The following describes the privacy policy guidelines for Arrivalist Company and its subsidiaries and affiliates (collectively, “Arrivalist”) regarding the collection and use of personal or corporate information that is provided to Arrivalist or collected on Arrivalist’s website, arrivalist.com.
This privacy policy was last updated on December 20, 2019.
Arrivalist requests that users check this Privacy Policy periodically as it may have changed. The new provisions will be effective as soon as they are posted.
Arrivalist provides analytics services for marketers, including destination marketers like tourism boards and Convention and Visitor’s Bureaus and other government-funded or government-related organizations. Our services measure the effectiveness of their marketing campaigns by measuring – in aggregate – which messages are most effective at influencing users to visit their place. This agreement outlines how we collect information, what information we collect and how we use this information on our site, Arrivalist.com, and for Arrivalist’s marketing services.
On Arrivalist.com we collect information that helps us analyze the effectiveness of our website and its performance. We may collect and use non-Personally Identifiable Information (“Non-PII”) information (such as in aggregate to gauge the effectiveness of our own marketing programs or deliver advertising messages to our site visitors for marketing purposes. We also collect Personally-Identifiable information (“Non-PII”) from information entered in to our “Contact Us” form. We only use site visitor’s PII to respond to incoming inquiries and let interested parties know about updates to our marketing services. We do not sell or share this information. If you wish to correspond with us through this form and do not wish for us to use the PII information that you’ve provided to us via our Contact Us form or other means, please email privacy@arrivalist.com.
Arrivalist marketing services collects information on behalf of its marketing partners, largely comprised of destination marketers. The information that we collect includes Non-PII information related to the user’s device’s destination (on a city level), which marketing messages the user has been exposed to and subsequent changes in the user’s destination on a market – by – market basis. None of the information we collect is personally-identifiable and the destination information that we collect is only the on the city level. (i.e., device 12345 was exposed to Ad 1 and 2 in City A and moved to City B). We may deliver marketing messages, such as banner ads or content, to users who have been exposed to our marketing partner’s media in order to serve subsequent marketing messages based on changes in the city that the user’s device is in. For these marketing messages, the information the we collect includes Non-PII information such as IP addresses, destination derived from cell towers, information from the destinations of Wifi routers and other means of determining (on a city-wide level) the destination of a computing device. Should a user wish not to have the messages his/her device is exposed to and the subsequent changes in the device’s destination measured broadly in aggregate, he / she may opt out by following the instructions in the opt out section below.
Arrivalist uses the information that we collect to report—in aggregate – on the effectiveness of marketing campaigns on influencing users to experience new places. We report to advertisers which online marketing messages (email, banner ads, site visits, video views, etc) preceed changes in a devices destination.
Once we collect information in aggregate about users, Arrivalist does not sell the data that we collect to third parties. Arrivalist does provide a reporting interface where our clients, the marketers, may gather insights about the effectiveness of their campaigns. In addition, Arrivalist may promote travel-related messages from our affiliates, and deliver ads in the aggregate (not to individuals) to devices which our technology has indicated have changed destinations recently.
We will not share our data with third parties unless we are required to by legal authorities or compelled to in a court of law.
Arrivalist stores its data in distributed data storage system. In the process of storing and retrieving information from such systems, some of our information may cross international borders. We do collect some limited visitation information about the effectiveness of online marketing initiatives from around the world. By submitting your data to Arrivalist or utilizing our servies, you consent to the transfer of this information in various countries around the world.
Arrivalist uses cookies on our website and in our marketing services for a few purposes. Cookies are small pieces of information stored by your browser on your computer’s hard drive and are used in website system administration to keep track of movement of an individual from one screen to another. This information may be used by our staff to detect and resolve website problems and to assist with customer support concerns. We also use the information recorded in our cookies to report on the effectiveness of ad campaigns. Most web browsers automatically accept cookies, but you can usually change your browser to prevent this. Please be assured that accepting a cookie does not give us access to your computer or personal information under any circumstances. We may use the information provided by cookies to analyze trends, administer the site, or for research and marketing purposes to help us better serve our clients. No information that personally identifies site visitors will be collected through or recorded to the cookies. Visitors can set their browsers to block and/or notify themselves of a cookie’s presence — thereby accepting or declining a cookie. No personally identifying information from site visitors will be collected. Arrivalist uses cookies to display advertisements to a user when that user is in the market that they have seen a promotion for on Arrivalist or a destination that they have requested information about or when our technology detects that the device has changed cities. For example, if a user were to visit a Tennessee tourism website and request a brochure, we may target ads to that user then they are in Tennessee that promote, for example, attractions to see in Tennessee or places to visit. Arrivalist uses cookies to promote the company’s own services and to promote messages from partner advertisers. If a user requests a brochure from a destination, for example, Arrivalist uses cookies collected from that site visit to display additional ads from the destination that the user has requested information about. We may also use cookies from a user’s visit in order promote our website or other advertisers messages through third parties. However, no personally- identifiable information will be shared with those third parties. Finally, Arrivalist uses cookies in order to monitor whether a user responds to a promotion for a destination on our site by visiting that destination. This information is collected in aggregate and may be shared with the destination marketers that we work with. No personal information is collected or distributed to third parties as part of this process.
A user may opt-out of advertisement targeted to the cookies that they have received from a Arrivalist site visit and delete the cookies resulting from a site visit by visiting these pages:
You can opt out of Arrivalist cookies by clicking here:
Arrivalist Cookie Opt Out
You can opt out of Arrivalist device id tracking by clicking here:
Arrivalist Device Id Opt Out
Through the Network Advertising Initiative (NAI), You can opt out of all partner cookies by clicking here: Partner Cookies Opt out.
You can also opt out of all tracking through Digital Advertising Alliance’s Ad Choices program you can opt-out of all tracking by visiting http://optout.aboutads.info.
Finally, as a European consumer, you may review the different options for your country at this page http://www.youronlinechoices.eu, as well as opt-out of specific programs.
The Arrivalist website contains links to other Websites belonging to alliance partners, clients, and other sites of interest to our users. Arrivalist does not control the privacy practices of these other sites. Should users depart Arrivalist’s site, it is recommended they read all relevant privacy policies.
Arrivalist.com is committed to safeguarding the confidentiality of your information. We maintain reasonable physical, technical, and administrative safeguards to protect information we process and maintain. Please be aware that although we endeavor to provide reasonable security
for the information we process and maintain, no security system can prevent all potential security breaches.
This site is not intended for use by children under the age of 13. We do not knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at info@arrivalist.com. We will delete such information from our files within a reasonable time.
We will share your information with third parties only in the ways that are described in this privacy statement. Arrivalist may provide the information collected to our business partners, which are under nondisclosure agreements with us not to disclose the information to anyone else, in order to assist us in growing our business with respect to similar products and services. If site visitors do not want their information shared in this manner they will have a chance to opt out prior to collection. Some of these business partners are located in the United States and others may be located in countries throughout the world.
Arrivalist may use or disclose information, including PII, to comply with the law or in response to a subpoena, court order, government request or other legal process, or as otherwise permitted by law. Arrivalist may also use or disclose information to prevent or take action regarding illegal activities, suspected fraud, or violations of Arrivalist’s terms of use.
In the event of a corporate reorganization, either by an operation of law, merger or purchase of assets, your information may be subject to a different privacy policy which we will make available on our website.
If site visitors have any questions concerning this privacy policy, general inquiries, media matters, or other matters described above, contact Arrivalist via email at privacy@arrivalist.com.
The information contained in this FAQ is not legal advice. Please contact a licensed attorney for guidance specific to your situation.
1. When does the GDPR take effect?
May 25, 2018
2. Who does the GDPR apply to?
Any company or organization which processes and holds the Personal Data of Data Subjects residing in the EU will be obliged to abide by the GDPR. This applies to every organization, regardless of whether or not they themselves reside in one of the 28 EU member states.
3. Is your company working towards meeting the requirements of the GDPR?
Yes. Arrivalist is participating in the Interactive Advertising Bureau (IAB) Europe’s “GDPR Transparency and Consent Framework” as a “third party” seeking to process Personal Data.
4. What constitutes “Personal Data”?
Any information related to a natural person (“Data Subject”), that can be used to directly or indirectly identify the person. It can be anything from a name, a photo, an email address, bank details, posts on social networking websites, medical information, or a computer IP address, according to the terms of the GDPR. Please note that IP addresses are not considered personally identifiable data in the US because the address associated with one user changes often.
5. Is Arrivalist a “Data Controller” under the GDPR?
No, Arrivalist is not a Data Controller. For its services, Arrivalist does not define how personal data is processed and the purposes for which it is processed.
6. Is Arrivalist a “Data Processor” under the GDPR?
Yes, Arrivalist processes Personal Data on behalf of its clients, who are Data Controllers.
7. What Personal Data does Arrivalist collect and share?
None. Arrivalist is not a Data Controller (which defines how personal data is processed and the purposes for which it is processed) and does not for itself collect, store, or share Personal Data.
8. What legal basis does Arrivalist have to process and store Personal Data (e.g. consent, legitimate interest)?
Arrivalist’s processing and storage of Personal Data is performed at the behest of Arrivalist’s clients who are the Data Collectors that control the media on which consents are collected (e.g., websites) and who define the legitimate interest for the collection of Personal Data.
9. Is Arrivalist obtaining consents from consumers?
No. Arrivalist is not a Data Controller, and Arrivalist’s services do not involve consent collection.
10. Does Arrivalist have a direct relationship with the Data Subject whose data Arrivalist processes?
No.
11. Does Arrivalist share with its Media Partners Personal Data that is sourced from 3rd parties (e.g. mobile apps, publishers, SSPs, social sharing buttons etc.)?
No. Arrivalist does not share any Personal Data with its Media Partners (advertisers who place Arrivalist’s pixels in paid media).
12. How does Arrivalist plan to disseminate consents to Media Partners?
Since Arrivalist does not have a direct relationship with Data Subjects this does not apply to Arrivalist.
13. Does Arrivalist have a technical approach for how Arrivalist will receive from Media Partners Data Subjects’ requests to be erased (forgotten)?
Yes, Arrivalist provides an email address to receive requests (privacy@arrivalist.com). This email is monitored regularly by Arrivalist personnel.
14. Does Arrivalist collect Personal Data from children? What ages do you use for this determination (e.g. 13? 16? 18?). Please specify if this differs by market?
No. Arrivalist does not collect, store or share Personal Data from children.
15. Are an individual’s preferences and changes to those preferences communicated to third parties to whom their personal information has been disclosed?
Arrivalist does not pass along any personal data to third-parties. When Arrivalist receives a do- not-track signal, Arrivalist ceases to monitor a consumer’s GPS data and does not retain the IP Address.
16. Is the Personal Data collected limited to the information necessary and relevant to the processing for which the information was collected?
Arrivalist is not a Data Controller and does not for itself collect Personal Data.
17. Do your Personal Data processing activities include the processing of sensitive personal information (information revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, and genetic data or data concerning health or sex life and sexual orientation)?
No.
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Arrivalist Co. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
| Category | Examples | Collected |
A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | NO |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information. | Genetic, physiological,behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | NO |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A:
Identifiers.
Category B:
California Customer Records personal information categories.
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: (833) 278-5781
Website: https://www.arrivalist.com
Email: privacy@arrivalist.com
Postal Address:
Arrivalist Co.
Attn: Privacy Compliance
1460 Broadway, 6th Floor
New York, NY 10036