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TERMS AND POLICIES
Privacy Policy




ARM GLOBAL PRIVACY STATEMENT

Last updated: January 1, 2023

 * Introduction
 * Scope
 * Personal Data We Collect
 * Device and Usage Data
 * Why and How We Use Your Information
 * When and How Can Arm Share Your Personal Data
 * How Long Do We Retain Your Information For
 * Security of Personal Data
 * Your Legal Rights
 * International Transfer of Personal Data
 * Children’s Privacy
 * Changes
 * Contact Us
 * Filing a Complaint


INTRODUCTION

This Arm Privacy Statement ("Privacy Statement") describes our privacy
practices. Please read this Privacy Statement carefully to learn how we collect,
use, share and otherwise process information relating to individuals ("Personal
Data"), and to learn about your rights and choices regarding our processing of
your Personal Data. If you are a candidate, please see Arm’s Candidate Privacy
Notice.

A reference to “Arm”, “we,” “us” or the “Company” is a reference to Arm Limited
of 110 Fulbourn Road, Cambridge CB1 9NJ, UK.



SCOPE

Arm is the controller of your Personal Data as described in this Privacy
Statement.

For the avoidance of doubt, this Privacy Statement does not apply to the extent
we process Personal Data in the role of a processor on behalf of our customers,
including where we offer to our customers various cloud products and services.


TYPES OF PROCESSING ACTIVITIES

This Privacy Statement applies to the processing of Personal Data collected by
us when you:

 * Visit our websites that display or link to this Privacy Statement;
 * Visit our branded social media pages;
 * Visit our offices;
 * Receive communications from us, including emails, phone calls, texts or fax;
   or
 * Register for, attend and/or otherwise take part in our events, webinars or
   contests.



PERSONAL DATA WE COLLECT

1. DIRECTLY FROM YOU

The Personal Data that we collect directly from you includes the following:

 * If you express an interest in obtaining additional information about our
   services, use our "Contact Us" or similar features, register to use our
   websites, sign up for an event, contest, or download certain content, we will
   require that you provide to us your contact information, such as your name,
   job title, company name, address, phone number, email address or username and
   password;
 * If you attend an event where we scan your attendee badge, we will collect
   from your attendee badge information such as name, title, company name,
   address, country, phone number and email address;
 * If you use and interact with our websites or emails, we automatically collect
   information about your device and your usage of our websites or emails
   through cookies, web beacons or similar technologies (please see the "Device
   and Usage Data" section below for more information);
 * If you use and interact with our services, we automatically collect
   information about your device and your usage of our services, through log
   files and other technologies, some of which may qualify as Personal Data
   (please see the "Device and Usage Data” section below for more information);
   and
 * If you visit our offices, you will be required to register as a visitor and
   to provide your name, email address, phone number, company name and time and
   date of arrival.

If you provide us with any Personal Data relating to other individuals, you must
explain to those individuals that their Personal Data will be used in accordance
with this Privacy Statement. If you believe that your Personal Data has been
provided to us improperly, or if you otherwise wish to exercise your rights
relating to your Personal Data, please contact us by using the information set
out in the “Contact Us” section below.

2. FROM OTHER SOURCES

We also collect information about you from other sources and combine this
information with Personal Data provided by you. This helps us to update, expand
and analyze our records, identify new customers and create more tailored
advertising to provide services that may be of interest to you. In particular,
we collect Personal Data from third party providers of business contact
information, including professional contact details, employment-related
information (such as job titles) and device / location-related information (such
as IP addresses) for purposes of targeted advertising, delivering relevant email
content, event promotion and profiling.

We obtain information through partners, vendors, suppliers and other third
parties. These enterprises largely fall into the following categories: partners,
hosts or vendors at events or trade shows, research partners and enterprises
that deploy the Arm technology or third-party offerings that include Arm
technology. We might also obtain information through a partner as part of our
business operations. This kind of data is used for work such as improving
algorithms and data models, product testing and improvement, enhancing existing
products and developing new capabilities and features.



DEVICE AND USAGE DATA

We use common information-gathering tools, such as cookies, web beacons and
similar technologies, to automatically collect information that may contain
Personal Data from your computer or mobile device as you navigate our websites,
our services or interact with emails we have sent to you. For details on the
cookies we use and your choices, please visit Arm’s Cookie Policy.

We gather certain information automatically in connection with the use of our
website by individual users. This information may include IP address (or proxy
server), device and application identification numbers, location, browser type,
Internet service provider and/or mobile carrier, the pages and files viewed,
searches, operating system and system configuration information and date/time
stamps associated with your usage.

In addition, we gather certain information automatically as part of your use of
the cloud products and services. This information may include the information
described in the preceding paragraph.

This device and usage data is primarily used for the purposes of identifying the
uniqueness of each user logging on (as opposed to specific individuals), apart
from where it is strictly required to identify an individual (e.g., by means of
an obvious identifier, such as a name) for security purposes or as required as
part of our provision of the services to our customers (where we act as a
processor). In any event, device and usage data will constitute your Personal
Data.



WHY AND HOW WE USE YOUR INFORMATION

We collect and process your Personal Data for the purposes and on the legal
bases identified in the following:

 * Providing our websites and services: We process your Personal Data to perform
   our contract with you for the use of our websites and services and to fulfill
   our obligations under applicable terms of use/service; where we have not
   entered into a contract with you, we base the processing of your Personal
   Data on our legitimate interest to operate and administer our websites and to
   provide you with the content you access and request (e.g., to download
   content from our websites);
 * Promoting the security of our websites and services: We process your Personal
   Data by tracking use of our websites and services, creating aggregated,
   non-Personal Data, verifying accounts and activity, investigating suspicious
   activity and enforcing our terms and policies, to the extent this is
   necessary for our legitimate interest in promoting the safety and security of
   the services, systems and applications and in protecting our rights and the
   rights of others;
 * Managing user registrations: If you have registered for an account with us,
   we process your Personal Data by managing your user account for the purpose
   of performing our contract with you according to applicable terms of service;
 * Handling contact and user support requests: If you fill out a “Contact Me”
   web form or request user support, or if you contact us by other means
   including via a phone call, we process your Personal Data to perform our
   contract with you;
 * Managing event registrations and attendance: We process your Personal Data to
   plan and host events or webinars for which you have registered or that you
   attend, including sending related communications to you, to perform our
   contract with you;
 * Managing contests or promotions: If you register for a contest or promotion,
   we process your Personal Data to perform our contract with you. Some contests
   or promotions have additional rules containing information about how we will
   process your Personal Data;
 * Developing and improving our websites and services: We process your Personal
   Data to analyze trends and to track your usage of and interactions with our
   websites and services to the extent it is necessary for our legitimate
   interest in developing and improving our websites and services and providing
   our users with more relevant content and service offerings, or where we seek
   your valid consent;
 * Assessing and improving user experience: We process device and usage data as
   described above, which in some cases may constitute Personal Data, to analyze
   trends and assess and improve the overall user experience to the extent it is
   necessary for our legitimate interest in developing and improving the service
   offering, or where we seek your valid consent;
 * Assessing capacity requirements: We process your Personal Data to assess the
   capacity requirements of our services to the extent that it is in our
   legitimate interest to ensure that we are meeting the necessary capacity
   requirements of our service offering;
 * Identifying customer opportunities: We process your Personal Data to assess
   new potential customer opportunities to the extent that it is in our
   legitimate interest to ensure that we are meeting the demands of our
   customers and their users’ experiences;
 * Registering office visitors: We process your Personal Data for security
   reasons, to register visitors to our offices and to manage non-disclosure
   agreements that visitors may be required to sign, to the extent that such
   processing is necessary for our legitimate interest in protecting our offices
   and our confidential information against unauthorized access;
 * Sending marketing communications: We process your Personal Data to send you
   marketing information, product recommendations and other non-transactional
   communications (e.g., marketing newsletters, telemarketing calls, SMS, or
   push notifications) about us and our affiliates and partners, including
   information about our products, promotions or events as necessary for our
   legitimate interest in conducting direct marketing or to the extent you have
   provided your prior consent (please see the "Your legal rights" section below
   to learn how you can control the processing of your Personal Data by Arm for
   marketing purposes); and
 * Complying with legal obligations: We process your Personal Data when
   cooperating with public and governmental authorities, courts or regulators in
   accordance with our legal obligations under applicable laws to the extent the
   processing or disclosure of Personal Data to protect our rights is necessary
   for our legitimate interest in protecting against misuse or abuse of our
   websites, protecting personal property or safety, pursuing remedies available
   to us and limiting our damages, complying with judicial proceedings, court
   orders or legal processes or to respond to lawful requests.

Where we need to collect and process Personal Data by law, or under a contract
we have entered or will enter into with you, and you fail to provide the
required Personal Data when requested, we may be unable to perform our contract
with you.



WHEN AND HOW CAN ARM SHARE YOUR PERSONAL DATA?

SHARING WITH THIRD PARTIES

We share information with the following third parties:

 * Third party service providers (for example advertising and event / marketing
   services, information technology, product delivery, website hosting, data
   analysis, IT services, auditing, payment processing or customer service and
   other service providers) in order for these third parties to provide services
   on behalf of Arm.
 * As required by law, to comply with a legal obligation, in connection with a
   request from a public or governmental authority, or in connection with court
   or tribunal proceedings, to prevent loss of life or injury, or to protect our
   rights or property. Where possible and practical, and where we are legally
   permitted to do so, we will tell you in advance of such disclosure.
 * Relevant third parties as part of a contemplated or actual corporate
   transaction such as a reorganization, merger, sale, joint venture,
   assignment, transfer or other disposition of all or any portion of our
   business, assets or stock (including in connection with any bankruptcy or
   similar proceedings).
 * With third parties that are not suppliers or vendors but are working with us
   to offer certain opportunities such as sweepstakes, contests, and similar
   promotions, to enable joint products or research studies, or to facilitate
   services like message boards, blogs or other shared platforms. In these
   cases, additional terms or privacy notices will be provided where required.

SHARING WITHIN ARM

We share your information across the Arm corporate group in order to provide,
maintain and develop our products and services. Arm employees will only access
the information to the extent necessary to achieve the particular purpose(s) and
perform their job.

We also share information that is not Personal Data, such as anonymized or
aggregated information, for purposes such as analysis, identifying trends in the
areas of our products and to help research and develop new Arm services.

DATA AGGREGATION AND ANALYTICS

We collate your Personal Data which you provide to us or we collect and use it
anonymously for analytics, benchmarking and to effectively monitor our website
and improve your user experience.



HOW LONG DO WE RETAIN YOUR INFORMATION FOR?

We retain Personal Data for the period necessary to:

 * Provide requested Arm services, as needed to comply with legal obligations
   (e.g., maintaining opt-out lists to fulfill advertising and marketing choices
   or to comply mandatory record retention or legal hold requirements), as
   agreed in an individual consent; and
 * to resolve disputes, and to otherwise fulfill the purposes, rights and
   obligations outlined in this Privacy Statement.

Retention periods can vary significantly based on the type of information and
how it is used and our retention periods are based on criteria that include
legally mandated retention periods, pending or potential litigation, our Arm
intellectual property or ownership rights, contract requirements, operational
directives or needs, and historical archiving. When Personal Data is removed
from our systems, it will be deleted or destroyed using appropriate security
protocols so that it cannot be reconstructed or read.



SECURITY OF PERSONAL DATA

We take all reasonable and appropriate steps to protect your Personal Data to
prevent loss, misuse, unauthorized access, disclosure, alteration, and
destruction. Our technical and organisational safeguards include physical access
controls, systems and data access controls, encryption, internet firewalls,
intrusion detection and network monitoring depending on the nature of the
information and the scope of processing. We also contractually require our
business partners and suppliers to protect Personal Data from accidental or
unlawful destruction, loss, alteration, unauthorized disclosure, or access.



YOUR LEGAL RIGHTS

If you are located in a European Union Member State and certain other countries,
you have the following additional rights:

Access and / or have your information provided to you

You can request a copy of the Personal Data we are processing about you.

Change or correct

You can ask us to change, fix or update information about you (for example, if
it is incomplete or inaccurate).

Deletion

You can ask us to delete Personal Data about you.

Restrict or limit use

You have the right to restrict our processing (i.e., stop any active processing)
of your Personal Data (for example, if the information about you is inaccurate).

Portability 

In certain circumstances, you have the right to obtain Personal Data we hold
about you in a structured, electronic format, and to transmit such data to
another data controller.

Object

You have the right to object to Arm using your Personal Data in some
circumstances (in particular, where we don’t have to process the data to meet a
contractual or other legal requirement, or where we are using the data for
direct marketing). See below for information about how to unsubscribe to direct
marketing.

Opt-out

You can withdraw your consent, including for marketing messages that you receive
from us.

Please note that these rights may be limited, for example if fulfilling your
request would reveal Personal Data about another person, or if you ask us to
delete information which we are required by law or have compelling legitimate
interests to keep. If you have unresolved concerns, you have the right to
complain to a data protection authority as described below.

Make a Data Subject Access Request

Your California Privacy Rights

If you are a California resident, California law may provide you with additional
rights regarding our use of your personal information. To learn more about your
California privacy rights, visit the CCPA Privacy Statement.



INTERNATIONAL TRANSFER OF PERSONAL DATA

Your Personal Data may be collected, transferred to and stored by us in the
United States and by our affiliates and third parties disclosed above, that are
based in other countries.

Therefore, your Personal Data may be processed outside your jurisdiction, and in
countries that may not provide for the same level of data protection as your
jurisdiction, such as the European Economic Area (EEA). We ensure that the
recipient of your Personal Data offers an adequate level of protection, for
instance by entering into the appropriate data processing agreements and, if
required, standard contractual clauses for the transfer of data as approved by
the European Commission (Art. 46 GDPR).



CHILDREN’S PRIVACY

We will not knowingly collect Personal Data from children under the age of 13
years. On occasion Arm does run campaigns to encourage the use of technology for
children under the age of 13. Such campaigns are strictly for educational
purposes only. Any information collected by Arm of participating children under
the age of 13 is done with the consent of the parent or legal guardian and the
data collected is strictly segregated and deleted immediately after the end of
any such campaign.



CHANGES

We may modify this Privacy Statement at any time. If we make changes to this
Privacy Statement, then we will post an updated version of this Privacy
Statement on our website. We will specifically notify you by email or through a
notice on our website homepage about any material changes to this Privacy
Statement.



CONTACT US

If you believe we have used your Personal Data in a way that is not consistent
with this Privacy Statement or your choices, or if you have any questions or
comments about this Privacy Statement, please contact the Arm Global Privacy
Office at by emailing here: privacy[at]arm[dot]com. Any request will be
evaluated and completed in accordance with applicable data protection law,
including verification of the requestor’s identity.

Alternatively, please contact us at the following address:

Global Privacy Office
Arm Limited
110 Fulbourn Road
Cambridge
CB1 9NJ



FILING A COMPLAINT

If you have a complaint about this Privacy Statement or any element of how we
use your Personal Data, then please contact us first. If you are not satisfied
and are located in a European Union country, then please contact your local data
protection authority. If you are based in, or the issue relates to, the UK, you
can contact the Information Commissioner’s Office at the following address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Alternatively, you can use an online form via the Information Commissioner’s
website (https://ico.org.uk/concerns).

If you are based in, or the issue you would to complain about took place
elsewhere in the EEA, please visit this website
(https://edpb.europa.eu/about-edpb/about-edpb/members_en) for a list of local
data protection authorities in other EEA countries.

Last updated: January 1, 2023, SP-LES-PRE-20809 Version: 1.09

Copyright © 2023 Arm Limited (or its affiliates). All rights reserved.

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