Privacy Policy
1. Data Controller
SM Marketing Management LLC, operating ArtTern in the United Arab Emirates, is the controller of personal data processed through arttern.com, except where another party is identified as an independent controller.
Privacy contact: support@arttern.com.
2. Personal Data We Collect
| Category | Examples | Source |
|---|---|---|
| Account and identity | Name, username, email, phone, login records, age/eligibility confirmation, identity or authority evidence where verification is needed | You; authorised representative |
| Professional profile | Artist name, biography, nationality if provided, residence country/city, languages, education, career history, awards, exhibitions, gallery representation, services, price range, availability | You; authorised representative; public sources where lawful |
| Portfolio and media | Profile photo, artwork images, videos, audio, logo, artist statement, captions, documents, CV, links, social profiles | You; authorised representative |
| Contact and communications | Public contact details selected for display, support enquiries, messages, survey responses, feedback, complaints, and consent records | You |
| Transaction data | Package, price, currency, tax, payment status, invoice and transaction identifiers; payment-card details are generally handled by payment processors rather than stored by us | You; payment provider |
| Technical and usage data | IP address, device, browser, operating system, approximate location, pages, clicks, referral source, session and cookie identifiers, errors and security logs | Automatically from your device |
| Marketing and preference data | Communication preferences, campaign engagement, interests, profile category, target market, and opt-in/opt-out records | You; service interactions |
| Moderation and compliance | Reports, rights complaints, evidence of permission or provenance, fraud/risk signals, policy decisions, and related correspondence | You; users; third parties; lawful authorities |
Please do not submit sensitive personal data unless specifically requested and legally appropriate. Do not provide another person’s personal data unless you have authority and have given them any required privacy information.
3. Why We Process Personal Data
| Purpose | Data typically used | Basis or reason |
|---|---|---|
| Create and provide accounts, profiles, listings, package features, support, and requested AI-assisted tools | Account, profile, content, transaction, technical data | To perform the requested service or contract; consent where required |
| Publish and promote artist profiles and User Content through ArtTern channels | Public profile, portfolio, professional data | Requested listing service and the content licence in the Terms |
| Process orders, invoices, payments, renewals, and fraud prevention | Account, transaction, technical, risk data | Contract, legal obligations, protection of rights |
| Communicate service notices and respond to enquiries or complaints | Contact, account, communications | Service administration, contract, legal obligations |
| Personalise discovery, improve features, measure performance, and conduct analytics | Profile, usage, cookie, technical data | Consent where required; service improvement and compatible business purposes |
| Send newsletters, opportunities, offers, and marketing | Contact, preferences, engagement | Your separate consent where required; you may opt out at any time |
| Moderate content, verify rights, secure the Website, enforce terms, and establish or defend legal claims | All relevant categories | Legal obligations, protection of rights, security, fraud prevention |
| Develop or train AI systems using identifiable profile content | Only the categories stated in the AI consent presented to you | Separate, specific, recorded consent; see the AI & Data Use Policy |
| Create anonymised or aggregated statistics and research | Data altered so individuals are not identifiable | Analytics, planning, and platform development |
4. Public Profiles and Search Visibility
Artist and creative profiles are public by design. Information marked for public display may be seen, copied, indexed, cached, translated, quoted, shared, or linked by search engines, social networks, media, users, and other third parties globally. You should publish only information you are comfortable making public.
Removing a profile from ArtTern does not instantly remove copies already cached or independently republished by third parties. We may assist with de-indexing under our control, but third-party removal depends on their systems and policies.
5. Marketing and Brand Development
We may use public profile content and licensed User Content to promote the listed artist, ArtTern, ArtTern opportunities, and the ArtTern community through our Website, social channels, newsletters, presentations, advertising, editorial features, and search previews, as described in the Terms.
Using your private contact details to send direct marketing is separate from publicly displaying and promoting your requested profile. Where consent is required, marketing messages will be sent only after a clear opt-in. You may unsubscribe through the message or email support@arttern.com. Service, security, payment, and legal notices are not marketing and may still be sent where necessary.
6. AI-Assisted Processing
We may use AI-assisted tools to help with translation, categorisation, search, recommendations, moderation, fraud detection, accessibility, image or text improvement, content drafting, and features you request. Human review may be used where appropriate.
We do not rely on acceptance of this Privacy Policy alone as consent to use identifiable personal data or copyrighted portfolio content to train a general AI model. Where we seek such use, we will present a separate consent describing the content, purpose, recipients or processors, cross-border processing where relevant, and withdrawal method. See our AI & Data Use Policy.
You may object to qualifying automated decisions and request human review where applicable law provides that right.
7. Who We Share Data With
We may share data only as reasonably necessary with:
- the public, for information you choose or request to publish;
- hosting, cloud, security, analytics, email, CRM, customer-support, media, translation, and AI service providers acting for us under appropriate instructions and protections;
- payment processors, banks, accountants, and tax providers to process transactions and records;
- professional advisers, insurers, auditors, and prospective business transaction parties subject to confidentiality and lawful safeguards;
- rights holders, complainants, or affected parties where reasonably necessary to investigate and resolve a complaint while protecting privacy;
- courts, regulators, law enforcement, and authorities where required or permitted by applicable law; and
- a successor or affiliate in a merger, acquisition, reorganisation, financing, or transfer of the relevant business, subject to applicable law.
We do not sell private personal data as a standalone product. Public profile content remains publicly accessible as part of the service.
8. International and Cross-Border Processing
ArtTern is based in the UAE, but service providers and public audiences may be located in other countries. Personal data may therefore be processed outside the UAE. Where required, we use appropriate contractual, organisational, security, consent, or other lawful safeguards. Public profile information may be accessed globally without geographic restriction.
9. Cookies and Similar Technologies
We use necessary technologies for login, security, preferences, checkout, and Website operation. Subject to your choices and applicable requirements, we may also use analytics, performance, personalisation, and advertising technologies. Details and controls are in our Cookie Policy.
10. Retention
We retain personal data only for as long as reasonably necessary for the stated purpose, including:
- while your account, listing, subscription, or relationship remains active;
- for payment, invoice, tax, accounting, audit, and legal retention periods;
- for security, fraud prevention, complaints, disputes, enforcement, and establishment or defence of claims;
- for backup cycles and reasonable technical deletion periods; and
- indefinitely where data has been properly anonymised and can no longer identify you.
Retention length varies by category and legal requirement. We may preserve a limited suppression record to honour an opt-out and evidence that consent was withdrawn.
11. Your Rights and Choices
Subject to applicable law and exceptions, you may request:
- information about processing and access to your personal data;
- correction or completion of inaccurate data;
- erasure, restriction, or cessation of processing;
- withdrawal of consent at any time, without affecting lawful processing before withdrawal;
- objection to direct marketing, including related profiling;
- data portability where legally applicable;
- information about qualifying automated processing and human review of qualifying automated decisions; and
- submission of a complaint to the competent UAE data-protection authority.
Send requests to support@arttern.com. State the email connected to your account and the right you wish to exercise. We may request reasonable identity or authority verification. We may retain or refuse deletion of information where legally permitted or required, including for legal claims, third-party rights, financial records, security, and compliance.
12. Security and Data Breaches
We use reasonable technical and organisational safeguards appropriate to the nature and risk of processing. No internet system is completely secure, and we cannot promise absolute security. If a breach requires notification, we will notify the competent authority and affected persons as required by applicable law.
13. Children
The Services are intended for adults aged 18 or older. We do not knowingly create accounts for children. If you believe a child has submitted personal data, contact us. Content depicting children must be submitted only with all necessary parent or guardian permissions and must comply with law and our policies.
14. Third-Party Sites
Links, embedded content, payment services, and social-media features may be governed by third-party privacy policies. ArtTern is not responsible for their independent processing.
15. Changes to This Policy
We may update this Policy to reflect legal, technical, or service changes. The latest version will be posted with its effective date. We will provide additional notice or request consent where required.
16. Contact
SM Marketing Management LLC — ArtTern PrivacyWebsite: https://arttern.com
Email: support@arttern.com
WhatsApp: +971 52 220 4964
United Arab Emirates