Privacy Policy

DATA

INTRODUCTION

The protection of your confidential information is our top priority. We strive to create a secure, transparent, and trustworthy environment for all those who are interested in art and investing. To achieve this, we have implemented internal policies and processes that comply with international data protection standards, including provisions similar to those outlined in the General Data Protection Regulation (GDPR), as well as other recognized privacy regulations.

This Privacy Policy explains in detail what personal data we collect or receive from you, how we process it, and what security measures are in place to protect it. We are committed to full transparency in the handling of personal data and aim to maintain the trust of our users, clients, and partners worldwide.

Even if the collected data does not directly identify you, you can be assured that it will only be used following this Privacy Policy.

Please carefully review this Privacy Policy. By using our website or other platforms owned by us, you confirm your full agreement with the terms of this Policy. If you do not agree with these terms, please refrain from using our Platform.

Each of the following resources – ArtyTraders, any associated URLs, and our platforms (each individually or all together, depending on the context, hereinafter referred to as the “Platform”) – is provided by ArtyTraders, Inc, located at the address listed on the homepage and Company Details, as well as its affiliated companies (collectively referred to as “ArtyTraders,” “we,” “us,” or “our”).

This Privacy Policy outlines our principles and procedures for collecting, using, and disclosing personal information received through the Platform from visitors and registered users (hereinafter referred to as the “Privacy Policy”).

It forms an integral part of our Terms of Use, which govern your access to the Platform and/or use of the site, Platform content (as defined in the Terms of Use), and services provided through the Platform, including access, use, or download of any products, services, features, content, widgets, materials, or other tools offered by ArtyTraders (collectively referred to as the “Service”).

All terms with capital letters have the meanings defined in the Terms of Use unless it is stated otherwise in this document.


If you have any comments, suggestions, questions, or concerns regarding our Privacy Policy, please contact us via email at [email protected] .


The document is intended to inform you of the following:

  • What data do we collect,
  • How do we use the collected data,
  • How do we share the collected data,
  • How do we protect the collected data,
  • Other important privacy-related information.

This Privacy Policy applies whenever you access or use any domains or subdomains of the ArtyTraders Platform, as well as when you use our services. It does not apply to information you choose to share directly with other users of the Platform, including messages or transactions with individual users, as we do not control the collection or use of such information directly. Please exercise caution when sharing information with other users.

Please note that your relationship with ArtyTraders is also governed by our Terms of Use of the Platform, as well as any transaction documents you may enter into in relation to investments through our Platform. Additionally, ArtyTraders works with third parties for the use of cookies on our Platform, as described below. We recommend you review these sections carefully.

TYPES OF INFORMATION WE COLLECT

To provide our services and facilitate interactions between Platform users, we collect personal information directly from you, as well as information about you indirectly through electronic correspondence and third parties (collectively referred to as “Personal Data”).

INFORMATION PROVIDED BY THE USER DURING REGISTRATION

Depending on the service you wish to access, we may request some or all of the following types of Personal Data:

  • Name
  • Address
  • Email address
  • Phone number
  • Legal entity information
  • Financial information
  • Co-owner information
  • Date of birth
  • Citizenship
  • Payment information
  • Investment experience information
  • Information on compliance with investment requirements
  • Other legal and personal information based on the section and Services you interact with or plan to interact with.

Our registration process, forms, and surveys may request the provision of additional information, which you may choose to provide or leave unchanged at your discretion. Any information you provide will be subject to this Privacy Policy. If you contact us by email, we may retain a record of your contact information and correspondence, as well as use your email address and any information you provide in the message to respond to you.

VERIFICATION INFORMATION

If required for identity verification, you may provide us with a copy of your driver’s license, passport, or another government-issued ID. If necessary for confirming your address, you may provide us with a utility bill, lease agreement, or other documents verifying your residence. You may also provide us with other documents for verification, such as bank statements confirming the source of funds, to comply with the applicable laws, rules, and regulations governing our activities and interactions.
For identity confirmation, we may request various necessary information. All requested information is required solely for ensuring transparency, security, and legality in our interactions, aiming to prevent fraud, money laundering, and other illegal activities, thus ensuring mutual security.
If you wish to invest through a legal entity or corporation, you may provide us with documents related to the jurisdiction of incorporation, legal status, and ownership of the legal entity. By providing verification information and the aforementioned documents, you also provide us with data in these records, which may include characteristics of protected classifications, such as your gender, age, national origin, and citizenship.

BANKING INFORMATION

To invest in various financial instruments offered through our Platform, you must provide us and our financial partners or third parties with certain information about your account and other payment methods, such as the details required to process payments via ACH, bank transfer, electronic checks, cryptocurrency, foreign currency, or any other payment method accepted by us at that time. Our registration and purchasing process provides additional details regarding the types of required payment information.

For users who link or verify bank accounts through our Platform and/or one of these third parties, you also consent to the transfer, storage, and processing of your personal and financial data by that third party in accordance with their own privacy policies.

AUTOMATICALLY OR PASSIVELY COLLECTED INFORMATION

In addition to the information you provide directly, we automatically or passively collect information when you access or use our Service, including but not limited to your IP address, device identifiers, click paths, usage of our Platform, and other electronic data. We may also track page views (visit counters) and other general statistical information to monitor how our Platform is used, as well as for security and monitoring purposes. To determine if your computer is supported by our system, we may collect additional technical information about your operating system and browser, as well as any software that our Platform may require to function with your computer or any third-party software on your computer.

COOKIES

In addition, we may collect, store, and use “cookies.” A cookie is a small amount of data, often including an anonymous unique identifier, that is sent to your browser from the Platform’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a personalized user experience, make it easier to use the Platform on subsequent visits, and help you navigate between pages efficiently. We may use cookies on our Platform to recognize you when you return. You can configure your browser to refuse cookies. However, cookies must be enabled in your web browser if you wish to use certain personalized features of our Service. We recommend that you carefully review this section to learn more, as well as to familiarize yourself with the options to opt-out of some cookies that are not essential to participate in our Platform.

  • Session Cookies: These cookies are automatically deleted whenever you leave the Platform. We use these cookies to provide users with access to various sections of the Platform and perform actions that require user authorization.
  • Persistent Cookies: Persistent cookies typically have an expiration date in the future and remain in your browser until they expire or you manually disable them. These cookies are used to track user patterns on the Platform and to understand your activities on our Platform.
  • Third-Party Cookies: We use third-party cookies to track users. We may use these cookies to determine whether a user is logged in or subscribed to web notifications.

We use various types of cookies to enhance the user experience, analyze behavior, personalize content, and for marketing purposes. Below are the main categories of cookies and examples of third parties that may place them:

Type of cookies Who places cookies?
Strictly Necessary Our Platform
Functional and Productive Our Platform
Analytical Our Platform third third-party analytics services.
Advertising Third-party advertising platforms and partners.
Social Media Third-party social platforms (e.g. Meta, TikTok).

These cookies help us ensure the proper functioning of the Platform, analyze its usage, improve functionality, display personalized advertising, and facilitate integration with social media platforms.

HOW TO MANAGE COOKIES

There are several ways to control the use of cookies on our Platform and on your devices:

  • Cookies on the Platform. By using the Platform, you agree to the use of the types of cookies described in this Privacy Policy.
  • Advertising identifiers. You can adjust your device settings to manage advertising identifiers:
  • On Apple devices: enable the “Limit Ad Tracking” option in your device settings.
  • On Android devices: enable the “Disable Ad Personalization” option in your device settings.
  • Opting out of third-party cookies. Many third-party services and social networks that place cookies allow you to opt-out of their use on their own websites. You can find details in their privacy policies.

Please note: Deleting or rejecting all cookies may impact the functionality of the Platform and the services it provides.

For more information about cookies, you can visit www.allaboutcookies.org (if you are in the US) or www.youronlinechoices.eu (if you are in Europe).

PIXELS

We may also use so-called “pixel tags” – small graphic images (also known as “web beacons” or “one-pixel GIF files”) to determine which sections of the Platform users visit, assess the reach and effectiveness of our advertising, and measure the performance of search queries made on the Platform. Pixels also allow us to send emails in a readable format and track whether these emails have been opened, to ensure that they are of interest to the recipients.

Some web browsers send “Do Not Track” signals to websites. Currently, our Platform is not designed to respond to these signals or similar browser mechanisms.

We may send emails using “click-tracking URLs” leading to content on the Platform. When you click such a URL, you first pass through our server before reaching the target page. We track these transitions to determine interest in specific topics and measure the effectiveness of our communication. If you do not want your clicks to be tracked, do not click on text or graphic links in emails.

USAGE INFORMATION

We collect certain information about you when you visit and interact with the Platform, as well as when you use our Services. We collect information about you for the purpose of carrying out the core and related activities of our company. We record when you use the Service, which pages you visit, which links you click, which files you upload or download (including their type, size, and name), and what search queries you perform. If you invite others to use the Platform, we retain information about your referral.

We also collect information related to the transactions in which you engage through our Platform, including participation in primary offerings or secondary market transactions. Transaction data may include, without limitation, the terms of purchase or sale, price, volume, type of securities, offers, acceptances, transfer restrictions, and any derivative information related to them.

INFORMATION FROM THIRD PARTIES

We collect information about you from third-party sources with whom we have business relationships. We use a third-party identity verification service to confirm your identity, prevent fraud, money laundering, and other illegal activities, as well as comply with legal requirements. We also receive information about you and your activity from companies such as Google, LinkedIn, Meta, and other advertising, social media, and marketing research partners, who provide data on interest in our Services. Additionally, we may receive information from marketing partners through referral programs, affiliate agreements, retirement account providers, and joint marketing initiatives.

By using our Service, you agree to this Privacy Policy and consent to the use of tracking technologies, such as cookies and pixels, as well as the collection of user and third-party information in accordance with this Policy.

HOW WE USE THE COLLECTED INFORMATION

 We may use the information we collect about you for the following commercial purposes:

  • to administer, manage, support, and ensure the proper functioning of your interaction with our Platform and provision of the Service;
  • to support our operational processes, including fulfilling legal and regulatory requirements, such as identity verification, checks, anti-money laundering measures, and “Know Your Customer” procedures;
  • to determine your investment suitability;
  • to enable subscription to investment offers, facilitate and receive payments, and conduct transactions;
  • to comply with record-keeping and transfer-agent obligations in accordance with applicable laws, regulations, and rules;
  • to communicate with you regarding the Service, as well as for targeted advertising, marketing, and sales to enhance your user experience and increase engagement. These communications may include notifications about new services, offers, features, content, and promotional events related to the Service;
  • to provide information about the current Service, including onboarding materials, availability and terms of new investment opportunities, reminders, and details about your previous investments;
  • to verify your identity, accounts, and activities; monitor suspicious or fraudulent activity; identify violations related to the use of the Service;
  • to eliminate errors, detect and fix technical malfunctions of the Platform and/or Service;
  • in anonymized and aggregated form – for research and analytical purposes, including analyzing usage patterns of the Service to identify potential issues or areas for improvement;
  • to contact you or, if necessary, your authorized representatives via mail, phone, SMS, email, fax, and other communication channels as part of your interaction with our Platform, including providing information and updates about the Service. 

OTHER PURPOSES FOR USING PERSONAL DATA

  • Enhancing website security and preventing unauthorized access.
  • Complying with anti-money laundering (AML) and counter-terrorism financing (CFT) requirements.
  • Ensuring compliance with international human rights standards and non-discrimination, including equal access to digital services.
  • Maintaining adherence to ethical data processing standards.
  • Participating in international initiatives for ensuring digital resilience and protecting user rights online.

Additionally, in the event of a merger, acquisition, financial audit, reorganization, bankruptcy, establishment of a trust, or any other related legal entity, receivership, or sale of assets of our Platform, your information may be transferred, conveyed, or sold while maintaining confidentiality as part of the relevant transaction, as permitted by law or contract.

If your interaction with our Platform ends, we will continue to handle your personal information as necessary, in accordance with this Policy.

HOW WE SHARE THE INFORMATION WE COLLECT

We do not buy, sell, or transfer personally identifiable information to third parties for their direct marketing or similar purposes without your knowledge and consent. We also do not offer financial incentives, special service conditions, or any price or service distinctions in exchange for your information.

The manner in which our partners, service providers, and other third parties use the information we share is governed by their own policies, and we are not responsible for their actions or privacy practices. Typically, you can easily identify when one of our partners is involved in providing a service. However, some partners may operate anonymously, and in such cases, we only share the information necessary to perform a specific service. This may include sharing your personal data with databases used for identity verification, including in connection with anti-money laundering and “Know Your Customer” procedures.

We share your information in the following cases:

  • Partner Relationships. We engage other companies to perform certain functions on our behalf, including: brokers-dealers who organize and promote investments; service providers involved in the administration of the Platform and marketing activities; identity verification providers; analytics companies; marketing partners, including pension account providers; payment systems; and other necessary entities. We may share your information with them for the duration of your membership on the Platform.
  • Business Transformations. Your data may be transferred to a third party as a result of a merger, asset sale, reorganization, or similar transaction, or to government authorities if we reasonably believe the transfer is required by law or to respond to legal requests. We will also share data with third parties if, in good faith, we believe it is necessary to prevent fraud, ensure security, protect our rights, comply with governmental or judicial authorities’ requirements. If this occurs and affects your personal data, we will, to the extent legally possible, notify you and request your consent for the changes.
  • Service Providers. For service operations, we share data with providers, including financial institutions, brokers-dealers, accountants, auditors, lawyers, payment providers, IT consultants, advisors, and affiliates. Information is shared only to the extent necessary to fulfill our obligations to you and regulatory authorities, and only for the duration of your use of the Platform or Service.
  • Affiliates. We regularly share data with companies closely connected to us-our “affiliates.” An affiliate is an organization that controls us, is controlled by us, or is under common control with us. Affiliates may use the rights provided in this Policy, and we are responsible for ensuring they comply with privacy provisions.
  • Regulators. We may share your information with regulatory authorities in the jurisdictions where we interact, if we believe it is necessary or appropriate to comply with laws, regulations, or law enforcement requests.
  • Third-party Websites. The Platform may contain links to third-party websites. These sites are outside our control, and we are not responsible for their content, accuracy, or privacy policies. When you visit a third-party website, please be aware that any data you provide is governed by their terms of use and privacy policy.

HOW DO WE PROTECT YOUR DATA

SECURITY SYSTEMS AND PROCESSES

Arty Traders has developed a comprehensive written Information Security Policy that covers all company employees and regularly conducts corporate training on protecting the personal information of clients and investors, as well as the proper disposal of irrelevant data. We have implemented security systems aimed at preventing unauthorized access to and disclosure of personal data. We take all reasonable measures to protect this data, including:

  • Access to the password-protected part of the Platform is granted only after authentication using unique identifiers (e.g., username and password).
  • We apply industry-standard encryption for data storage.
  • Arty Traders employees are required to acknowledge familiarization with the Privacy Policy and its compliance regarding the protection of personal data.
  • Partners we collaborate with, when necessary, are obliged to adhere to similar data protection measures.
  • Access to databases with personal data is granted only to Arty Traders employees, contractors, and government authorities (if applicable) – solely on a “need-to-know” basis.
  • We use automated network traffic monitoring tools to detect and track unauthorized access attempts or data changes.

These measures are aimed at preventing unauthorized access to the information you provide. However, please be aware that no security system can guarantee absolute protection. Due to the nature of internet communications and the development of technology, we cannot guarantee that your information will always be fully protected from loss, improper use, or alteration by third parties who gain access despite our measures.

PAYMENT DATA SECURITY

Arty Traders does not collect or store bank card data directly. All payment data is processed by third-party financial providers, and their processing is governed by the privacy policies and terms of use of these providers.

ADDITIONAL IMPORTANT PRIVACY INFORMATION

SECURITY INCIDENT RESPONSE

In the event of a suspected data breach or unauthorized access to personal information on the Arty Traders Platform, we will conduct an internal investigation and attempt to notify all affected users in writing (including via email) within 72 (seventy-two) hours from the discovery of the incident. The notification will include at least a description of the incident, the type(s) of affected information, Arty Traders’ response measures, and recommendations for users on how to further protect their data.

DATA RETENTION

We store collected information for the duration of your use of Arty Traders’ Services, including the ownership of investments, or as long as necessary to achieve the purposes of collection, provide services, resolve disputes, comply with legal obligations, protect rights, and enforce agreements. We may also retain anonymized and aggregated data, backups, and archived versions of information in accordance with regulatory requirements or our internal data retention policies.

LOSS OR THEFT OF INFORMATION

If you become aware that any information you have provided has been lost, stolen, or used without your permission, please contact us immediately.

CHILDREN AND MINORS

In accordance with children’s online privacy protection laws, Arty Traders does not provide access to the Platform for individuals under 18 years of age. To use our Services, you must be at least 18 years old. We can not always verify the age of every user; however, if a parent or guardian becomes aware that a child has provided us with personal information without consent, they can contact us, and we will remove such data within a reasonable timeframe.

YOUR RIGHTS

Regarding your data, you have the following rights:

  • Right of Access – you have the right to request information about your personal data that we store. We will provide you with a copy of this data within a reasonable time.
  • Right to Rectification – you have the right to request the correction of inaccurate or incomplete personal data.
  • Right to Erasure – you can request the deletion of your personal data if it is no longer necessary for the purposes for which it was collected.
  • Right to Restriction of Processing – you can request the restriction of processing your data if you dispute its accuracy or wish for the data not to be processed in certain circumstances.
  • Right to Data Portability – you have the right to request the transfer of your personal data in another format for use in another service or system.
  • Right to Object to Processing – you can object to the processing of your personal data when the processing is based on legitimate interests.
  • Right to Withdraw Consent – if you have given consent to the processing of your data, you can withdraw it at any time.

To exercise these rights, please contact us through the provided contact details.

Please note that your rights take precedence over our commercial interests. However, if your request contradicts security or legal requirements, its processing will be considered separately.

OPTING OUT OF COMMUNICATIONS

If you wish to stop receiving marketing or promotional messages or opt out of the use of your information for the purposes described in this policy, you can use the “Unsubscribe” link (or similar) in the email or contact us directly. However, even if you opt out of marketing emails, you may still receive service-related notifications, including updates to the terms of use or privacy policy. Please also note that some messages required by law or regulatory authorities cannot be opted out of.

CHANGING OR DELETING INFORMATION

You can view, update, correct, or delete your personal data held by Arty Traders by contacting us or, in some cases, through your user account. When you contact us, we will take reasonable steps to delete your data. However:

  • Full deletion may not be possible due to regulatory requirements (e.g., tax reporting), the presence of investments on the Platform, and backup data.
  • Deleting data may result in losing access to certain features of the Platform and Service.
  • Some data may be retained in storage systems by our data retention policy even after account deletion.

RIGHT TO OPT-OUT OF DATA SHARING WITH THIRD PARTIES

You have the right to request the opt-out of sharing your Personal Data with third-party organizations not affiliated with Arty Traders by submitting a “Do Not Sell My Data” request. However, please note that the opt-out may not be possible in cases where:

  • (i) the transfer is part of joint marketing agreements with service providers (if applicable, notification is provided),
  • (ii) necessary for account servicing and transaction processing,
  • (iii) to prevent fraud, comply with legislation, or mandatory reporting.

CHANGES TO THE PRIVACY POLICY

Each time you visit the Platform, your visit is governed by the version of the Privacy Policy in effect at that time. We recommend checking the date of the latest update to stay informed of any changes. Arty Traders reserves the right to amend the Privacy Policy. In certain cases, we may request your explicit consent to the updated Policy as a condition for continued use of the Platform and/or Services.

ADDITIONAL RESOURCES

If you want to learn more about personal data protection and internet security, it is recommended to consult official resources in your jurisdiction, as well as international guidelines related to online safety.

GEOGRAPHIC SCOPE

The Arty Traders Platform operates with users worldwide. Your Personal Data may be processed in countries where we or our partners have offices or service providers. By using the Platform, you consent to:
(i) the transfer of your information outside your country of residence, including to countries with different data protection standards than those in your jurisdiction;
(ii) the use of your Personal Data in accordance with this Privacy Policy.
In certain cases, law enforcement or regulatory authorities may gain access to your data in accordance with local laws.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA (EEA)

If you reside in the EEA, Arty Traders processes your information only on the legal basis established by the EU General Data Protection Regulation (GDPR). We process your data when:

  • It is necessary to provide our Services, fulfill contractual obligations, offer support, and ensure security.
  • we have a legitimate interest that does not override your rights and freedoms.
  • You have given consent to the processing of specific data.
  • It is required to comply with legal obligations.

You may withdraw your consent or object to data processing by contacting us. You also have the right to complain to a data protection authority in your country.

CONTACTS

If you have any questions regarding the Privacy Policy, the Platform, or your interactions with us, please contact us via email: [email protected].