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ArticHall

ArticHall

PRIVACY POLICY AND PERSONAL DATA PROTECTION

pursuant to EU Regulation 2016/679 (GDPR) and Italian Legislative Decree 196/2003 as amended

Version 1.2 | Effective Date: 31.10.26

1. Data Controller

The data controller is ArticHall S.r.l.s. (full corporate name: ArticHall Società a Responsabilità Limitata Semplificata), a simple limited liability company incorporated under Italian law, with registered office at Via San Pasquale 19, 80121 Naples (NA), Italy, tax code and VAT number 11114191213, registered with the Business Register of Naples under REA number NA-1155990, with a fully paid-up share capital of EUR 3,000.00, represented by its sole director and legal representative Roberto Ciampa Carrelli Palombi (hereinafter, "ArticHall", "we", "us" or "our").

For any matter relating to the processing of personal data, please contact us at:

2. Scope of Application

This Privacy Policy describes how ArticHall collects, uses, stores and shares the personal data of users (hereinafter, "Users") and content authors (hereinafter, "Authors") who access and use the ArticHall platform, which is available through the ArticHall website at www.artichall.com (hereinafter, the "Website") and, once released, through the ArticHall mobile application (hereinafter, the "App") (together, the "Platform"). This Privacy Policy also applies to visitors of the Website and to persons who subscribe to the waitlist on the Website in order to be notified of the App's release (hereinafter, "Waitlist Subscribers"), whether or not they register an account.

This Privacy Policy forms an integral part of ArticHall's Terms and Conditions of Use and must be read together with them and with the Cookie Policy.

ArticHall acts as data controller in respect of personal data processed through the Platform. For personal data processed by third-party payment providers in the context of their services (Stripe for payments made through the Website; Apple and Google for in-app purchases made through the App Store and Google Play), each provider acts as an independent data controller under its own privacy policy.

3. Minors

The Platform is accessible to users aged 14 and above. Under Italian law (Article 2-quinquies of Legislative Decree 196/2003 as amended by Legislative Decree 101/2018), the processing of personal data of minors aged 14 and above is lawful on the basis of the minor's own consent.

Minors aged between 14 and 17 who register on the Platform declare that they are at least 14 years old and, where required by the law of their country of residence, that they act with the consent or authorisation of their parent or legal guardian. ArticHall is unable to independently verify the age of Users who are not Authors. Responsibility for false statements regarding age rests exclusively with the user and, if a minor, with the relevant parent or guardian.

If ArticHall becomes aware that a user under the age of 14 has registered on the Platform, it will proceed to delete the account and the related personal data without undue delay.

The waitlist on the Website is likewise reserved for persons aged 14 and above: by subscribing, the person declares that they meet this requirement. If ArticHall becomes aware that a Waitlist Subscriber is under the age of 14, it will delete the related e-mail address without undue delay.

This section describes the categories of personal data we collect. For each category we indicate separately the purposes for which the data is processed and the legal basis under the GDPR that allows the processing. Where the same data is used for more than one purpose, the legal basis of each purpose is indicated with the same letter: (a), (b), (c).

4.1 Data provided directly by the User

When registering and using the Platform, we collect the following personal data:

  • Registration data : e-mail address, password (stored in hashed form), username, country and preferred language, preferred topics of interest.

Purposes: (a) creating and managing the User's account, authenticating access and providing the Platform's services, including the topic feeds chosen by the User; (b) sending service communications, such as subscription notifications, updates and changes to the Terms; (c) sending promotional communications and marketing, where introduced in the future.

Legal bases: (a) Performance of a contract (Art. 6(1)(b) GDPR); (b) Consent (Art. 6(1)(a) GDPR), requested separately.

  • Voluntary profile data : profile photo, biographical description, links to social profiles (if added by the user).

Purpose: displaying the User's profile and enabling interaction with other Users and Authors, according to the settings chosen by the User.

Legal basis: Performance of a contract (Art. 6(1)(b) GDPR)

  • Communication data : any messages sent to customer support or to ArticHall through official channels.

Purposes: (a) handling requests and providing technical support and customer assistance; (b) keeping a record of the communications where necessary to establish, exercise or defend legal claims.

Legal bases: (a) Performance of a contract (Art. 6(1)(b) GDPR); (b) Legitimate interest of ArticHall (Art. 6(1)(f) GDPR).

4.2 Authors' data

In addition to the data referred to in section 4.1, Authors provide:

  • Identity verification data: copy of identity document (front and back) and video selfie, processed by Stripe's identity verification service acting in its capacity as independent data controller.

Purposes: (a) verifying the Author's identity and granting verified status; (b) preventing impersonation, fraud and abuse; (c) complying with identification and due diligence obligations applicable to digital platforms and to payment services, where applicable.

Legal bases: (a) Performance of a contract (Art. 6(1)(b) GDPR); (b) Legitimate interest of ArticHall (Art. 6(1)(f) GDPR); (c) Legal obligation (Art. 6(1)(c) GDPR).

  • Tax and payment data : bank account details for receipt of earnings, relevant tax information.

Purposes: (a) paying earnings to Authors; (b) complying with fiscal and accounting obligations and with reporting obligations to tax authorities, such as those under DAC7 in the EU.

Legal bases: (a) Performance of a contract (Art. 6(1)(b) GDPR); (b) Legal obligation (Art. 6(1)(c) GDPR).

  • Author account data : selected Author type (Media, Journalist, Sector Expert, Content Creator), subscribed Author plan, published content, created compilations, performance statistics.

Purposes: (a) managing the Author account, publishing content, offering subscription plans and compilations and providing performance statistics; (b) content moderation and enforcement of the Terms and Conditions.

Legal bases: (a) Performance of a contract (Art. 6(1)(b) GDPR); (b) Legitimate interest of ArticHall (Art. 6(1)(f) GDPR).

  • Additional data for 'Media' Authors : company name, VAT number, country of registration.

Purposes: (a) verifying the status of the outlet and linking editorial content to the organisation responsible for it; (b) complying with fiscal and accounting obligations.

Legal bases: (a) Performance of a contract (Art. 6(1)(b) GDPR); (b) Legal obligation (Art. 6(1)(c) GDPR).

4.3 Automatically collected data

During use of the Platform, we automatically collect:

  • Technical data : IP address, device type and operating system, browser type and version, App version, unique device identifiers, mobile network operator, time zone.

Purposes: (a) delivering the Website and the App to the User's device and ensuring their correct operation; (b) IT security and prevention of fraud, abuse and unlawful activities.

Legal bases: (a) Performance of a contract (Art. 6(1)(b) GDPR); (b) Legitimate interest of ArticHall (Art. 6(1)(f) GDPR).

  • Usage data : content viewed, saved, purchased or downloaded; authors followed; searches performed; frequency and duration of sessions; interactions with content (e.g. bookmarks, offline in-app, purchases).

Purposes: (a) providing the features requested by the User, such as saved content and collections, followed authors, and Offline In-App mode and Download to Device where available; (b) aggregate and anonymous analysis of Platform usage for service improvement; (c) personalised recommendations, including the collection of traffic data in the Personalised Navigation mode, as described in section 5.

Legal bases: (a) Performance of a contract (Art. 6(1)(b) GDPR); (b) Legitimate interest of ArticHall (Art. 6(1)(f) GDPR); (c) Consent (Art. 6(1)(a) GDPR).

  • Transaction data : amount and date of purchases, payment method (reference token provided by the payment provider only — no raw card data is ever stored by ArticHall), Wallet balance, transaction history. On the Website, payments are processed by Stripe. In the App, purchases are made exclusively through the in-app payment systems of Apple (App Store) and Google (Google Play), from which ArticHall receives only the information needed to confirm the transaction.

Purposes: (a) managing purchases, subscriptions and the Wallet; (b) complying with fiscal and accounting obligations, including the retention of billing data; (c) preventing payment fraud and abuse.

Legal bases: (a) Performance of a contract (Art. 6(1)(b) GDPR); (b) Legal obligation (Art. 6(1)(c) GDPR); (c) Legitimate interest of ArticHall (Art. 6(1)(f) GDPR).

4.4 Geolocation data

Subject to the User's explicit consent, we collect approximate geolocation data (based on IP address or device regional settings) in order to personalise content recommendations within the Personalised Navigation mode. The collection of geolocation data is subject to a specific consent request presented in the App via push notification or, on the Website, through a dedicated prompt. The User may withdraw this consent at any time from their account settings.

Purpose: personalising content recommendations within the Personalised Navigation mode.

Legal basis: Consent (Art. 6(1)(a) GDPR), requested through a specific prompt and withdrawable at any time.

4.5 Waitlist data

Through the Website, any interested person may subscribe to the waitlist, independently of whether they register an account on the Platform. Subscribing to the waitlist does not create an account and is not required in order to use the Website. For this purpose we collect:

  • E-mail address: the only data required to subscribe to the waitlist.

Purpose: sending an e-mail to notify the Waitlist Subscriber when the App becomes available for download. The e-mail address is not used for any other purpose without a separate consent.

Legal basis: Consent (Art. 6(1)(a) GDPR), withdrawable at any time through the unsubscribe link included in each e-mail or by writing to privacy@artichall.com .

  • Subscription record: date and time of the subscription and evidence of the consent given.

Purpose: demonstrating that consent was given, as required by Art. 7(1) GDPR.

Legal basis: Legal obligation (Art. 6(1)(c) GDPR)

4.6 Purposes applying to several categories of data

In addition to the purposes indicated above for each category of data, ArticHall may process the data referred to in this section for the following purposes:

  • Prevention of fraud, abuse and unlawful activities on the Platform, IT security and integrity of systems, content moderation and enforcement of the Terms and Conditions.

Legal basis: Legitimate interest of ArticHall (Art. 6(1)(f) GDPR)

  • Retention of data from suspended or deleted accounts, where in violation of the Terms, to the extent necessary to protect ArticHall's rights.

Legal basis: Legitimate interest of ArticHall (Art. 6(1)(f) GDPR)

  • Management of legal proceedings and defence in litigation.

Legal basis: Legitimate interest of ArticHall (Art. 6(1)(f) GDPR)

  • Response to requests from competent authorities and disclosure of data to tax authorities in the cases required by applicable law, e.g. DAC7 in the EU.

Legal basis: Legal obligation (Art. 6(1)(c) GDPR)

Where processing is based on consent, the consent may be withdrawn at any time from the account settings or, as regards the waitlist, through the unsubscribe link included in each e-mail or by writing to privacy@artichall.com , without affecting the lawfulness of processing carried out prior to withdrawal.

4.7 Data not collected

ArticHall does not collect biometric data, health data, genetic data or facial recognition data. The Author identity verification process is entirely managed by Stripe, acting as an independent data controller for such data.

5. Algorithmic Recommendation System

ArticHall uses an internally developed algorithmic recommendation system to personalise each User's feed in the "For You" section and in the recommendation bars of the Discovery section. The system processes User usage data (content viewed, authors followed, searches performed, selected topics of interest) and, subject to consent, traffic data and approximate geolocation data.

In accordance with EU Regulation 2022/2065 (Digital Services Act), ArticHall ensures full transparency regarding the operation of the recommendation system:

  • For each piece of recommended content in the "For You" section, the User may access an information point indicating the types of data used to generate that specific recommendation.
  • The User may select Private Navigation mode, which deactivates personalised recommendations and limits data collection to the minimum necessary for the operation of the service.

The algorithmic recommendation system does not employ profiling mechanisms that produce legally significant or similarly significant effects on the User within the meaning of Art. 22 GDPR.

6. Sharing of Personal Data

ArticHall does not sell personal data of Users and Waitlist Subscribers, nor does it share such data for purposes of third-party behavioural advertising. Personal data may be shared with the following categories of recipients:

6.1 Service providers (data processors)

ArticHall engages third-party providers who process personal data on ArticHall's behalf as data processors under Art. 28 GDPR, including:

  • Stripe, Inc.: payment services for payments and Wallet top-ups made through the Website, Author identity verification and payouts. Stripe also acts as an independent data controller for identity verification and payment processing activities. For more information: https://stripe.com/privacy
  • Cloudflare, Inc.: hosting, data storage, content delivery network (CDN) and computing services, as well as security services such as protection from attacks and abuse, for which the technical data of the requests made to the Website and the App transits through Cloudflare's infrastructure.
  • Analytics service providers : anonymous and aggregate analysis of Platform usage.
  • Push notification providers : delivery of service notifications to Users.
  • E-mail service providers : management of the waitlist and delivery of e-mails to Users and Waitlist Subscribers.

6.2 Payment platforms of the app stores

For purchases made within the App, payments are processed exclusively through the in-app payment systems offered by Apple (App Store) and Google (Google Play). Stripe is not used to process payments made within the App. Apple and Google do not act on ArticHall's behalf: each of them acts as an independent data controller under its own privacy policy (Apple: https://www.apple.com/legal/privacy/ ; Google: https://policies.google.com/privacy ). ArticHall does not receive or store the User's card or payment account data and receives from Apple or Google only the information needed to confirm the transaction and to provide the purchased content or credit the Wallet.

6.3 Authors

When a User purchases content or subscribes to an Author's profile, ArticHall transmits to the Author the information strictly necessary to manage the relationship (e.g. subscription notification, aggregate content performance statistics). ArticHall does not transmit Users' personal details (name, e-mail) to Authors without the User's explicit consent.

6.4 Public authorities

ArticHall may disclose personal data to competent authorities (judicial, law enforcement, tax or regulatory) where required by law, by an order of authority, or where necessary for the protection of ArticHall's rights, those of Users or of third parties.

6.5 Corporate transactions

In the event of a merger, acquisition, transfer of a business unit or other corporate transaction, personal data may be transferred to the acquirer, who will be required to comply with this Privacy Policy or provide adequate equivalent protection guarantees.

7. International Data Transfers

Personal data collected by ArticHall may be transferred to and processed in countries outside the European Economic Area (EEA) by the service providers and payment platforms referred to in section 6. Such transfers occur exclusively on the basis of the following safeguards:

  • Adequacy decision by the European Commission for countries deemed adequate under Art. 45 GDPR.
  • Standard Contractual Clauses (SCCs) adopted by the European Commission under Art. 46(2)(c) GDPR.
  • Other appropriate safeguards under Chapter V of the GDPR.

For information on international data transfers and the safeguards adopted, please contact us at privacy@artichall.com .

8. Data Retention

Personal data is retained for the time strictly necessary to achieve the purposes for which it was collected, in accordance with the following criteria:

  • Active account data: for the entire duration of the contractual relationship with the User or Author.
  • Transaction and tax data: for a period of 10 years from the date of the transaction, in compliance with applicable tax and accounting obligations.
  • Identity verification data (Authors): in accordance with the timeframes indicated by Stripe in its own privacy policy.
  • Usage and browsing data (Personalised Navigation): for a period not exceeding 24 months from the last interaction, unless consent is withdrawn earlier.
  • Geolocation data: for a period not exceeding 12 months from the last collection, unless consent is withdrawn earlier.
  • Waitlist data: until the e-mail notifying the release of the App has been sent or, if earlier, until the person unsubscribes or withdraws consent, and in any event for no longer than 24 months from subscription.
  • Data from accounts suspended or deleted for breach of the Terms: for the time necessary to protect ArticHall's rights and prevent further violations, and in any event not exceeding 5 years.
  • Data related to legal proceedings: for the duration of the proceedings and until expiry of the relevant limitation periods.

Upon expiry of the retention period, data will be deleted or permanently anonymised.

9. Rights of Data Subjects

In accordance with Arts. 15–22 GDPR, Users, Authors and Waitlist Subscribers have the right to:

  • Access (Art. 15 GDPR): obtain confirmation as to whether personal data concerning them is being processed and, if so, to access such data and related information.
  • Rectification (Art. 16 GDPR): obtain the correction of inaccurate or incomplete personal data.
  • Erasure ('right to be forgotten', Art. 17 GDPR): obtain the deletion of their personal data in the cases provided for by law.
  • Restriction of processing (Art. 18 GDPR): obtain restriction of processing in the cases provided for by law.
  • Data portability (Art. 20 GDPR): receive their personal data in a structured, commonly used and machine-readable format, and transmit it to another data controller.
  • Objection (Art. 21 GDPR): object to the processing of their personal data based on the Controller's legitimate interest, including profiling.
  • Withdrawal of consent (Art. 7(3) GDPR): withdraw consent at any time, without affecting the lawfulness of processing based on consent carried out prior to withdrawal.
  • Lodge a complaint with the supervisory authority: file a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali — www.garanteprivacy.it ), without prejudice to any other administrative or judicial remedy.

To exercise their rights, data subjects may send a written request to privacy@artichall.com , specifying their identity and the nature of their request. ArticHall will respond within 30 days of receipt of the request, subject to a justified extension of up to a further 60 days for complex requests. Waitlist Subscribers may also unsubscribe at any time through the link included in each e-mail.

ArticHall reserves the right to verify the identity of the requester before acting on any request.

10. Data Security

ArticHall implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, accidental loss or destruction, in accordance with Art. 32 GDPR. Such measures include, among others:

  • Encryption of user passwords.
  • Transmission of data via secure protocols (TLS/HTTPS).
  • Access to personal data restricted to authorised personnel bound by confidentiality obligations.
  • Security incident management procedures and personal data breach notification to competent authorities and data subjects, in the cases provided for by Arts. 33–34 GDPR.

Payment data is not stored by ArticHall: processing is entirely delegated to the payment providers, namely Stripe for payments made through the Website and Apple or Google for in-app purchases made through the App. Stripe is PCI-DSS certified. ArticHall receives from them only reference tokens and transaction confirmations, with no access to full card data.

No security system is impenetrable. ArticHall cannot guarantee the absolute security of data transmitted over the Internet.

11. Download to Device — Notice

The Download to Device feature allows the User to physically save a file (e.g. PDF, audio, video) on their device. Once a file has been downloaded to the User's device, ArticHall is no longer able to control its subsequent use. The downloaded file is intended exclusively for the User's personal use, in accordance with the Terms and Conditions of Use and applicable copyright law. Any unauthorised distribution, reproduction or commercial use of the downloaded file is prohibited and constitutes an infringement of the Author's rights.

12. Cookies and Tracking Technologies

ArticHall uses cookies and similar tracking technologies for the operation of the Platform. For detailed information on the types of cookies used, their purposes and how to manage preferences, please refer to ArticHall's Cookie Policy, available on the Website and, once the App is released, within the App in the profile settings. Where required by law, cookies and similar technologies other than strictly necessary ones are used only with the prior consent of the person concerned, which can be given or withdrawn through the cookie preferences panel.

13. Changes to this Privacy Policy

ArticHall reserves the right to update this Privacy Policy at any time. Material changes will be communicated to Users and Authors with at least 15 days' notice, via in-app notification, a notice on the Website or e-mail to the registered address. The date of the last update is indicated at the top of the document. Continued use of the Platform following the entry into force of any changes constitutes acceptance of those changes.

14. Applicable Law and Supervisory Authority

This Privacy Policy is drawn up in accordance with EU Regulation 2016/679 (GDPR), Italian Legislative Decree 196/2003 as amended by Legislative Decree 101/2018, and European legislation on digital services (EU Regulation 2022/2065 — Digital Services Act).

The competent supervisory authority is the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), Piazza Venezia 11, 00187 Rome, Italy. Website: www.garanteprivacy.it

15. Contact

For any questions regarding this Privacy Policy or the processing of personal data:

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