Privacy Policy (RoW)

*This Privacy Policy applies to individuals and businesses residing outside the European Economic Area (EEA).

1. Introduction

Artoh Inc. ("Artoh," "we," "us," or "our") provides stablecoin-powered payment solutions, facilitating the use of stablecoins and associated applications for businesses.

This Privacy Policy describes our practices concerning the information we receive or collect when you visit our website located at artoh.com (“Website”) or access our online platform through the website of one of our partners (collectively, “Services”). Specifically, it describes the information we collect, how and for which purposes we may use such information, where we store it and for how long we retain the information, with whom we may share it, our use of tracking technologies and communications, our security practices, your choices and rights regarding such information, our policy concerning children, and how to contact us if you have any concerns regarding this Policy or your privacy.

Please read this Privacy Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services.

2. Policy Standards

2.1 Information Collection

We collect the following main categories of information (and to the extent one or more of them may enable the identification of a specific person or is linked to such potentially identifying data, we will deem it “Personal Information”):

Information You Provide. You may provide us Personal Information such as your name, e-mail address, phone number, and hashed password when you use our Services, create a user account, or contact us. If you choose to make any payments via our Services, you may also provide us with your payment information and preferences, as well as information about any vendors receiving payment.

Information We Collect Automatically. When you visit, interact with or use our Services, we may collect certain technical data about you. We collect or generate such data either independently or with the help of third party services, including through the use of “cookies” and other tracking technologies (as further detailed in Section 6 below). Such data consists of sensor, location, connectivity, technical and aggregated usage data, such as your GPS/GNSS location data; home and work locations; IP addresses, wireless networks, cell towers and Wi-Fi access points; non-identifying data regarding a device, operating system, and browser; activity, communication, and performance logs; issues and bugs; and user activity on our Services. This data does not enable us to learn your true identity or contact details, and serves mostly to improve the overall performance of our Services, and to better understand how our users typically use our Services and how we could improve their user experience.

Information from Third Parties. We may receive information about you from third parties. For example, we may receive information about you from outside records of third parties, such as marketing-related or demographic information. We may supplement the information we collect about you through the Website and the Services with such information from third parties in order to enhance our ability to serve you, to tailor our content to you and/or to offer you opportunities to purchase products or services that we believe may be of interest to you. If we combine such data with information we collect through the Website or the Services, such information is subject to this Privacy Policy unless we have disclosed otherwise.

2.2 Information Use

We use your Personal Information as necessary for the performance of our Services; for complying with applicable law; and based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing, customer service and support operations, and protecting and securing our users, ourselves, and members of the general public.

Specifically, we use Personal Information for the following purposes:

• To facilitate, operate, and provide our Services;
• To authenticate the identity of our users, and to allow them to access and use our Services;
• To provide our users with assistance and support;
• To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences, and difficulties;
• To contact our users with general or personalized service-related messages (such as password-retrieval); or with promotional messages (such as newsletters, special offers, new features etc.); and to facilitate, sponsor and offer certain events and promotions;
• To support and enhance our data security measures, including to prevent and mitigate the risks of fraud, error, or any illegal or prohibited activity;
• To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services;
• To enforce our Terms of Service and any other agreements between you and [Company]; and
• To comply with any applicable laws and regulations.

2.3 How We Share Your Information in Connection with the Services

• Payors and Payees. In connection with the Artoh Services, we may share some of your Personal Information with the business with which you are transacting in order to process your transaction.
• Artoh Partners. If you access our online platform through the website of one of Artoh’s partners, then we may share your Personal Information with that partner.
• Artoh Service Providers. We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting and server co-location services, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, payment processing services, e-mail and SMS distribution and monitoring services, session recording, and our business, legal and financial advisors) (collectively, “Service Providers”). These Service Providers may have access to your Personal Information, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
• Subsidiaries and Affiliated Companies. We may share Personal Information internally within our family of companies, for the purposes described in this Policy.
• Business Transfers. Should Artoh or any of its affiliates undergo any change in control, including by means of merger, acquisition, or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
• Legal Compliance. We may disclose or allow government and law enforcement officials access to certain Personal Information, in response to a subpoena, search warrant, or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
• Protecting Rights and Safety. We may share your Personal Information with others if we believe in good faith that this will help protect the rights, property, or personal safety of Artoh, any of our users, or any members of the general public.
• With Your Permission. Artoh may share your Personal Information pursuant to your explicit consent.

2.4 Location, Retention, and Protection of Information

• Your Personal Information may be maintained, processed, and stored by Artoh and our authorized affiliates and Service Providers in the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law. While privacy laws may vary between jurisdictions, Artoh, its affiliates, and Service Providers are each committed to protect Personal Information in accordance with this Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
• Artoh Partners. If you access our online platform through the website of one of  Artoh’s partners, then we may share your Personal Information with that partner.
• We will retain your Personal Information for as long as you use the Services or as necessary to fulfil the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable law. If we are required to maintain a record of any information, you may not be able to delete such information due to such requirements. Please be aware that your personal information may be stored on backup tapes and locations, third-party servers, and other repositories that may not be erasable and residual information may be retained. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such information.
• We maintain administrative, technical, and physical safeguards that are designed to protect the privacy and security of your Personal Information. For example, all information you provide is accessible only to designated staff. In addition, all information is protected by SSL/TLS encryption when it is exchanged between your web browser and the Website or via the Services. We note, however, that the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of information transmitted to our Website or via the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. In addition, where you have chosen a password for access to certain parts of our Website, you are responsible for keeping this password confidential.

2.5 Cookies and Tracking Technologies

Session Trackers. In operating the Website and the Services, we may use cookies and similar session tracking technologies (“Session Trackers”). Session Trackers help provide additional functionality to the Website, customize users’ experiences with the Website and help us analyze Website usage more accurately for research and product development purposes. We (including third parties that we work with) may place session trackers on your device for security purposes, to facilitate navigation of the Website or the Services, and to personalize your experience while using our Website or the Services. If you would prefer not to accept Session Trackers when using the Website or the Services, please follow the instructions provided by your website or mobile browser (usually located within the “Help”, “Tools” or “Edit” facility) to modify your Session Tracker settings. Please note that if you disable Session Trackers, you may not be able to access certain parts of our Website or Services and other parts of our Website or Services may not work properly. As a result, we recommend that you leave Session Trackers turned on when accessing the Website or the Services because they allow you to take advantage of some of the Website and Services’ features.

Web Beacons. In addition to Session Trackers, we may use web beacons (also known as “clear GIFs”), which are transparent graphic images placed on a web page or in an email and indicate that a page or email has been viewed or tell your browser to get content from another server. We use web beacons to measure traffic to or from, or use of, our online forms, tools or content items and related browsing behavior and to improve your experience when using the Website or the Services. We may also use customized links or other similar technologies to track hyperlinks that you click and associate that information with your Information in order to provide you with more focused communications.

2.6 Managing Your Preferences

We want to communicate with you effectively, whether by sending you relevant marketing materials or operating an intuitive and informative website. At the same time, we appreciate that your preferences regarding marketing, promotions, and online privacy will continue to evolve. This section provides you with information on how you can fine-tune your preference settings.

We may use your Personal Information to provide you with marketing or other promotional communications via mail or email. If, at any time, you would like to stop receiving these promotional e-mails, you may follow the opt-out instructions contained in any such e-mail or by contacting us as set out below. Please note that by opting out, you may prohibit Artoh from informing you of offerings that may be of interest to you. It may take up to ten (10) business days for us to process opt-out requests.

In addition, we may use your Personal Information to send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off on your device.

2.7 Accessing, Updating, and Correcting Your Information

Updating Your Information. If you are a registered user of the Services, you may update and correct your information and delete inaccuracies through your account. Specifically, you can review and edit specific types of information at any time by logging in to the Website or the Services and making changes.

Correcting Information from Third Parties. Artoh may receive Personal Information about third parties (notably, payees) from its customers and may have no direct relationship with the individuals to whom that information relates. An individual who is not an Artoh registered user who seeks to access, correct, amend, or delete data provided to us by our customers should direct those requests to the customer, as they will have access to that information through their own account. If you request that data be removed, we will respond within a reasonable timeframe.

2.8 Social Media

You may also find additional information regarding the Services on our social media sites such as Facebook, LinkedIn, or Twitter. Please keep in mind that any information you share through such social media sites is visible to all participants, and you should never post any sensitive information (such as account numbers) on such social media sites. Please carefully review the terms of use and privacy policies of these social media sites as they may differ from our policies.

2.9 Other Websites and Businesses

This Privacy Policy covers the privacy practices of Artoh only. This Privacy Policy does not apply to the practices of third-party websites, services, or applications, including those of third parties with which we partner. These third-party services are governed by their own privacy policies. Artoh is not responsible for the privacy policies and practices of these third parties.

2.10 Do-Not-Track Settings

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.

2.11 Children Under 13 Years of Age

Our Services are not directed to children under 13 years of age, and we do not knowingly collect information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child.

2.12 Your California Privacy Rights

If you are a California resident (each a “California Party”), the following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“California Personal Information”). For California Parties, the provisions of this section prevail over any conflicting provisions in other sections of this Privacy Policy. We share, and in the past 12 months have shared California Personal Information such as California Parties use of our Online Services with our marketing and advertising partners for cross-contextual advertising and analytics purposes as further described below. Otherwise, we do not sell, and in the past 12 months we have not sold, California Personal Information. Additionally, we do not sell or share, and in the past 12 months we have not sold or shared, California Personal Information of individuals we know to be under 16 years of age.

We have collected the following categories of California Personal Information within the last 12 months from the sources listed below:

• Identifiers, such as a real name, physical address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. This category of information is collected from you, your devices, and third parties, and public databases. This category of information is collected from you and your devices.
• Personal information described in subdivision (e) of Section 1798.80 (California customer records statute), such as a name, address, telephone number, credit card number, debit card number, or other payment information. This category of information is collected from you directly.
• Characteristics of protected classifications under California or federal law such as age, gender, race, ethnicity or national origin. This category of information is collected from you when you choose to provide it to us directly or indirectly through our service providers and business partners as part of our surveys and market research.
• Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This category of information is collected from you and your devices.
• Internet or other similar network activity, including, but not limited to, browsing history, search history, browser settings like language preference, and information regarding a California Party’s interaction with a website, application, or advertisement. This category of information is collected from you and your devices.
• Geolocation data, including physical location or movements. This category of information is collected from you and your devices.
• Inferences, such as a profile about a California Party’s preferences, characteristics, and behavior, drawn from the information we collect and insights we receive from third parties such as our marketing and advertising partners and data analytics providers.
• Sensitive personal information, such as account login information allowing access to an account, precise geolocation data, race, and ethnicity, in each case as further described above in the relevant categories. If you win a promotional prize or sweepstakes, we may also collect your W9 information, including FEIN or SSN for legal compliance. Please note we do not collect sensitive personal information for the purpose of inferring characteristics about you.

For each of the above categories, we use the California Personal Information for a variety of business purposes such as:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Helping to ensure security and integrity to the extent the use of a Consumer's personal information is reasonably necessary and proportionate for these purposes;
• Debugging to identify and repair errors in our systems;
• Short-term, transient use including contextual non-personalized advertising shown as part of a California Party’s current interaction with us; 
• Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
• Conducting internal research to develop and demonstrate technology;
• Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide; and
• Other business purposes described in the “How We Use and Share Information” Section.

We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.

Within the last 12 months, we have disclosed California Personal Information for our business purposes. To learn more about the categories of third parties with whom we share such information, please see the “When and to Whom We Disclose Data” Section.

If you are a California Party, you have certain rights related to your California Personal Information, including:

• The right to know what California Personal Information we have collected about you, including the categories of personal information, the categories of California Personal Information, the categories of sources from which the California Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing California Personal Information, the categories of third parties to whom we disclose California Personal Information, and the specific pieces of California Personal Information we have collected about you.
• The right to correct inaccurate California Personal Information that we have collected about you.
• The right to delete California Personal Information that we have collected from you, subject to certain exceptions required by applicable law. 
• The right to opt out of the sale or the sharing of California Personal Information.
• We do not sell California Personal Information, but if you wish to opt out of the sharing of California Personal Information in the future, please contact us via one of the methods outlined under the “Contact Us” section below.
• The right to limit the use or disclosure of your sensitive personal information. We do not use or disclose sensitive personal information for purposes that, under applicable law, require us to support the right to limit the use or disclosure of sensitive personal information.
• The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by applicable law, including the right not to be retaliated against for the exercise of your rights.

You may request to exercise any of your rights under this Privacy Policy by contacting us via the methods noted under “Contact Us” below.

2.13 Other States

If you are a resident of a state in which state-level privacy law is enacted (e.g., Colorado, Connecticut, Utah or Virginia), additional rights described in this Section may apply to you as applicable law comes into effect. You may have the following rights, in each case to the extent set out in applicable law:

The right to confirm whether we process personal information about you and request access to such personal information (including, if applicable, in a portable and readily usable format). The right to correct inaccuracies in certain personal information we may hold about you; and The right to request that we delete personal information collected from or about you.

You may request to exercise these rights by contacting us via the methods noted under “Contact Us” below. If your rights request is denied, you may lodge an appeal with us. The response to your rights request will inform you of any appeal rights you may have and how you may exercise them. 

We do not sell personal information, but if you wish to opt out of the sharing of personal information in the future, please contact us via one of the methods outlined under the “Contact Us” section below.

As required under applicable law, we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your first name, last name, email address, the amount of your last transaction and the date of your last transaction to verify your identity in response to exercising requests of the above type. We may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights described above, we will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.

Under applicable law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. To the extent permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent. If you are an authorized agent submitting a request on behalf of a consumer, please make a request as outlined below under “Contact Us”.

2.14 Contact Us

If you have questions or concerns regarding, or a request to make pursuant to this Privacy Policy, please contact us by mail at Artoh Inc, 169 Madison Ave #2151, New York, NY 10016, or by email at support@artoh.com.

2.15 Changes to This Privacy Policy

Please read this Privacy Policy carefully. Artoh will occasionally update this Privacy Policy. When we do, we will also revise the “last updated” date at the top of this page. Any changes to our Privacy Policy will become effective upon our posting of the revised Privacy Policy on the Website. Use of the Website following such changes constitutes your acceptance of the revised Privacy Policy then in effect. To the extent Artoh makes any material change to this Privacy Policy, it will provide you with notice via email, on the Website, or through the Services prior to the change becoming effective.

‍