Privacy Agreement

1. Introduction

Arrow Senior Living Management, LLC (“Company or “we”) values the privacy and secure processing of your data very highly. Transparency with regard to the use of your personal data is crucial for building trust, goodwill and a strong relationship. That is why we will tell you how we collect and process your personal data in this Privacy Policy. This ensures that you as a user always know what kind of and how much personal information we have about you and what we use it for.

Before discussing this Privacy Policy in detail, we would like to highlight some of the key principles behind it.

This Privacy Policy exists for three reasons:

Explaining the way we use the information you share with us in order to build a digital platform and give you a great experience with it; Ensuring that you understand what information we collect with your permission, and what we do and not do with it; and Holding us accountable for protecting your rights and privacy under this Privacy Policy.

We hereby confirm, among other things, that we comply with the legal requirements for the processing of personal data, pursuant to national regulations.

When you visit our App Platform (, you are expected to have read this Privacy Policy. Please note that we update this Privacy Policy on a regular basis. Therefore, we kindly ask you to visit this page regularly. Substantial changes will be clearly communicated on the Arrow App platform. Obviously, you can save this Privacy Policy in digital format, print it out, or otherwise make a copy of it.

If you have any questions or concerns after reading this Privacy Policy, please contact us via email at

2. Personal data collected

The personal information we collect includes:
Registration information, including your name, email address, and other details you provide us (birth date, phone number, community address) when you sign up for the Arrow App platform. When you place an order via the Arrow App platform, you do so within your community, who is deemed responsible for the proper execution of the service delivery. If any financial data is requested, the processing thereof will be handled through external e-commerce payment software. Such data will not be communicated to Arrow App and will be handled by (payment) service providers only. Other information collected includes:

 Information provided when filling out a form or our website, or when filling in specific Cubes;

 Information provided when subscribing to our newsletter;

 Information provided when placing orders on the Arrow App platform;

 Information provided in the context of surveys or any other marketing communication;

 Information provided in connection with the use of certain websites that are associated with the Arrow App platform, such as Cubigo or Zendesk, with which our support department can assist you with any questions or problems you may encounter when using the Arrow App platform;

 Any other information that you send to us, such as when you contact us with questions or comments.

2.2. Cookies
Cookies are small files that are stored on the computer or smartphone of a website or app visitor. These files store small amounts of data on a specific user and website, which can be accessed from the user’s computer. The web page can therefore be tailored to the user. The Arrow App platform only uses essential cookies.
You can find out more about the use of cookies in our Cookies policy.

2.3. Data for which explicit permission has been obtained
Another information category comprises information that enables us to offer you additional features. We never receive such information unless you expressly choose to share it with us. Here are some examples:
– Your specific location: We will never collect or use your specific device location without first getting your explicit permission.
– Your microphone: By using the microphone, you will be able to control the Arrow App platform with your voice. Nevertheless, we will never access or use your microphone unless you give us explicit permission to do so. Even if you give us permission to do so, you will always have the ability to disable access to the microphone.

In addition, service providers offering their services via Cubes on the Arrow App platform may collect additional personal data.

Although in principle we do not collect sensitive personal data (such as data on race, ethnic origin, religious beliefs, criminal background, physical or mental health, and/or sexual preferences), it is possible that this type of information will be processed. Based on how you use the Arrow App platform – and certain Cubes in particular – implicit information about your health, medication, religion and more may be communicated. We would like to draw your attention to this fact and make you aware of the sensitivity of this data. Obviously, we take the necessary measures to protect your personal data.

3. Data collection method

Most personal data is supplied by yourself as a user – when registering or using the Arrow App platform, for instance – although we may also receive it automatically from your computer system or mobile device. Furthermore, depending on the kind of profile you opt for and the Cubes you use, third parties such as caregivers, family, acquaintances, etc., may also provide additional personal data about you. The community will operate as Controller of the Personal Data of End-Users within the scope of this Community master license. The community collects an opt-in from all End-Users on the product license.

Users can update their personal information through their Arrow App account. Account removals are processed by our support team. The email address for these requests is or our support channels, reachable through the contact form in our support center.

4. Data Controller

Pursuant to national regulations on personal data protection, the “Data Controller” is the natural or legal person who determines the purpose and means for the processing of personal data. The Data Controller can do this alone or in cooperation with other parties.

The company that manages the Arrow App platform and processes your personal data, whether on behalf of its partners or not, is:

Arrow Senior Living
3333-9 Rue Royale
Saint Charles, Missouri 63376
(800) 983-8876
Email address:

We are solely responsible for processing personal data for our own purposes, such as handling the personal data of our (prospective) users for customer relationship management, sales, direct marketing, shipping and invoicing,

Furthermore, your community and its related service providers may offer their services and products on the Arrow App platform through specific Cubes. With regard to the personal data collected by these service providers on the aforementioned Cubes, only those service providers are responsible for the data processing and Arrow App acts solely as a processor. This means that Arrow Senior Living processes such personal data solely according to the instructions of the service provider. Therefore, Arrow Senior Living will only be liable for such data as a processor and not as Data Controller.

5. Purposes of data processing

We offer digital services on the Arrow App platform with the following purposes:
 to connect residents and their family with the community and its staff;
 to provide access to quality services in terms of comfort, well-being, leisure and healthcare;
 to inform residents and their family on the news and activities in the community;
 to follow-up on requested services;
 to support healthcare professionals in their work processes.
All the information we collect when you visit the Arrow App platform is related to the provision of services via the Arrow App platform and its features.

In brief, we collect information for the following specific purposes:
 Information we need so that you can use the Arrow App platform;
 Information we can use in the future to provide new solutions and improved experiences if you choose to share that Information; and Information we need so that we can offer you the best possible support when using the Arrow App platform.

5.2. Information we need so that you can use the Arrow App platform
We collect your data first of all to create and maintain your personal account on Arrow Community, to ensure the proper functioning of the Arrow App platform and to deliver the services and/or products (or have them delivered) that you order from or via the Arrow App platform.

For instance, you can use the Cubigo platform to:
 Communicate with your community, staff, caregivers, family or acquaintances, and vice versa;
 Receive the necessary information to follow up on the requested services;
 Set up communication between you, your family, the community, service providers and its staff;

5.3. Information we need in order to provide new solutions and improved experiences
Based on the personal data we have about you, and in order to optimize our services, we may analyze, evaluate and assess your preferences and needs. For clarity’s sake, we emphasize that these activities can be qualified as ‘profiling’ under national and European regulations on personal data protection.

We also use the personal data and information we collect to:
 Customize your experience as a user;
 Determine the kind of content and offers you are most interested in and inform you about them;
 Offer you a better service, answer more of your questions, and meet your needs better;
 Provide you with information;
 Process your queries and orders quickly; and
 Communicate with you on various topics such as events, news items, and Platform feedback.

We never sell, trade or transfer your personal data to/with any third parties, unless we inform you about this in advance and you give us your explicit permission to do so.

We do share your contact details with website hosting partners or other third parties that help us conduct our business or operate our website and the Arrow App platform, or that provide services directly to you. This mostly – but not only – includes service providers and product vendors that have a Cube on the Arrow App platform. These partners are also obliged to keep this information confidential. Furthermore, we may share your personal data when we are legally obliged or entitled to do so.

Certain information that cannot lead to the identification of a natural person, such as website/platform statistics and similar data, may be shared with external parties for marketing, advertising or other purposes.

6. Protecting your data

We strive to protect the information of our users. Your password is the first level of protection for your user account. You should therefore use a unique and strong password, restrict access to your browser and computer, and log out after using the Arrow App platform. Furthermore, we always take the appropriate technical and organizational measures consistent with industry practice to protect your personal data against accidental or unwanted destruction, loss, modification, access or any other unauthoroptized processing.
We have also implemented several security measures to guarantee an appropriate level of security according to technological evolution, implementation costs and the nature, scope, context and purpose of the processing.
We store your personal data on secure servers, which are only accessible to a limited number of people who have special access rights to these systems in emergency cases. These technicians are also bound by a confidentiality agreement and must always use and handle personal data in accordance with the Arrow App Privacy Agreement.

Furthermore, all personal data is encrypted by Secure Socket Layer (SSL) technology.

Moreover, we implement a variety of security measures to protect your personal data when you, as a user, enter your data or access your personal information. While we consider these policies and procedures to be adequate, there is still a risk that your personal data could be misappropriated. No method of transmission over the internet, or method of electronic storage, is completely secure. Therefore, we cannot guarantee the absolute security of your personal data. If you have any questions about security on our site, you can send an email to us at email address specified in Section 13.

7. Data retention period

We store your personal data as long as your account remains active and no longer than necessary unless a longer retention period is required or allowed by law. Once you ask us to delete your profile, your data will be permanently and irrevocably removed from the Arrow App platform unless a longer retention period is required or allowed by law. Inactive users’ personal data may be anonymized in order to assess and improve the Arrow App platform and the services offered therein. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide requested services or information to you; (ii) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or; (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

8. Your rights as a Arrow App website or platform user

We process your personal data in a fair and lawful manner. This means that we only process your personal data for the legitimate purposes explicitly stated in Section 5. Furthermore, we ensure that the type and amount of personal information we collect is always relevant and in reasonable proportion to the purposes for which it is processed.

8.1. Right of access
Anyone who proves their identity has the right to access the personal data we hold about them. This means that you have the right to request information about the data we process, the purposes for which we process it, the categories of personal data concerned, and the recipients we share your data with. This Privacy Policy is a first step towards this. You have the right to ask us to provide you with an overview of all personal data we hold and process about you, as well as the source from which we have obtained it, in an easily intelligible way.

8.2. Right to rectification
When we process personal data, it is important that such data is accurate. Therefore, you can always tell us to correct or delete inaccurate or incomplete data about you.
Since we cannot detect errors or omissions in your personal data, we are counting on you to inform us of any inaccuracies or omissions and to make the necessary adjustments to your registration data.

8.3. Right of objection/Right to be forgotten
Any user can exercise their right to object to the processing of personal data for serious and legitimate reasons, free of charge. However, the user cannot object to the processing of personal data if the data is necessary to fulfill the respective contractual obligations. Arrow Senior Living will notify the user of the deletion of their personal data within thirty (30) days.

8.4. Exercising these rights
You can exercise the above rights by sending us a written and signed request, accompanied by a copy of your identity card, to We will respond to your request as soon as possible.

9. Abrogation of this Privacy Statement

If you don’t or no longer agree to the processing of your personal data as described in this Privacy Policy, you can delete your profile or contact us at the email address set forth in Section 13. Please note that we will not be able to process questions or contact you without your personal data.

You can unsubscribe from emails sent by the Arrow App platform by clicking ‘Unsubscribe’ at the bottom of the email or by following this link. Important service-related emails will still be sent.

10. Links to third-party websites

The Arrow App platform may contain links to websites, products and/or third-party services. If these websites are not managed by Arrow Senior Living, Arrow Senior Living can in no way be held liable for their content nor for the privacy policy that applies to them. Nevertheless, protecting the integrity of the Arrow App platform is our highest priority, and we appreciate any feedback you may want to give us regarding these websites.

11. Can children use the Arrow App platform?

Persons under the age of 18 can only use the Arrow App platform if they submit a written permission from a parent or legal guardian who has read this Privacy Policy. In the case of underage users, the parents or legal guardians are fully responsible for all actions taken by the minor. We are committed to protecting the privacy needs of children. We do not target the Arrow App platform or our website to children less than 18 years of age or knowingly collect information from children for the purpose of selling products or services.

12. Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. The California Consumer Privacy Act (“CCPA”) gives California residents the right to opt out of the “sale” of their personal information. We do not sell personal data in the traditional sense; that is, we do not generate revenue from disclosing your data. However, in order to provide you with the services or information you request, we may share information with third parties, or they may automatically receive certain limited information associated with you as part of your use of our services, as described above. We also may share information, including contact information, with third parties as set forth in this Privacy Policy, which might be considered a “sale” under California law.

California Consumers who wish to opt out of the sale of their personal data may opt out by contacting us

Colorado, Connecticut, Virginia, and Utah each provide their residents with rights to:
• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their residents with rights to:
• Correct inaccuracies in their personal information.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Please note that we do not currently sell data triggering these statutes’ opt-out requirements. Nonetheless, to exercise any of these rights, please contact us

13. Modifications to this Privacy Policy

Since we want to continuously improve our website, the Arrow App platform and our services, we occasionally adjust this Privacy Policy so that it is consistent with applicable laws, our business needs, and the needs of our users, visitors and service providers.

That is why we publish updated versions of this Privacy Policy on the website and on the Arrow App platform. These new versions are given a timestamp so that you can check which version of the Privacy Policy is the most recent. Important changes will always be communicated to you.

14. Contact

In case you have any question regarding Arrow App data privacy policy, please contact Arrow Senior Living at
Arrow Senior Living, 3333-9 Rue Royale, Saint Charles, MO 63376 (800) 983-8876


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