Privacy Policy for Art in the Middle Magazine LLC

Introduction and Overview

At Art in the Middle Magazine, accessible from artinthemiddle.com, we prioritize the privacy and security of our visitors and subscribers. This Privacy Policy document outlines the types of information we collect, how we use it, your rights regarding this information, and our commitment to protecting your privacy.

This Privacy Policy applies to all our online and offline activities related to Art in the Middle Magazine, including our website, digital subscriptions, newsletters, events, and other services (collectively, our "Services"). By using our Services, you consent to the data practices described in this policy.

Effective Date: February 26, 2025
Last Updated: April 30, 2025

1. Information We Collect

1.1 Personal Information You Provide

We collect the following categories of personal information that you voluntarily provide to us:

• Identity Information: Name, email address, phone number.
• Account Information: Subscription details, preferences.
• Payment Information: We do not collect any payment information from our audience.
• Communication Information: Correspondence with us, survey responses, feedback.
• Content Contributions: Articles, comments, artwork submissions, contest entries.
• Professional Information: If you are an artist, gallery owner, or contributor, we may collect information about your career, portfolio, and professional background.

1.2 Information Collected Automatically

When you interact with our Services, we and our third-party service providers may automatically collect:

• Device Information: IP address, browser type and version, operating system, device type
• Activity Information: Pages visited, time spent on pages, links clicked, search queries
• Location Information: General geographic location based on IP address or more precise location if permitted by you
• Log Data: Access times, browser type, language, referring website addresses
• Cookies and Similar Technologies: Information collected through cookies, web beacons, pixels, and similar technologies (see our Cookie Policy section)

1.3 Information from Third Parties

We may receive information about you from other sources, including:

• Social media platforms when you interact with our content or connect your social media accounts
• Business partners, such as co-sponsors of events or promotional activities
• Data providers and aggregators who enhance our data for analytics and marketing
• Publicly available sources, such as public social media profiles or art directories

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Providing and Managing Our Services

• Process subscriptions and registrations
• Deliver digital content, newsletters, and notifications
• Manage your subscriptions preferences
• Respond to your inquiries and provide customer support

2.2 Improving and Developing Our Services

• Analyse usage patterns to enhance user experience
• Debug and fix technical issues
• Develop new features and content
• Conduct research and analytics to understand our audience
• Test and evaluate potential new products and services

2.3 Personalization

• Customise content based on your interests and preferences
• Recommend articles, artists, exhibitions, or events you might enjoy
• Create a more tailored experience across our services
• Remember your preferences and settings

2.4 Marketing and Communications

• Send promotional messages, special offers, and information about our services
• Deliver newsletters and content updates you've requested
• Inform you about events, contests, or opportunities related to arts and culture
• Conduct surveys and collect feedback
• Communicate about changes to our Services or policies

2.5 Security and Legal Compliance

• Protect against fraudulent, unauthorised, or illegal activity
• Verify identity and authenticate users
• Comply with legal obligations and industry standards
• Enforce our terms of service and other agreements
• Establish, exercise, or defend legal claims

2.6 Legal Basis for Processing (Under GDPR and Similar Laws)

Where applicable law requires a legal basis for processing, we rely on the following:

• Consent: When you have given clear consent for us to process your personal information for a specific purpose
• Contractual Necessity: When processing is necessary to fulfil our contractual obligations to you (e.g. providing subscription services)
• Legitimate Interests: When processing is necessary for our legitimate interests or those of a third party, provided those interests don't override your fundamental rights and freedoms
• Legal Obligation: When processing is necessary to comply with our legal obligations
• Vital Interests: In rare circumstances, when processing is necessary to protect someone's life or safety

For each major processing activity, the specific legal basis is:

• Subscription management: Contractual Necessity
• Content delivery: Contractual Necessity
• Customer support: Contractual Necessity and Legitimate Interests
• Personalization: Consent and/or Legitimate Interests
• Marketing communications: Consent and/or Legitimate Interests
• Analytics and improvement: Legitimate Interests
• Security measures: Legitimate Interests and Legal Obligation

3. Information Sharing and Disclosure

3.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Subscription management and payment processors
• Customer relationship management systems
• Email and newsletter distribution services
• Cloud storage and hosting providers
• Analytics and research companies
• Customer support services
• Marketing and advertising partners
• Event management platforms

These service providers are contractually obligated to use your information only for providing services to us and in compliance with this Privacy Policy.

3.2 Business Partners

We may share limited information with our business partners, including:

• Co-sponsors of events, contests, or promotional activities
• Galleries, museums, or cultural institutions for joint initiatives
• Artists or contributors featured in our content (with your consent)

3.3 Advertising Partners

We work with advertising partners who help us deliver relevant advertisements. These partners may include:

• Online advertising networks
• Social media platforms
• Search engines
• Marketing analytics providers

These partners may use cookies and similar technologies to collect information about your interactions with our Services and other websites. For a complete list of our advertising partners and links to their privacy policies, please contact us using the information in the "Contact Us" section.

3.4 Affiliates and Corporate Group

We may share information with our parent company, subsidiaries, and affiliated entities for purposes consistent with this Privacy Policy.

3.5 Legal Requirements and Business Transfers

We may disclose your information when we believe in good faith that:

• It is required by law, regulation, or legal process
• It is necessary to protect our rights, property, or safety
• It is necessary to protect the rights, property, or safety of our users or others
• It is related to an investigation of suspected or actual fraudulent or illegal activity

If Art in the Middle magazine is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any change in ownership or use of your information.

3.6 With Your Consent

We may share or disclose your information in other ways with your consent or at your direction.

3.7 Data Sales and Sharing for Cross-Context Behavioural Advertising

Under laws like the California Consumer Privacy Act (CCPA) and similar state regulations, certain disclosures of personal information to third parties may be considered "sales" or "sharing" even if no money is exchanged. This includes sharing identifiers and internet activity information with advertising partners for cross-context behavioural advertising (targeted advertising).

Art in the Middle magazine may engage in such activities. You have the right to opt out of these practices as described in the "Your Privacy Rights and Choices" section.

4. Cookies and Tracking Technologies

4.1 Types of Tracking Technologies We Use

We and our partners use various tracking technologies, including:

• Cookies: Small text files stored on your device that help us recognise you and remember your preferences
• Web Beacons/Pixels: Tiny electronic images that help us understand how users interact with our content
• Local Storage: Data stored in your browser or device that persists after you close your browser
• SDKs and APIs: In mobile applications, software development kits that help collect and analyse information

4.2 Categories of Cookies

We use the following types of cookies:

• Essential: Required for basic functionality of our Services
• Functional: Enable enhanced features and remember your preferences
• Analytics: Help us understand how users interact with our Services
• Advertising: Used to deliver relevant ads and measure their effectiveness
• Social media: Enable social sharing and integration with social platforms

4.3 Your Cookie Choices

You can manage cookies through your browser settings, which typically allow you to:

• Accept or reject all cookies
• Accept or reject specific types of cookies
• Receive notifications when cookies are set
• Delete cookies periodically

To manage cookies, visit your browser's help section for instructions specific to your browser (Chrome, Firefox, Safari, Edge, etc.). Most mobile devices also provide settings to limit tracking.

4.4 Specific Third-Party Cookies

Like many websites, we use certain third-party cookies including Google Analytics and potentially Google DoubleClick DART cookies. Google uses these cookies to serve ads based on a user's prior visits to our website or other websites. You may opt out of personalized advertising by visiting Google's Ads Settings (https://www.google.com/settings/ads) or by visiting www.aboutads.info.

4.5 Do Not Track Signals

Some browsers transmit "Do Not Track" (DNT) signals to websites. While we strive to respect user preferences, there is currently no consistent industry standard for responding to DNT signals. We continue to monitor developments in this area and may update our practices accordingly.

5. Log Files

Art in the Middle Magazine follows standard procedures for using log files. These files log visitors when they visit websites. All hosting companies do this as part of hosting services' analytics. The information collected by log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any personally identifiable information. The purpose of this information is for analyzing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

6. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The duration of our relationship with you and provision of services
• Legal obligations to retain data for certain periods
• Statutes of limitations for legal claims
• Ongoing business needs, such as maintaining financial records
• Industry standards and best practices

When personal information is no longer needed, we securely delete or anonymize it.

7. Data Security

We implement appropriate technical, organisational, and physical safeguards to protect your personal information from unauthorized access, use, alteration, and disclosure. Our security measures include:

• Encryption of sensitive data in transit and at rest
• Access controls and authentication requirements
• Regular security assessments and penetration testing
• Employee training on data protection and security practices
• Physical security measures at our facilities
• Regular monitoring for suspicious activities

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

8. International Data Transfers

Art in the Middle Magazine operates globally, which means your information may be transferred to, stored in, or processed in countries outside your country of residence, including countries that may not have the same data protection laws as the country where you reside.

When we transfer personal information outside the European Economic Area (EEA), United Kingdom, Switzerland, or other regions with comprehensive data protection laws, we ensure appropriate safeguards are in place, which may include:

• European Commission approved Standard Contractual Clauses
• Binding Corporate Rules for transfers within our corporate group
• Derogations under Article 49 of the GDPR such as explicit consent
• Other legally approved mechanisms

For more information about our cross-border data transfers and the safeguards we implement, please contact us using the information provided in the "Contact Us" section.

9. Your Privacy Rights and Choices

Depending on your location, you may have certain rights regarding your personal information. These may include:

9.1 Access and Information

• The right to know what personal information we collect about you
• The right to request copies of your personal information
• The right to know how we use and disclose your information

9.2 Correction and Deletion

• The right to correct inaccurate personal information
• The right to delete your personal information (subject to certain exceptions)
• The right to have incomplete information completed

9.3 Restriction and Objection

• The right to restrict certain processing of your information
• The right to object to certain processing activities
• The right to opt out of "sales" or "sharing" of personal information for cross-context behavioural advertising

9.4 Data Portability

• The right to receive your personal information in a structured, commonly used format
• The right to transmit that information to another entity

9.5 Consent Withdrawal

• Where processing is based on consent, the right to withdraw that consent at any time

9.6 Non-Discrimination

• The right not to be discriminated against for exercising your privacy rights

9.7 How to Exercise Your Rights

To exercise any of these rights, please contact us using the methods described in the "Contact Us" section. We will respond to your request within the timeframe required by applicable law (generally within 30 days).

For verification purposes, we may ask for specific information to confirm your identity. This is a security measure to ensure we don't disclose personal information to unauthorized individuals.

There is no fee for exercising your rights. However, we may charge a reasonable fee or decline to act on requests that are manifestly unfounded, excessive, or repetitive.

9.8 Authorized Agents

In certain jurisdictions, you may authorize someone else to make a request on your behalf. If you use an authorized agent, we may require proof of the agent's authorization and your identity.

9.9 Specific Regional Rights

California Residents

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have specific rights, including:

• The right to know what personal information is collected, used, shared, or sold
• The right to delete personal information (with certain exceptions)
• The right to opt-out of the "sale" or "sharing" of personal information
• The right to limit the use and disclosure of sensitive personal information
• The right to non-discrimination for exercising these rights

To exercise these rights, visit our "Do Not Sell or Share My Personal Information" page at [artinthemiddle.com/privacy/do-not-sell] or call our toll-free number at [1-800-XXX-XXXX].

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us through our contact information provided below.

European Economic Area, United Kingdom, and Switzerland Residents

If you are located in these regions, you have rights under the General Data Protection Regulation (GDPR) or similar laws, including those listed above. You also have the right to lodge a complaint with your local data protection authority.

10. Children's Privacy

Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information promptly.

For children between 13 and 16 years old (or higher age limits as required by local law), we obtain parental consent before collecting personal information used for behavioural advertising, profiling, or the sale of personal information.

We encourage parents and guardians to observe, participate in, and/or monitor and guide their children's online activity. If you believe we might have any information from or about a child under the applicable age limit, please contact us using the information in the "Contact Us" section.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. When we make material changes, we will:

• Post the updated Privacy Policy on our website with a "Last Updated" date
• Notify you through a pop-up notice, email, or other prominent means
• For significant changes, obtain your consent if required by applicable law

We encourage you to review this Privacy Policy periodically to stay informed about our privacy practices.

12. Third-Party Links and Services

Our Services may contain links to third-party websites, apps, or services that are not operated by us. This Privacy Policy does not apply to those third-party services, and we are not responsible for their content or privacy practices. We are advising you to consult the respective Privacy Policies of these third-party websites and services for more detailed information.

13. Our Advertising Partners

Some advertisers on our site may use cookies and web beacons. Each of our advertising partners has their own Privacy Policy for their user data practices. For easier access, we provide links to their Privacy Policies on our website. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on our website or other websites.

Note that Art in the Middle Magazine has no access to or control over these cookies that are used by third-party advertisers.

14. Financial Incentives and Loyalty Programs

We may offer financial incentives or operate loyalty programs related to the collection, retention, or use of your personal information, such as discounted subscriptions or exclusive content access. Participation in these programs is voluntary, and you may withdraw at any time.

The terms of these programs, including the categories of personal information involved and how to opt in or out, will be provided at the time we offer the program.

15. Dispute Resolution

If you have a complaint about our privacy practices, please contact us using the information below. We will investigate and attempt to resolve any disputes regarding the use of your personal information.

For residents of the European Economic Area, United Kingdom, or Switzerland, if we are unable to resolve your complaint, you have the right to lodge a complaint with your local data protection authority.

For U.S. residents, we comply with the applicable state privacy laws regarding dispute resolution.

This Privacy Policy shall be governed by and construed in accordance with the laws of the United Arab Emirates, without regard to its conflict of law provisions.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us using the following information:

Privacy Officer
Art in the Middle Magazine LLC
Sharjah Media City
Sharjah, United Arab Emirates
Email: info@artinthemiddle.com
Website: www.artinthemiddle.com/contact-us