Privacy Policy

LAST UPDATED: September 27, 2025

I. INTRODUCTION

ArtWorkout Limited (“we,” “us,” “our,” or “ArtWorkout”) is committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms of Use https://artworkout.app/terms/) applies when you use our ArtWorkout application (the “Service”), or interact with us in any way. This Privacy Policy describes how we treat your data that we gather when you access or use our Service or interact with us.

By using the Service, you agree to our collection, use, and disclosure of your data as described in this Privacy Policy.

This Privacy Policy can be updated from time to time and therefore we ask that you check back periodically for the latest version. If the Privacy Policy changes significantly from the time we collect your data, we will notify you. Your continued use of the Service following any changes constitutes your acceptance of such changes, regardless of whether you are notified of the changes.

If you have any questions about this Policy or want to send us any notice in relation to its application, you can contact us at privacy@artworkout.app.
For the purposes of this Privacy Policy, ArtWorkout Limited acts as the Data Controller of your personal data. In some cases, we may act as a Data Processor on behalf of partners; in those cases, the partner remains the Data Controller.

II. INFORMATION WE MAY COLLECT

By default, we do not collect your personal data, which we understand as any information relating to an identified or identifiable natural person.
We may collect or have in the past collected the following personal data:
  • Your age;
  • Your gender;
  • Your email address; and
  • Your nickname.

The Service may also automatically collect or have in the past collected the following information:

  • The type of mobile device you use;
  • Your mobile device’s unique identifiers and IDs, including your identifiers for advertisers and vendors, anonymous identifier (AdID), Firebase App Instance ID, Facebook Encoded Device Info, Facebook Anonymous ID;
  • The IP address of your mobile device;
  • Your mobile operating system;
  • The type of mobile Internet browser you use;
  • Usage data; and
  • Analytics data about you that we receive from third parties.

III. PURPOSES FOR WHICH WE USE THE DATA

We may use the collected data for the following purposes:
  • For age verification and other compliance purposes;
  • To improve customer service and customer support;
  • To personalize user experience and provide information about the Service, including about changes to it;
  • To provide and maintain the Service and its features and to allow you to engage with these features when you choose to do so;
  • To develop, improve, and protect the Service;
  • For market research and to monitor usage of the Service;
  • To audit and analyze the Service;
  • To ensure the technical functionality and security of the Service;
  • To remember information so that you will not need to reenter it during your visit or the next time you visit the Service;
  • To provide custom, personalized content and information, including targeted content and advertising;
  • To monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns in our Service;
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
  • To protect against or deter fraudulent, illegal or harmful actions, and maintain the safety, security and integrity of the Service; and
  • To differentiate between the devices you use to access the Service in order to prevent desynchronization of the user database.

Under the GDPR, our processing of personal data is based on different legal grounds, including consent, performance of a contract, compliance with legal obligations, and our legitimate interests, depending on the specific purpose.

IV. HOW WE DISCLOSE DATA

We do not sell, share, or otherwise disclose your data to third parties unless stated below. The data collected in the Service may be disclosed in the following circumstances and with the following categories of third parties:
  • Service Providers. To assist us in meeting business operations needs and to perform certain services and functions, we may share the data we collect with service providers. Pursuant to our instructions, these parties will access, process or store the data in the course of performing their duties to us. The tasks for which we employ service providers include:
    • Analytics. We may use third-party service providers to monitor and analyze the use of our Service, including to measure traffic and usage trends. No personal data is collected in this process.
    • Advertising. We may use third-party service providers to show advertisements to you to help support and maintain our Service. Any ads shown to users under 13 (or such other minimum age as required by law) are strictly contextual and not based on profiling or behavioral tracking.
    • Behavioral remarketing. We use remarketing services to advertise on third party websites to you after you have used our Service. We and our third-party vendors may use cookies to inform, optimize, and serve ads based on your past visits to our Service.
    • Payments. We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing. We do not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your data is governed by the applicable terms and policies. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands including Visa, MasterCard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
    • Refund requests. If we receive a refund request for an in-app purchase from an end-user, we reserve the right to provide a third-party with information regarding the user’s in-app purchase consumption. This includes the following data: app usage time, anonymous account identifier, total amount spent, and total amount refunded.
  • Business Transfers. If we are involved in a merger, acquisition, financing, due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, the necessary data we have collected and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
  • Legal Requirements. We may share the data we collect if required to do so by law or in the good faith belief that such action is necessary to (i) comply with legal or regulatory obligations, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service or the public, or (v) protect against legal liability.
Moreover, we may disclose anonymous information to third parties in an aggregate format that does not constitute personal data and that does not allow the identification of individual users. “Anonymous information” means information that does not enable identification of an individual user, such as aggregated, anonymized or de-identified information about the use of the Service. We may use anonymous information and/or disclose it to third parties without restrictions (for example, to improve our services and products and enhance your experience with them).

For underage users, we only collect the minimum data necessary to operate the Service (e.g., age for eligibility, device settings). We do not collect or use identifiers such as advertising IDs, emails, or sign-in credentials without parental consent.

V. DATA SECURITY

The security of personal data is important to us. For example, the servers we use are secured and protected by a firewall. Even so, we cannot guarantee that your data will always be secure as data security measures in use from time to time may be vulnerable.

We periodically review and adjust security safeguards as the threat landscape evolves. Ultimately, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, our policy is to take reasonable steps to investigate the situation and cure the breach.

VI. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to any country in which we or our affiliates or service providers maintain facilities and to the use and disclosure of information about you as described in this Privacy Policy. If you are located outside of the United States, please note that we transfer the data to the U.S. and process it there. Also, we use Google’s Firebase Crashlytics, Apphud, Facebook technologies (e.g. Facebook SDK) provided by Meta Platforms etc., and processing may occur on their global infrastructure. In these and other cases where personal data is transferred outside the EEA, we rely on the European Commission’s Standard Contractual Clauses and, where applicable, the EU–U.S. Data Privacy Framework to ensure adequate protection.

VII. CHILDREN’S PRIVACY

Our Service can be used by children. We process and collect children’s data as described in Sections II-IV of this Policy, subject to the provisions of this Section.

We ask for their date of birth. If they are under the applicable age of digital consent (depending on jurisdiction), we will require verifiable parental consent before collecting or processing any personal data.

The Service only requires disclosure of personal information before accessing certain functions. We do not share any personal information we collect from persons under the age of 13 (or such other minimum age as required by law). We use data about their age only for age verification purposes. We delete any other personal information collected from such persons upon learning of their age.
 
As explained in Section IV, we share our users’ information with third parties. Below is a list of the third parties to which we disclose such information and their services we use:

If, during the age verification process, we learn that a user is under 13 (or such other minimum age as required by law):

  • We do not collect or share with third parties their advertising ID;
  • We do not share any of their device-level data with third parties;
  • We add a child-no-tracking tag to all Advertising Software Development Kits we use; and
  • As a result of the above measures, any ads a user under 13 sees are strictly contextual.
The Service has two multiplayer modes. In the quasi-multiplayer, a user does not interact with other humans. We moderate the quasi-multiplayer pursuant to the Terms of Use. The real multiplayer is age-restricted. If we learn that a user is below 13 (or such other minimum age as required by law), they are not allowed access to the real multiplayer mode. We do not knowingly collect their sign-in credentials.

If you have any questions about the application of this Privacy Policy to your children or requests regarding their data, you can contact us at privacy@artworkout.app. You have the right to review, request deletion, and refuse to permit further collection, use, or disclosure of your or your children’s information. You may prohibit the disclosure of your children’s information to third parties while agreeing to its collection and use for the purposes of
accessing the Service. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Parents or legal guardians have the right to:
– Review the personal data collected from their child,
– Request deletion,
– Withdraw consent,
– Object to further collection or processing.

To exercise these rights, please contact us at privacy@artworkout.app. We implement additional safeguards for children’s data in accordance with GDPR-Kids (Article 8) and COPPA requirements.