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Privacy & Cookie Policy

 

Our Privacy & Cookie Policy was last updated on May 12, 2020.

 

Introduction

 

Users and our data controllers

Tutuhaoyi.com (“Tutuhaoyi”, “we,” “us,” or “our”) is an online platform for art researchers, artists, and collectors to share research results, antique appreciation and collection information, art news, and/or newly finished artworks. Pickahouse Pty Ltd, ABN (Australia) 15 609 914 481, the technology company that sponsored and designed this website and provides its Services, will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services.

Postal address:

PO Box 2363

Carlingford

New South Wales

Australia 2118

 

Our registered users (“Members”) are given privilege to share their professional knowledge, exchange insights on antiques and modern artworks, post and view relevant content, ask questions regarding website content, get technical support and find business opportunities through our Services. Content and data on some of our Services is viewable to non-members (“Visitors”). 

 

In accordance with laws on the prevention of money laundering and the financing of terrorist organisations, Tutuhaoyi is obligated to identify each user who tries to sell personal collections of antiques and artworks. Necessary documents and identification may be required where appropriate. If we are not completely satisfied with the information provided, we reserve the rights to refuse the user to post comments in any section in our products.

 

As a Member or Visitor of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy, Terms and Conditions, and other documents referenced in this Privacy Policy, as well as their updates.

 

Services

This Privacy Policy applies when you use our Services (provision of the websites and related products and services, collectively the “Services”, but excluding services that state that they are offered under a different privacy policy). We offer our users choices about the data we collect, use and share as described in this Privacy Policy, Terms and Conditions, Comments and Contact Us sections.

 

Change

Tutuhaoyi can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes. If you object to any of our Privacy Policy or its changes as a member, you must go to Contact Us page and request to close your account formally. However, our Privacy Policy still applies where relevant if you continue to be a visitor of our Services.

 

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

 

 

1. Data We Collect

 

1.1 Data You Provide to Us

Registration

In order to enjoy privilege as a Member of Tutuhaoyi, you need to create an account with us. You need to provide data including your name, email address, password and/or mobile number to us. If you register for a premium Service, you will need to provide payment (e.g., credit card) and billing information.

 

Profile

You have choices about the information on your profile, such as your demographic data, speciality, photo, personal hobbies and collections. Please do not post or add personal data to your profile that you would not want to be publicly available.

 

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you make a comment, subscribe to our newsletter, or fill out a form on the Contact Us page.

 

When you post or upload information to our products, we will automatically and manually scan and analyse such information. This is done for the purposes of

  • fraud prevention,
  • detection of unlawful acts and violations of our Terms and Conditions, and
  • to improve communication and customer service.

We process data in accordance with our legitimate interests in line with applicable Australian laws.

 

Using our internal messaging tool

As a Member you have the option to communicate with us via an internal messaging tool provided on the website. To use the internal messaging tools, registration is required.

 

Same as stated above in Posting and Uploading, our data processing for the aforementioned purposes is a recognised legitimate interest in accordance with the Australian laws.

 

You can manage your sent and received messages by yourself and delete them on request. In the event of an attempted fraud, an unlawful act or breach of the Terms and Conditions, we may store the appropriate messages even after request for deletion on the bases of our legitimate interests in order to assert or defend against claims or exercise legal rights.

 

Registering for our newsletter

If you register through our website for our newsletter by email, then you agree to us periodically informing you of our activities. However, at all times you will be offered the possibility to indicate that you wish to receive no further information. If you no longer wish to receive our newsletter, you can discontinue this service by sending us a message and specifying your requests on Contact Us page.

 

We may also use your e-mail address without your express consent to send you information about similar products of Tutuhaoyi if you are an existing customer and have not objected to the use of your e-mail address. You can unsubscribe at any time, such as via link at the end of each newsletter. Alternatively, you can unsubscribe at any time by requesting us in writing.

 

1.2 Data from Others

Content and News

You and others may post content that includes information about you (as part of articles, posts, comments, news or images) on our Services. You must request us in writing to remove such information from our Services.

 

Partners

We receive personal data (e.g., your name, geographic data and email address) about you when you use the services of our business partners.

 

1.3 Service Use

We temporarily log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as the date and time of access our content or ads, the name and URL of the retrieved file, the website from which access is occurring (referrer URL), or shared articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use. Such information is subsequently automatically deleted after a period of 26 weeks.

 

We process the aforementioned data for the following purposes:

  • to ensure a trouble-free connection with our website;
  • to ensure convenient use of our website and optimise our platform;
  • to monitor and ensure system security and stability;
  • to detect and prevent attacks on our website, and
  • for other internal statistical and administrative purposes.

We never use collected data to reference you as a person. In the event of an attack on our network infrastructure however, your IP address will be identified in order to assert or defend against legal claims.

 

1.4 Cookie Policy

What is a cookie

Members and Visitors are informed that, when visiting the Site, a cookie may be automatically installed within his or her browser software.

 

A cookie is a block of data that does not allow users to be identified, but serves only to record information on how they navigate the website.

 

The settings of the browser software can be set so as to indicate the presence of a cookie and even to refuse it. You can also delete all cookie information that your browser has previously stored via your browser preferences.

 

What do we do with cookies

We respect your privacy and do not leak or sell the collected data to third parties. We are also committed to being transparent about the tracking technologies we use. This Privacy Policy, including Cookie Policy, describes our practices concerning the personal information collected through our website, and any related Tutuhaoyi products and Services. Cookies, web beacons, pixel tags, clear gifs, and other similar files or technologies may be used to collect and store the information automatically collected about your computer, device, and Service usage.

 

Under the conditions indicated above, you have the right to access, withdraw and modify the personal data provided by means of the cookie.

 

1.5 Your Device and Location

When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings.

 

 

 

2. How We Use Your Data

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalise our Services, including with the help of automated systems and inferences we make, so that our Services (including ads) can be more relevant and useful to you and others.

 

Info to Ad Providers

We do not share your personal data with any third-party advertisers or ad networks except for:

  • device identifiers (to the extent they are personal data in some countries);
  • with your separate permission (e.g., in a lead generation form), or
  • data already visible to any users of the Services (e.g., profile).

However, if you view or click on an ad on or off our Services, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of mechanisms such as cookies, determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

 

Service Development

We use data, including public feedback, to improve our Services, drive membership growth and engagement on our Services.

 

Customer Support

We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

 

Insights That Do Not Identify You

We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their specialities, their collection types to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service.

 

Security and Investigations

We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our Terms of Use and/or attempts to harm our Members, Visitors or others.

 

 

 

 

3. How We Share Information

 

3.1 Our Services

Profile

Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third-party search engines).

 

Posts, Likes, Comments

Our Services allow viewing and sharing information including through posts, likes and comments.

When you share an article or a post (e.g., an image, blog, news or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).

When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).

 

3.2 Related Services

We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others.

 

3.3 Service Providers

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

 

3.4 Legal Disclosures

We only disclose your personal data to third parties if:

  • you have expressly consented thereto in accordance with Australian laws
  • there is a legal disclosure obligation pursuant to Australian laws
  • disclosure is required pursuant to Australian laws
  • in order to assert or defend against claims or exercise legal rights and there are no grounds to assume that you have a prevailing legitimate interest in non-disclosure of your data.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to:

(1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies;

(2) enforce our agreements with you;

(3) investigate and defend ourselves against any third-party claims or allegations;

(4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or

(5) exercise or protect the rights and safety of Tutuhaoyi, our Members, personnel or others.

We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

 

3.5 Change in Control or Sale

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

 

 

 

4. Your Choices & Obligations

 

4.1 Data Retention

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. In some cases we choose to retain certain information in a depersonalised or aggregated form.

 

4.2 Rights to Access and Control Your Personal Data

You can access, change, restrict or delete your personal data. We offer you settings to control and manage the personal data we have about you.

 

4.3 Account Closure

If you choose to close your Tutuhaoyi account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

 

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our policies), enforce our Terms of Use policy, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalised information after your account has been closed.

 

Information you have shared with others (e.g., through comment) will remain visible after you close your account or delete the information from your own profile, and we do not control data that other Members have copied out of our Services. Comment content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache. 

 

5. Other Important Information

 

5.1. Security

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us or post on our website. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

 

5.2. Cross-Border Data Transfers

We process data both inside and outside of Australia and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.

 

5.3 Lawful Bases for Processing

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Tutuhaoyi Services you have subscribed) and “legitimate interests”.

 

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please fill in the form in Contact Us page.

 

5.4. Direct Marketing and Do Not Track Signals

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

 

5.5. Contact Information

If you have questions or complaints regarding this Policy, please first fill in the form in Contact Us page. You can also reach us by physical mail. If contacting us does not resolve your complaint, you may have more options under Australian law.

We use cookies to improve your experience and deliver personalised advertising. By continuing to use Tutuhaoyi.com, you agree to our use of cookies as detailed in our Privacy & Cookie Policy.