Arc generally acts as a processor for personal information in Customer Content. The customer determines the purposes and lawful basis, controls access and instructs processing under an applicable data processing agreement, which must be in place before personal data is uploaded. Do not upload sensitive personal information without expressly agreed arrangements.
Arc acts as a controller for its website enquiries, business contacts, account administration and billing. We rely on legitimate interests in responding to enquiries, managing business relationships and securing the service; contract where necessary to provide a service to an individual; legal obligations for required records; and consent for optional marketing. Separate consent is required for non-essential tracking where applicable.
The customer’s contractual authorisation of service providers is distinct from an individual’s data-protection consent. Subprocessor authorisation, notice of changes and the opportunity to object are governed by the data processing agreement and applicable law.