1. THIS DOCUMENT
1.1 Who we are: Artoh Inc., a company incorporated in the USA registered at 1209 Orange Street, Wilmington, Delaware and other companies in the Artoh group collect and use certain Personal Data.
1.2 Please read this Privacy Policy: We take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your Personal Data) in connection with your use of the Services and other online platforms. It also explains your rights in relation to your Personal Data and how to contact us or a relevant regulator in the event you have a complaint.
1.3 We are the controller: We are the controller of Personal Data obtained via the Services and other online platforms (such as social media), meaning we are the organisation legally responsible for ensuring compliance with data protection laws, including (but not limited to) the EU GDPR and any other national, implementing or supplementing data protection legislation. This includes deciding how and for what purposes Personal Data is used.
1.4 Third party links: Throughout our Services we may link to other websites owned and operated by certain trusted third parties, including to help us perform identity verification or make additional products and services available to you. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
1.5 Changes to this Privacy Policy: We may change this privacy policy from time to time—when we make significant changes, we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.
Definitions: We use the following definitions in this Privacy Policy:
“Artoh Website”: means the Artoh website available at artoh.com and any other website made available by Artoh or its affiliates from time to time.
“Artoh”, we or us means Artoh Building Sp. Z.o.o. and other companies of the Artoh group.
“EEA” means the European Economic Area.
“EU GDPR” means the European Union’s General Data Protection Regulation (Regulation (EU) 2016/679) and any laws and regulations implementing or created pursuant to the EU GDPR.
“Personal Data” means any data that relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Artoh (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Artoh or any other person in respect of an individual.
“Privacy Policy” means this privacy policy.
“Services” means the Artoh Website, our online platform (including APIs) made available through the website of one of our partners and any other online service or platform that Artoh provides users from time to time.
“User(s)” or “You” means the users of the Services.
2. THE TYPES OF PERSONAL DATA WE COLLECT
The Personal Data we collect about you depends on the particular activities carried out. Many of the services offered by Artoh require us to obtain Personal Data about you in order to perform the Services we provide. Users may be unable to access the Services if such Personal Data are not provided. In relation to each of the services described at Section 2.1 above, we will collect and process the following Personal Data about you:
- Information that you provide to us: This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (but is not limited to):some text
- basic Personal Data (such as first name; family name; job role; email address; phone number; postal address; city; postcode; country; hashed password; national identification number, identity documents, proof of address documentation, payment information (such as banking information, wallet address, payment card details));
- any other information that you choose to share via the Services that may be considered Personal Data;
- Information that we collect or generate about you. This includes (but is not limited to): technical information about your use of the Services e.g. 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.
For more information on the cookies and other tracking technologies used by Artoh please see Section 9 of this Privacy Policy and our Cookie Notice below.
- Information we obtain from other sources. 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 identity information. We may supplement the information we collect about you through the Services with such information from third parties in order to verify your identity or enhance our ability to serve you. If we combine such data with information we collect through the Services, such information is subject to this Privacy Policy unless we have disclosed otherwise.
3. HOW WE USE YOUR INFORMATION
3.1 Under data protection law, we can only use your Personal Data if we have a proper reason, e.g.:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party.
3.2 A legitimate interest is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
3.3 The table below explains what we use your Personal Data for and why.
| Purpose |
Our reasons and lawful basis relied on under the EU GDPR |
Relevant categories of Personal Data |
| To facilitate, operate, and provide our Services as set out in their relevant terms and conditions and to enforce our Terms of Service and any other agreements between you and Artoh. |
To perform our contract with you (or to take steps at your request before entering into a contract). |
Your name, address, date of birth, and contact information, including email address and telephone number, your account details (username) and your payment details.
Your identity documentation and proof of address documentation.
Your national identification number.
Any other information that you choose to share via the Services which may be considered Personal Data.
|
| To provide our users with assistance and support. |
To perform our contract with you. |
Your account details (username) and contact information, including email address and telephone number. |
| To authenticate the identity of our users, and to allow them to access and use our Services. |
Compliance with a legal obligation and to perform our contract with you. |
Your name, address, date of birth, and contact information, including email address and telephone number, your account details (username) and your payment details.
Your identity documentation and proof of address documentation.
Your national identification number.
Any other information that you choose to share via the Services which may be considered Personal Data.
|
| To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error, or any illegal or prohibited activity. |
Compliance with a legal obligation and legitimate interests. |
Your name, address, date of birth, and contact information, including email address and telephone number, your account details (username) and your payment details.
Your identity documentation and proof of address documentation.
Your national identification number.
Any other information that you choose to share via the Services which may be considered Personal Data.
|
| To comply with any other applicable laws and regulations. |
Compliance with a legal obligation. |
Your name, address, date of birth, and contact information, including email address and telephone number, your account details (username) and your payment details.
Your identity documentation and proof of address documentation.
Your national identification number.
Any other information that you choose to share via the Services which may be considered Personal Data.
|
4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
The table below sets out who we share Personal Data with.
| Who we share with |
Use by recipient |
Relevant categories of personal information transferred (or likely to be transferred to) recipient |
| Other Artoh Group companies |
To assist us in performing our Services. |
Your name, address, date of birth, and contact information, including email address and telephone number, your account details (username) and your payment details.
Your identity documentation and proof of address documentation.
Your national identification number.
Any other information that you choose to share via the Services which may be considered Personal Data.
|
| Third party service providers |
To help deliver our Services to you, such as payment service providers, digital storage providers, and identity verification providers.
To help us run our business including (but not limited to) 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. 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.
|
Your name, address, date of birth, and contact information, including email address and telephone number, your account details (username) and your payment details.
Your identity documentation and proof of address documentation.
Your national identification number.
Any other information that you choose to share via the Services which may be considered Personal Data.
|
| Artoh Partners |
If you access Services through the website of one of Artoh’s partners, then we may share your Personal Information with that partner in order to provide the Services. |
Your name, address, date of birth, and contact information, including email address and telephone number, your account details (username) and your payment details.
Your identity documentation and proof of address documentation.
Your national identification number.
Any other information that you choose to share via the Services which may be considered Personal Data.
|
| Our regulators, law enforcement agencies or other relevant governmental agencies |
Compliance with a legal obligation and legitimate interests. |
Your name, address, date of birth, and contact information, including email address and telephone number, your account details (username) and your payment details.
Your identity documentation and proof of address documentation.
Your national identification number.
Any other information that you choose to share via the Services which may be considered Personal Data.
|
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 Data 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.
5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
5.1 We may transfer your Personal Data: Artoh has customers and operations spread around the world. As a result, we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.
5.2 Protections when transferring internationally: Where we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside the EEA, for example, this may be done in one of the following ways:
- the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. We rely on adequacy decisions for transfers to the following countries: United States;
- there are appropriate safeguards in place for you (including, but not limited to, the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data);
- the recipient may have adhered to binding corporate rules (only for intragroup transfers);
- in other circumstances the law may permit us to otherwise transfer your Personal Data outside of the EEA.
You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA by contacting us as described below.
6. HOW WE SAFEGUARD YOUR INFORMATION
We maintain administrative, technical, and physical safeguards that are designed to protect the privacy and security of your Personal Data. 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 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 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 Services. In addition, where you have chosen a password for access to certain parts of our Services, you are responsible for keeping this password confidential.
We will take steps to ensure that the Personal Data is accessed only by employees of Artoh that have a need to do so for the purposes described in this Privacy Policy.
7. HOW LONG WE KEEP YOUR PERSONAL DATA
7.1 How long we will hold your Personal Data for will vary and will be determined by the following cumulative criteria:
- the purpose for which we are using it – Artoh will need to keep your Personal Data for as long as is necessary for that purpose;
- as needed to deal with potential or actual legal claims, complaints, litigation or regulatory proceedings; and
- legal obligations – laws or regulation may set a minimum period for which Artoh has to keep your Personal Data.
8. YOUR RIGHTS
8.1 What are your rights: In all the above cases in which we collect, use or store your Personal Data, you may have the following rights which you can exercise free of charge. These rights include:
- the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
- the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
- in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Artoh;
- the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
- the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are legally entitled to retain it;
- the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
- the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
8.2 You can exercise your rights by contacting us using the details listed below. Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction. For a list of EEA data protection supervisory authorities and their contact details see here.
9 Cookies
9.1 What are Cookies: A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our Services. When you visit a page on the Services it may generate any of the following types of cookies:
- Essential Cookies: These cookies are required to save your session and to carry out other activities that are strictly necessary for the operation of the Services. They enable us to provide you with services you have specifically asked for and are essential for you to move around the Services and use its features, such as accessing secure areas of the Services. Without these cookies, services you have asked for cannot be provided to you. We also use security cookies to ensure the security of the Services. Because these cookies are strictly necessary to deliver the Services to you, you cannot refuse them. You can block or delete them by changing your browser settings, as described below in ‘Managing your cookies’. However, please note that if you do this you may not be able to use the full functionality of the Services.
- Functionality Cookies: If you consent, we use functional cookies to allow the Services to remember choices you make on the Services (such as your user name, language or the region you are in) to provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for. These cookies cannot track your browsing activity on other websites. They also do not gather any information about you that could be used for advertising or remembering where you’ve been on the Internet besides our websites.
- Performance Cookies: If you consent, these cookies collect information about your visit and use of the Services, for instance, which pages you visit most often, and if you get error messages from such web pages. These cookies do not collect information that identifies you. All information these cookies collect is only used to improve how the Services works. We also use these cookies to understand how our media campaigns work. This information is used to evaluate and improve the content of the Services and our campaigns and ultimately to improve user experience.
- Analytics and Customisation Cookies: If you consent, we use these cookies, to help us understand how users access and use our services. The data collected typically includes information such as your IP address, your internet service provider, your web browser, the time spent on web pages, the links clicked and the advertisements viewed on those pages. We use this information to improve the Services and your experience, to see which areas and features of our services are popular, and for which visitors, and to count visits.
9.2 Other tracking technologies: We use other similar technologies to cookies on our Services such 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 behaviour and to improve your experience when using 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.
Where we refer to ‘cookies’ in the reminder of this section, we are referring cookies or any other tracking technologies we use.
9.3 Consent to use tracking technologies and changing settings
We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.
You can withdraw any consent to the use of cookies or manage any other cookie preferences. If you do this, please be aware that you may lose some of the functionality of our Services.
Most browsers allow you to see what cookies you have on your device and to clear them all or individually. To find out how to do this, go to allaboutcookies.org, which contains comprehensive information on how to do this on a variety of browsers. It may be necessary to refresh the page for the updated settings to take effect.
For further information on cookies generally, including how to control and manage them, visit https://allaboutcookies.org/.
9.4 Our use of cookies
Artoh uses cookies to enhance your browsing experience, provide services, and analyze site traffic. These cookies include:
- Necessary Cookies: Essential for website functionality.
- Preference Cookies: Remember your preferences and settings.
- Analytics Cookies: Collect information on how users interact with our site.
- Advertising Cookies: Used to deliver targeted advertisements.
You can manage your cookie preferences through our cookie consent tool, available when visiting our website, or by adjusting your browser settings.
9.5 Third-party access to the cookies
We use third-party service providers, such as Google Analytics, who may set cookies on your device when you use our website. These providers help us analyze website traffic and provide tailored advertising.
10. CONTACT US
If you have questions or concerns regarding, or a request to make pursuant to this Privacy Policy, please contact us by please contact us using the following contact details.
Address: 169 Madison Ave #2151, New York, NY 10016
Email: support@artoh.com
11. CONCERNS AND COMPLAINTS
11.1 Contact us: For further information regarding the processing of your Personal Data by Artoh, this Privacy Policy, questions relating to consent, or in order to exercise the rights mentioned above, please contact us using the details above.
11.2 Lodging complaints: We strive to resolve any issues you may have regarding your Personal Data. If you believe that your data protection rights have been infringed, you have the right to lodge a complaint with a supervisory authority. Individuals in the EEA should contact their respective national data protection authorities for assistance. For more information, please consult your national data protection authority's website.
