Privacy Policy

Effective Date: April 20, 2026

This Privacy Policy (herein referred to as "Policy") explains how ArtLink LLC (herein referred to as the "Company," "we," "us," or "our") processes Personal Data that we collect from you (herein referred to as the "Subscriber") as a Controller.

1. DEFINITIONS

"Controller" means the natural or legal person, public authority, agency, or other body, which alone or jointly with others, determines the purposes and means of processing Personal Data.

"Personal Data" means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Service(s)" means Software for selling artwork and professional tools, connecting artists and their artwork to customers.

"Subscriber" means the natural or legal person who has subscribed to the Service(s) by agreeing to the Terms.

"Terms" means the binding contract between the Company and Subscriber that governs the Subscriber's access and use of the Service(s).

"Subscriber Content" means any artwork images, videos, audio, text, descriptions, biographical information, or other materials that the Subscriber uploads or provides to the Service.

"Automated Processing" means the use of automated systems, including artificial intelligence and machine learning technologies, to analyze, categorize, or extract information from data.

2. DATA COLLECTION

The Subscriber directly provides the Company with most of the data we collect. The Company collects Personal Data and Subscriber Content from the following sources:

Account Information: Name, email address, password, profile information, biographical details, and professional history.

Artwork and Content: Images of artwork, artwork titles, descriptions, dimensions, pricing, and related metadata that the Subscriber uploads to the platform.

Platform Interactions: How the Subscriber uses the Service, including browsing behavior, feature usage, and preferences.

Communications: Messages, support requests, and other communications with the Company.

Waitlist and Marketing: Email addresses and preferences for those who join our waitlist or subscribe to marketing communications.

Generated Data: Information derived from Automated Processing of Subscriber Content, including categorizations, tags, themes, color analysis, style descriptions, and other metadata generated by our systems.

Third-Party Account Connections: When the Subscriber chooses to connect a third-party service to their Pulse account (for example, an accounting platform such as QuickBooks Online), we collect and store the OAuth access and refresh tokens, account identifiers, and limited company metadata required to operate the connection. OAuth credentials are encrypted at rest.

3. PROCESSING OF PERSONAL DATA

Purposes of Processing. The Company processes the Subscriber's Personal Data and Subscriber Content for the following purposes:

• Marketing and promoting artists and their artwork
• Analyzing and categorizing artwork and artist information
• Enabling discovery, search, and recommendation features on the platform
• Assisting in selling artwork through the platform to clients
• Improving and developing the Service
• Communicating with Subscribers about their accounts and the Service
• Complying with legal obligations

Automated Processing and Artificial Intelligence. The Company uses Automated Processing, including artificial intelligence (AI) and machine learning technologies, to:

• Analyze artwork images to extract visual characteristics such as color palette, composition, style, and technique
• Generate descriptive metadata, categorizations, and tags for artwork
• Identify themes, moods, and artistic influences
• Enable personalized discovery and recommendations
• Improve marketplace functionality and user experience

The Subscriber acknowledges and consents to this Automated Processing by using the Service and uploading Subscriber Content.

Legal Basis for Processing. The Company will generally collect and process Personal Data from Subscribers only where:

• It is necessary to perform a contract with the Subscriber (e.g., providing the Service)
• The processing is in the Company's legitimate interests and not overridden by the Subscriber's data protection interests or fundamental rights and freedoms
• The Company has the Subscriber's consent
• The Company has a legal obligation to collect or process the Personal Data

Withdrawal of Consent. If the Company processes Personal Data with the Subscriber's consent, the Subscriber may withdraw their consent at any time by contacting us at the details provided in Section 10.

4. SHARING OF PERSONAL DATA

Service Providers. The Subscriber acknowledges that the Company may share the Subscriber's Personal Data and Subscriber Content with its group companies and third-party service providers to offer the Subscriber the Company's Service(s), process data on our behalf, and/or send information or updates about the Service(s).

AI and Technology Providers. To perform Automated Processing described in Section 3, the Company may share Subscriber Content (including artwork images) with third-party artificial intelligence and technology service providers. These providers:

• Process data solely on our behalf and according to our instructions
• Are bound by contractual obligations to protect data confidentiality and security
• Are prohibited from using Subscriber Content for their own purposes, including training AI models
• Include providers of image analysis, natural language processing, and machine learning services

Accounting and Financial Integrations. When a Subscriber chooses to connect a third-party accounting service such as QuickBooks Online, the Company shares transaction-level data with that service to enable bookkeeping. This may include sale amounts, payout amounts, artwork titles, buyer names and email addresses (used to identify or create customer records in the connected service), and timestamps. Data is shared only for connections the Subscriber has explicitly authorized via OAuth, and only with the specific accounting company the Subscriber has selected. Subscribers may disconnect at any time from their Pulse financials page; on disconnection the Company revokes its access tokens with the third-party service and removes the stored encrypted credentials, and no further data is shared. Data already posted to the connected service before disconnection remains in that service and is governed by that service's own terms and privacy policy.

Fraud Prevention. When the Company processes the Subscriber's order, it may send the Subscriber's Personal Data to and use the resulting information from credit reference agencies to prevent fraudulent purchases.

Marketing and Platform Operation. The Company shares Personal Data for marketing and promoting artists and their artwork, for analyzing and categorizing information, and for assisting in selling artwork through the platform to clients.

Legal Requirements. The Company may disclose Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

Business Transfers. In the event of a merger, acquisition, or sale of all or a portion of the Company's assets, Personal Data may be transferred as part of that transaction.

5. AUTOMATED DECISION-MAKING

Use of Automated Systems. The Company uses automated systems to analyze and categorize Subscriber Content. These systems generate insights, tags, and metadata that are used to improve platform functionality and enable features such as search and discovery.

No Solely Automated Decisions with Legal Effect. The Company does not make decisions based solely on Automated Processing that produce legal effects or similarly significantly affect Subscribers. Automated analysis is used to enhance the Service, not to make consequential decisions about Subscribers without human involvement.

Accuracy of Automated Analysis. The Company does not guarantee the accuracy, completeness, or appropriateness of any information generated through Automated Processing. Such information is provided for informational and functional purposes only.

No Training of External AI Models. Subscriber Content will NOT be used to train general-purpose artificial intelligence or machine learning models operated by third parties. Any processing by third-party providers is limited to providing services to the Company as described in this Policy.

6. RETENTION OF PERSONAL DATA

The Company retains Personal Data and Subscriber Content when an ongoing legitimate business need requires retention of such data (for example, to provide the Service, comply with legal obligations, or resolve disputes).

Retention of Generated Data. Metadata, categorizations, and other information generated through Automated Processing of Subscriber Content is retained for as long as the associated Subscriber account or content remains on the platform, and for a reasonable period thereafter for backup and compliance purposes.

In the absence of a need to retain Personal Data, the Company will either delete or aggregate it. If immediate deletion is not possible, the Company will securely store the Personal Data and isolate it from any further processing until it is deleted.

7. SECURITY OF PERSONAL DATA

The Company uses appropriate technical and organizational measures to protect the Personal Data and Subscriber Content it collects and processes. These measures are designed to provide a level of security appropriate to the risk of processing.

Third-Party Security. When sharing data with third-party service providers, including AI providers, the Company requires such providers to maintain appropriate security measures and to process data in accordance with applicable data protection laws.

If you are a Subscriber and have any concerns about the security of your Personal Data, please contact us immediately at the details provided in Section 10.

8. YOUR RIGHTS

Depending on your location and applicable law, you may have the following rights regarding your Personal Data:

• Right to Access. You may request a copy of the Personal Data we hold about you, including any data generated through Automated Processing.
• Right to Rectification. You may request that we correct any inaccurate Personal Data.
• Right to Erasure. You may request that we delete your Personal Data, subject to certain exceptions (such as legal retention requirements).
• Right to Restrict Processing. You may request that we limit how we use your Personal Data.
• Right to Object. You may object to the processing of your Personal Data for certain purposes, including Automated Processing.
• Right to Data Portability. You may request a copy of your Personal Data in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent. Where processing is based on consent, you may withdraw consent at any time.

To exercise any of these rights, please contact us at the details provided in Section 10. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

9. MODIFICATION

The Company keeps this Policy under regular review and may update this webpage at any time. This Policy may be amended at any time, and the Subscriber shall be notified if there are material changes to this Policy. Material changes include, but are not limited to, changes to how we process Subscriber Content using Automated Processing or changes to our data sharing practices.

We encourage Subscribers to periodically review this Policy for the latest information on our privacy practices. Continued use of the Service after changes to this Policy constitutes acceptance of those changes.

10. CONTACT DETAILS

If you have any concerns about this Policy, wish to exercise your rights under Section 8, or have questions about how your data is processed, please contact us at: