Last updated: 6 October 2022
1.1 References to "ARTA", "we" or "us" within this Policy are to Arta TechFin Corporation Limited, whose registered office is at the offices of Conyers Trust Company (Cayman) Limited, Cricket Square, Hutchins Drive, P.O. Box 2681, Grand Cayman, KY1-1111, Cayman Islands and “our” shall be construed accordingly.
1.2 This privacy and cookies policy ("Policy") explains how we collect, use and disclose your personal data when you use and access the website at https://www.artazine.com/ operated by us, any other websites operated by us or on our behalf (the "Website") and any mobile device application or desktop application developed by us or on our behalf (the "App") and the services that we provide through the Website and/or the App (collectively referred to as the "Services"), and the rights you may have under applicable privacy laws. If you do not agree with this Policy, you should not access the Website or App.
1.3. References to "you" means anyone accessing the Website or App and “your” shall be construed accordingly.
1.4. We are committed to protecting your privacy and ensuring the highest level of security for your personal data. This Policy explains the types of personal data we collect; how we use that information; who we share it with; how we protect that information; the kinds of tracking technologies we use; and your legal rights. We are committed to abiding by this Policy, as well as the requirements of applicable laws, in the operation of our business.
1.5. Please read the following carefully as it explains our views and practices regarding your personal data, and how it is handled. If you have any questions about how we use your personal data, please contact the Data Protection Officer at [email protected].
1.6. For the purposes of applicable data protection laws, the data user (controller) is Arta TechFin Corporation Limited with its principal place of business at Units 1-2, 9th Floor, K11 ATELIER King’s Road, 728 King’s Road, Quarry, Hong Kong.
1.7. In this Policy, "personal data" means information that (either on its own or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly. This may include your IP address, device type, cookie ID, location and the actions you take on the Website or the App, as well as technical information from the devices you use to access our Website or the App.
2.1. What personal data do we collect about you?
2.2. How and for what purpose will we use your personal data?
2.3. Whom do we share your personal data with?
We share your personal data with affiliated and unaffiliated service providers who support our business as well as advertising service providers. Where required or permitted by law, we will share your personal data with law enforcement agencies or regulators and with third parties pursuant to a legally binding court order. We may also share your personal data with other members, subsidiaries, or affiliates of our corporate group, to administer our and their services and products, including the Website or the App, and to conduct the activities described in this Policy. We may transfer your personal data to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of our business or where we acquire or form a joint venture with any other business. Your data may also be collected by third-party services such as social networks if you use the Website or the App via such third-party services.
2.4. Your rights
In certain circumstances, you have rights in relation to your personal data such as the right to access and the right to rectification.
2.5. How long do we keep hold of your personal data?
We retain your personal data for as long as it is necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. When we no longer need to use your personal data, we will remove it from our systems and records and / or take steps to promptly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).
2.6. How will we notify you of any changes to this Policy?
We will generally notify all users of any material changes to this policy by posting an alert on the Website or the App. We will also update the "Last Updated" date at the top of this Policy, which reflects the effective date of such policy. By accessing the Website or the App, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.
3. How We Collect Information
3.1. As detailed in section 5 (How and For What Purpose We Use Your Personal Data), and unless otherwise stated in this Policy, the personal data we collect from you or about you is required so that we can provide access to the Services to you, as detailed in our Terms and Conditions, and to improve and administer it.
3.2. The provision of certain data, e.g. cryptographic wallet address data, is mandatory for the purposes of your setting up a user account. If you do not provide the personal data required by us for account set up purposes, we will not be able to grant you access to parts of the Website or the App which are only accessible to account holders, or to receive "airdrops" of digital assets from time to time. However, you have control over certain kinds of personal data that you can choose to share or to withhold from us, and still be able to access the Website or the App, as detailed in this Policy.
3.3.1. technical information, including your IP address, time zone settings, language, cookie ID, your login information, browser type and version, device / browser identifier, location, operating system and platform, page response times and download errors;
3.3.2. data regarding the device or hardware you are using to access the Website or the App such as the model of your device, mobile device's unique identifier (UDID) or serial number, cellular information, WiFi network, identifier for vendor (IDFV), source of user (where you use your account on a third party platform to log in), device screen resolution, mobile carrier, software, platform, incident data, network type, device ID, operating system, a list of installed packages and running apps or processes, file names and types, Android ID, Google Advertising ID, MAC address and connection, other third-party apps you have on your device;
3.3.3. other types of data sent by your browser or device when you access the Website or the App, domain names, landing pages, pages viewed and the order of those pages, amount of time spent on particular pages, page interaction information (such as scrolling, clicks and mouseovers), referring pages, exit pages and URLs, number of clicks, and the date and time of this activity which are automatically tracked and recorded by our servers; and
3.3.4. information about your use of the Website or the App, including content you viewed or searched for.
Where you log-in from multiple devices, we will be able to use your profile data to identify your activity across devices.
3.4. You may choose to share certain data with us from third parties or through your use of the Website or the App. We set out further details on the data we receive from third parties below:
3.4.1. If you choose to register to use the Website or the App using your social network account details (e.g. Facebook, Twitter, Instagram, Google or Apple), you will provide us or allow your social network to provide us with your username and public profile (including your name, profile picture, gender, networks, user IDs, list of friends, followers and accounts you follow, date of birth, email address, and any other data you have set to public on your account).
3.5. When you contact us, correspond with us, or otherwise provide information to us (e.g., by emailing us) we will process your personal data (e.g., name, email address) so that we can respond to those messages. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
3.6. We may also receive either non-personal or public data from third parties in connection with market and demographic studies and/or data that we may use to supplement personal data provided directly by you. We may ask some third-party service providers to supplement the personal data that you provide to us for our own marketing and demographic studies, so that we can consistently improve our services and related advertising to better meet our users' needs and preferences. To enrich our understanding of individual users, we may tie this data to the data you provide to us.
4.2. What is a Cookie?
Cookies are alphanumeric identifiers that are stored on your browser by websites or apps that you visit. When you return to that website or app (or visit websites or apps that use the same cookies) these platforms recognise the Cookies and your browsing device. ARTA may transfer Cookies to your devices through your web browser for record-keeping purposes. Some cookies allow ARTA to make it easier for you to navigate our Website and App by providing certain features and functionality, while others allow ARTA to store and track information about your interests and preferences on the Website and App. We may combine the tracking data we obtain from Cookies together with personal data we may collect from you, for example if you register an account with you, in which case such tracking data shall be considered your personal data and shall be handled in accordance with this Policy.
4.3. Categories of Cookies
Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies can tell us, for example, whether you have visited the Website or the App before or whether you are a new user. They can also help to ensure that adverts you see online are more relevant to you and your interests.
There are different categories of Cookies, including:
(a). First-party Cookies
First party Cookies are small amounts of text which are served by us directly to your device.
(b). Third-party Cookies
Third-party Cookies, which are served by a third party on our behalf. We use third party Cookies for essential, functionality, analytic and performance, targeting or advertising and social media purposes.
Cookies can remain on your computer or mobile device for different periods of time. Some Cookies are "session cookies", meaning that they exist only while your browser is open and are deleted automatically once you close your browser. Other Cookies are "permanent cookies", meaning that they survive after your browser is closed. They can be used by the platform to recognise your device when you open your browser and browse the Internet again.
4.4. What types of Cookies do we use and how do we use them?
The types of Cookies and similar technologies used by us and our partners in connection with the Website or the App can be classified into one of five categories, namely "essential Cookies", "functionality Cookies", "analytics and performance Cookies", "targeting and advertising Cookies", and "social media Cookies". Cookies do a lot of different tasks to ensure you enjoy your use of the Website or the App, for example, they are used to remember your preferences on sites you visit, to help you navigate between pages more efficiently and to make sure the adverts you see on our Website or the App are relevant to you and your interests.
We have set out some further information about each category, and the purposes of the Cookies we and third parties set below.
4.4.1. Cookies that are necessary for essential purposes
4.4.2 Functionality Cookies
Functionality Cookies record information you have entered or choices you have made. These Cookies also enable you to optimise your use of the Website or the App after logging in so that we can personalise our content for you, greet you by name and remember your preferences.
4.4.3. Analytics and Performance Cookies
We use analytics/performance Cookies to understand what users are doing on our services, or which pages or sections are most popular. Information collected by performance cookies is used to improve how our Website or the App works and to enhance your experience on our Website or the App, for example by ensuring that users are finding what they are looking for easily. These Cookies do not collect information that individually identifies you and all information these Cookies collect is aggregated and anonymous. We also use third-party analytics tools to help us measure traffic and usage trends for the Website or the App (with your consent if required under applicable law).
4.4.4. Targeting or Advertising Cookies
Analytics: Our Website or the App may feature advertising. We allow third party companies, including advertising companies, to place Cookies in the Website or the App to track the performance of our advertisements (with your consent if required under applicable law). The information provided to third parties does not include personal data but it may be associated with personal data after they receive it.
4.4.5. Social Media Cookies
Third parties whose applications are connected to the Website or the App by you will set their own Cookies in order to customise their applications for you. Because of how Cookies work, we cannot access these Cookies, nor can the third parties access the data in Cookies used by us. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via Cookies.
4.5. Managing Cookies
You can manage Cookies by adjusting your browser settings, and, where required under applicable law, you always have the choice to change these settings by accepting, rejecting, or deleting Cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the services. All browser settings are slightly different, so to manage Cookies, you should refer to the relevant settings within your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each browser or device.
5. How and For What Purpose We Use Your Personal Data
5.1. We may use the data we collect about you in the following ways:
5.2. In accordance with, and to perform our contract with you, we may use your data to:
(a). allow you to use and access the Website or the App;
(b). notify you about changes to the Website or the App and send Website / App-related communications to you, including via push notifications;
(c). provide you with user support;
(d). enforce and notify you of changes to our terms of service, conditions and policies;
(e). administer the Website or the App including troubleshooting;
(f). administer sweepstakes, contests, or similar promotions where you enter into such programs; and
(g). communicate relevant information (such as updates and security alerts) and provide support to you.
5.3. In order to comply with our legal obligations, we may use your data to help us detect abuse, fraud and illegal activity in the Website or the App.
5.4. In accordance with our legitimate interests to provide an enjoyable and safe experience in accessing the Website or the App, we may use your personal data (name and email address) to:
(a). ensure your safety and security including reviewing messages and associated metadata for breach of our terms of service and other inappropriate content;
(b). ensure the Website or the App is presented in the most effective manner for you and your device;
(c). improve, promote, update and develop the Website or the App and your experience;
(d). better understand customer behaviour and improve our products and services through analytics;
(e). carry out data analysis and test the Website or the App to ensure its stability and security and data about installed packages and running apps or processes in order to ensure the security of the Website or the App network and prevent the spread of viruses and malware;
(f). provide you with personalised advertising and promotional emails (with your consent, if this is required by law), namely by sending messages regarding new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest relating to NFTs and crypto-related topics and we require your express consent (for use) and written consent (for transfer) before we do so (we will not transfer your personal data to other parties for gain); and
(g). to provide you with location-based services (where those services are available in your jurisdiction and you choose to share your precise location with us, and with your consent, if this is required by law).
6. How We Share Your Personal Data
6.1. We share your data with the following selected third parties:
6.2. Our corporate group
We may share your data with other members, subsidiaries, or affiliates of our corporate group, in order to administer our services and products, including the Website or the App, improving and optimizing the Website or the App, preventing illegal use and supporting users and conducting the activities described in this Policy.
6.3. Service providers
We provide data and content to service providers who support our business, including but not limited to infrastructure and IT service providers, cloud service and data storage providers, maintenance service providers, customer service providers, technical support providers and website analytics service providers who perform services on our behalf, assist us with the operation of the Website or the App, improve the Website or the App experience, conduct debugging, analytics and provide general support services ("Service Providers").
In the course of providing such services, these Service Providers may have access to your personal data. However, we will only provide our Service Providers with the information that is necessary for them to perform the services. All Service Providers are prohibited from retaining, using, or disclosing your personal data for any purpose other than providing us with their services. We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal data secure.
6.4. Advertising service providers
We may share and/or advertisers and third party measurement companies may collect some of your personal data, for example to show how many and which users of the Website or the App have viewed or clicked on an advertisement. We will also share and/or they may collect non-personal and personal data e.g. IDFA, IP address, time zone settings, browser type, language, operating system, network connection type and speed, and data regarding the device or hardware you are using to access the Website or the App such as the model and make of your device.
Please note, after clicking on a third party advertisement, you may no longer be on a site hosted by us. If you no longer want to receive tailored in-Website / App advertisements from third parties, you may adjust your privacy settings.
Our third-party analytics providers use this data to help us serve targeted adverts which may be of interest to you (if you have chosen to receive personalised advertising from us and/or our partners). For more data about how our analytics providers collect data from the Website or the App, please see section 4 (Cookies).
6.5. Social networks
If you interact with ARTA on social media platforms, ARTA can interact with you and send you messages via these platforms. Such interactions will be made in accordance with the social media platform’s rules but ARTA is not responsible for how the platform operators collect and handle your personal data. Further, ARTA is not responsible for what third parties post on their social media accounts.
If you choose to register to use the Website or the App using your social network or other account details (e.g. Facebook, Apple ID), you will provide us or allow your social network to provide us with your user name and public profile (including your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other data you have set to public on your account).
To manage the data we receive about you from a third-party application, such as Facebook, you will need to follow the instructions for the third-party application for updating your data and changing your privacy settings. You can also manage some aspects of data collection and use by visiting the "settings" page of your device and reviewing the permissions of each application or "app". Once we receive your data from a third-party application or your device, that data is stored and used by us in accordance with this Policy. You may access and update that data as described herein.
6.6. Law enforcement
We may share your data with law enforcement agencies, public authorities or other organizations if legally required or permitted to do so, or based on our legitimate business interests if such use is reasonably necessary to:
(a). comply with a legal obligation, process or request (we are not required to question or contest the validity of any legal process, search warrant, subpoena or other similar governmental request that it may receive);
(b). enforce our Terms and Conditions and other agreements, policies, and standards, including investigation of any potential violation thereof;
(c). detect, prevent or otherwise address security, fraud or technical issues; or
(d). protect and defend the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction).
These disclosures may be made with or without your consent, and with or without notice to you.
6.7. Sale or merger
We may transfer your personal data to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of our business or where we acquire or form a joint venture with any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business, or where will sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer provided that the receiving party agrees to treat your personal data in a manner consistent with this Policy.
7. Where We Store Your Personal Data
7.1. The personal data that we collect from you may be transferred to, stored at, and processed at a destination outside your jurisdiction of residence, depending on the country or territory from which you are accessing the Website or the App.
7.2. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy and provide a standard of protection that is comparable with the protection under the laws of your jurisdiction, regardless of where your personal data is transferred to or accessed from.
7.3. We will separately obtain your consent for international data transfer, if this is required under applicable law.
8. Your Rights
8.1. You may have various rights, under applicable laws, in connection with our processing of your personal data. Under Hong Kong law, you have the following rights:
8.8.1. Access. You may have the right to request a copy of the personal data we are processing about you, which we will provide back to you in electronic form. For your own privacy and security, we may require you to prove your identity before providing the requested information and we may charge a reasonable fee for supplying a copy of your personal data.
8.1.2. Rectification. You may have the right to have incomplete or inaccurate personal data that we process about you rectified.
8.1.3. Withdrawing consent. If you have consented to our processing of your personal data, you may have the right to withdraw your consent at any time, free of charge. If you would like to withdraw consent, including if you would like to opt out of receiving marketing correspondence from us, please contact us at [email protected] or for marketing follow the unsubscribe instructions located in the email (as relevant). Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your online account, relationship, activities, transactions and communications with us. Additionally, if you do request that we stop sharing your personal data with third parties for their direct marketing purposes, it is also prudent you opt out from or contact that third party directly.
8.2. Depending on your jurisdiction, you may have additional rights.
8.3. If you wish to exercise one or more of the above rights, please contact the Data Protection Officer with your request at [email protected], and include your name, email and postal address, as well as your specific request and any other information we may need in order to provide or otherwise process your request. We will respond to your request consistent with applicable law and subject to proper verification.
8.4. In addition:
8.4.1. You may opt out of receiving advertising and/or marketing communications by following the instructions in such communications.
8.4.2. If you have registered for an account you may access, review, and update certain personal data that you have provided to us by logging into your account and using available features and functionalities.
9. The Security of Your Personal Data
9.1. We have implemented technical and organisational security measures in an effort to safeguard personal data in our custody and control.
9.2. While we endeavour to always protect the Website, the App and our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.
9.3. We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personal data by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as us. Please check these policies before you submit any data to these websites.
9.4. To provide you with increased security, certain personal data stored in your online account is only accessible via your username and password. You are responsible for maintaining the confidentiality of your online account credentials, and we strongly recommend that you do not disclose your online account username or password to anyone. We will never ask you for your password in any unsolicited communication. Please notify us immediately (see section 13 (Contact Us)) of any unauthorised use of your online account credentials or any other suspected breach of security.
10. How Long Do We Keep Your Personal Data?
10.1. We will only retain your personal data for as long as it is necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and / or take steps to promptly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).
11. Data Relating to Children
11.1. We do not knowingly collect personal data from individuals under the age of 18 without first obtaining verifiable parental consent.
11.2. If you are under the age of 18 you should not provide information to us. If we become aware that an individual under 18 has provided personal data to us without verifiable parental consent, we will remove such personal data from our files.
11.3. If you believe that we have personal data of a child under age of 18 without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at [email protected] and we will delete such information.
12. Changes to this Policy
12.1. We reserve the right to change our Policy from time to time. We will generally notify all users of any material changes to this policy by posting an alert on the Website or the App and providing any other notice required by applicable law. We will also update the "Last Updated" date at the top of this policy, which reflects the effective date of such policy. By accessing the Website or the App, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it. If you do not agree to the updated policy, you must stop accessing or using the Website or the App.
13. Contact Us
13.1. Questions, comments and requests regarding this Policy should be addressed to the Editorial Team at [email protected]artazine.com.