This Privacy Policy applies to how information is collected, used, disclosed, transferred, stored, retained, or otherwise processed on our website www.arrowstars.vc. Users may be referred to in this Policy as “you” and “your'' as applicable and should be construed accordingly and references in these Terms to "us ","we " and “our” as applicable are to Arrow Stars LLC and should be construed accordingly. User and Arrow Stars Fund I SPV-SP LLC Series A may be referred to individually as “Party” and collectively as “Parties”. This site operates "AS-IS" and "AS-AVAILABLE," without warranties of any other kind. We are not responsible for events beyond our direct control.  Please read this policy carefully before asserting your consent. If you do not agree with this policy, do not access or use the services, or any other aspect of the website.
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Information we collect.

We may collect and receive the following data and other information:

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• Personal     Information, including (but not limited to) the documents submitted for     KYC, including identification cards, photographs, or financial     information.
• Log     data, including (but not limited to) Internet Protocol (IP) address, the     address of the web page visited before using the service, browser type and     settings, the date and time the services were used, information about     browser configuration and plugins, language preferences and cookie data.
• Location     Information to track the geographic location, including (but not limited     to) IP address from browser or device to approximate the location.
• Device     Information, including (but not limited to) type of device, what operating     system is used, device settings, application IDs, unique device     identifiers and crash data.
• Contact     Information, including (but not limited to) email address and social media     identifiers. 
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How we collect information.

We collect your Personal Information when you submit it to us whenexplicitly asked for on our website. 
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How we use information.

We use the information collected in furtherance of our legitimateinterests in operating our services, websites and business. More specifically,we use the information:

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• To provide, update, maintain and protect our websites and business. This includes the use of information to support the delivery of the services, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities.
• To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your information to respond.
• To develop and provide search, learning and productivity tools and additional features. We try to make the services as useful as possible. For example, we may improve functionality or update our services based on historical use and predictive models, or identify organizational trends and insights to customize a services experience or create new productivity features and products.
• Displaying your historical transaction or information.
• To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications including (without limitation) updates, newsletters, and     promotional offers regarding our services.  You may opt out from receiving the promotional and marketing information at any time.
• For billing, account management and other administrative matters. We may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of payments.
• To investigate and help prevent security issues and abuse.
• For analytics and improvement to improve our website's functionality, performance, and security.
• As required by applicable law, legal process or regulation.

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How long we retain your information.

We store your information for the time period that it is reasonablynecessary to provide the services and comply with the applicable laws. We mayretain copies of information about you and any transactions or services inwhich you may have participated for a period of time that is consistent withapplicable law, applicable statute of limitations or as we believe isreasonably necessary to comply with applicable law, regulation, legal process,or governmental request, to detect or prevent fraud, to collect fees owed, toresolve disputes, to address problems with our services, to assist withinvestigations, to enforce our general terms or other applicable agreements orpolicies, or to take any other actions consistent with applicable law.

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If information is aggregated, anonymized or de-identified so that it isno longer reasonably associated with an identified or identifiable naturalperson, we may retain it for a longer period of time and use it for anybusiness purpose.

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Transfer of data.

We may transfer some data to Third Party Service Providers (includingSub-processors). We will not transfer your Personal Data originating in the EUto a Third Party Service Provider unless we ensure that such a Third PartyService Provider is obliged to provide at least the same level of privacyprotection to your personal data as required under the Principles ofGDPR. 

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We may transfer your data to such Third Party Services providers if:

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• a user has expressly agreed to provision to a third party and handling in advance

• the provision is required by laws and ordinances
• the personal information is necessary for the implementation of a contract on the provision of services and it is extremely difficult to obtain normal consent for economic and technical reasons

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European Citizens Privacy Rights.

Subject to certain limitations and exceptions, if you are accessing ourwebsite in the European Economic Area (EEA), the EU General Data ProtectionRegulation (GDPR) provides you with the following rights:

• The right to request information     about whether and which personal data is processed by us, and the right to     demand that personal data is rectified or amended.
• The right to request that personal data should be deleted.
• The right to demand that the processing of personal data should be restricted.
• Withdraw your consent to the processing and use of your data completely or partially at any time with future application.
• Have the right to obtain your personal data in a common, structured and mechanically readable format.
• Contact our data protection officer if there are any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data.
• The right to complain to the responsible supervisory authority if believed that the processing of your personal data is in violation of the legislation.

EU residents can exercise these rights by raising a request bycontacting us at the information provided in the contact us section.

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California citizens privacy rights.

This section applies only to California residents. It describes how wecollect, use and share Personal Information of California residents inoperating our business, and their rights with respect to that PersonalInformation. For purposes of this section, “ Personal Information” has themeaning given in the California Consumer Privacy Act of 2018 (“ CCPA”) butdoes not include information exempted from the scope of the CCPA.

As a California resident, you have the rights listed below.However, these rights are not absolute, and in certain cases we maydecline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:some text
   
  • The categories of Personal Information that we have collected.
   
  • The categories of sources from which we collected Personal Information.
   
  • The business or commercial purpose for collecting and/or selling Personal Information.
   
  • The categories of third parties with whom we share Personal Information.
   
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of      Personal Information received by each category of third party recipient.
   
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
 
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Opt-out of sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
• Opt-in. We contractually prohibit our publishing and advertising clients from placing our technology on pages that target individuals younger than 16 years old. If we learn that you are younger than 16 years old, we will asking for your permission (or if you are younger than 13 years old, your parent or guardian’s permission) to sell your Personal     Information before we do so.
• Non-discrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

We will need to confirm your identity and California residency toprocess your requests to exercise your information, access or deletion rights.We cannot process your request if you do not provide us with sufficient detailto allow us to understand and respond to it.

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External Links.

Our site maycontain links to third party websites. Please be aware that we are notresponsible for the privacy practices of such third-party sites. We do notexercise control over third party websites displayed as search results or linksfrom within our site and these third-party websites may place their own cookiesor other files on your computer, collect data or solicit personal informationfrom you. As such, we encourage you to be aware of this fact when you leave ourwebsite and to read the privacy policies or statements of each and everywebsite that you visit which collects personally identifiable information. ThisPrivacy Policy applies solely to information collected on our site.

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Age Limitations.

To the extent prohibited by applicable law, we do not allow the use ofour services by anyone younger than 18 [AM1] [AO2] yearsold. If you learn that anyone younger than 18 has unlawfully provided us withpersonal data, please contact us and we will take steps to delete suchinformation.

 [AM1]do we want tosay 21 for the US ?

 [AO2]The age limit for consent forprivacy of data is 18 in most US states, in few states it is 16, but max is 18only.

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Complaint.

EU and UKindividuals with inquiries or complaints regarding our handling of personaldata received in reliance on the EU GDPR should first contact us at: info@arrowstars.vc

You may havethe right to lodge a complaint with the data protection authority of yourcountry of residence. If you live in the UK, you can make a complaint with theInformation Commissioner’s Office (ICO) at this address. If you live in the EU, you can findthe relevant data protection authority here. To submit a complaint tothe FTC, click here.

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Changes To This Privacy Policy.

We may change this Privacy Policy from time to time. We will post thechanges to this page and encourage you to review our Privacy Policy to stayinformed. If we make changes that materially alteryour privacy rights, we will provide additional notice, such as via email orthrough the Services.[AM1] [AO2] If you disagree with the changes to this Privacy Policy, you should not use ourservices. 

Contact Us at info@arrowstars.vc

Last Updated: November 2024

 [AM1]can we reservethe right to make changes to the policy but not need to inform about theupdates made?

 [AO2]Yes, but this is for materialchanges that may alter the privacy rights. In such cases, it is required underGDPR