, and deletion of their Personal Data, (2) opt out of the sale or sharing of their Personal Data, and (3) not be discriminated against for exercising one of their California privacy rights.

All individuals have the right to request access to and deletion of the information CEO360 holds about them either online via the CEO360 Privacy Request Form or by mail to CEO360, Privacy Office, 2681 West Canyon Ave. #545, San Diego, CA USA.

CEO360 does not sell the Personal Data of California consumers. 

CEO360 does not discriminate against individuals for exercising their privacy rights.

California Shine the Light

Residents of the State of California, under California Civil Code § 1798.83, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed Personal Data during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your Personal Data by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.

CEO360 has a comprehensive Privacy Statement and provides you with details on how you may either opt-out or opt-in to the use of your Personal Data by third parties for direct marketing purposes. Therefore, we are not required to maintain nor disclose a list of the third parties that received your Personal Data for marketing purposes during the preceding year.

Updates to this CEO360 Privacy Statement

We may update this Privacy Statement from time to time. If we modify our Privacy Statement, we will post the revised version here with an updated revision date. If we make material changes to our Privacy Statement, we may also notify you by other means, such as by posting a notice on our websites or sending you a notification. By continuing to use our website after such revisions are in effect, you accept and agree to the revisions and to abide by them.

The CEO360 Privacy Statement was revised and effective as of June 30, 2023.

Questions, comments, and how to contact us

We value your opinion. Should you have questions or comments related to this Privacy Statement, please submit a Privacy Request or send mail to:

CEO360 Privacy
Arrow Up Partners, LLC.
2681 West Canyon Ave. #545
San Diego, CA 95134 USA