Privacy Policy

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"):

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.)
• 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)
• To enforce our Terms of Service and any other agreements between you and Artoh
• 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 may also share business-related documents—such as KYB documentation, business registration records, or proof of transaction—with our authorized partners and payment processors as needed for compliance, transaction execution, and regulatory obligations.
• 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).
• 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.
• 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.
• 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.

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.

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.

2.5 Cookies and Tracking Technologies

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.

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.

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.

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. 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

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.

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.

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. 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.

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
• 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
• The right to limit the use or disclosure of your sensitive personal information
• The right not to receive discriminatory treatment by the business for the exercise of privacy 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
• The right to correct inaccuracies in certain personal information we may hold about you
• 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. 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.

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:

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.

2.16 GDPR Notice for EU/EEA Users

If you are located in the European Union (EU), the European Economic Area (EEA), or the United Kingdom (UK), the following additional terms apply to how we process your Personal Information under the General Data Protection Regulation ("GDPR") and similar laws: