Privacy Policy



In this legal document, the legally obligatory information on the processing carried out on your personal data in the context of our Website is provided.

The present Privacy Policy regulates the processing of your personal data performed by ARSENAL TRADING LIMITED (hereinafter, the “Company" or “We”), collected through the use of the services offered on the Website (hereinafter, "Services").

The latest update of this Privacy Policy is indicated at the top of this text and it will become effective as of the date indicated in each version. The Company, thus, recommends reviewing this Privacy Policy from time to time.




The following sections address the collection and processing of your personal information through any of the projects run by the Company, including any of their subdomains and sections.


1. Data controller


ARSENAL TRADING LIMITED, registered in Hong Kong with its registration number 2910452 and registered office at RM 512 NEW MANDARIN TOWER 14 SCIENCE MUSEUM ROAD, TSIM SHA TSU EAST, KOWLOON, HONG KONG, 999077, HONG KONG SAR CHINA.

You can send an email to to raise any questions, request or exercise of right regarding personal data protection.


2. Website Use under Terms and Conditions


You can only contract our services and validly consent to our Terms of Use if you are of legal age.

Our products are directed to people of legal age. In specific cases, we may explicitly allow them to be hired for use by minors. They must be examined and accepted, on the minor behalf, by the person of legal age who is the holder of the parental authority or in charge of their custody or education.

Notwithstanding the aforementioned, if you are a minor, in accordance with our terms and conditions, you cannot validly enter into any of the contracts we offer.


3. Our purposes and lawful basis of data we collect


Your personal data is processed with different purposes. Each processing must be based on a lawful basis, among those set forth by the regulation. We use the following basis:

1. Consent: you have given your informed, unequivocal and specific consent to the processing of your personal data aimed to a specific purpose.

2. Legal obligation: the law requires process and disclose certain data on occasions to certain institutions (for example, to the Tax Authority).

3. Execution of a contract: the data are strictly necessary to provide you with our services or to comply with what was agree with you.

4. Our legitimate interests, provided that your interests and rights do not prevail over them.

The legal bases of our data processing carried out through our Website, in relation to the purposes for which we will use your data, are the following:


3.1. Browsing the Website


When you browse and use the Website, even if you do not register, data is automatically collected through technology or automated interactions, such as IP address, device id, certains metadata (HTTP header, your browser, etc.). In addition, information is collected on the number of downloads and searches you perform. These data are recorded in order to control the number of downloads made by each user, thus allowing us to detect a fraudulent or illegitimate use of the Website, and, therefore, guarantee compliance with the Terms and Conditions of Use of the Website, that is, the management of the contractual relationship between you and Us.

These technical data observed when the user browser the Website are processed for the purpose of detecting and mitigating risks of attacks (bots, code injections, DDOS attacks), and, generally, to guarantee and maintain the Website security. Our lawful basis is our legitimate interest in protecting the security of our systems and preventing the violation of our terms and conditions.

 • Personal data processed: IP address, device id and certain metadata such as the browser used or the HTTP/HTTPS header.


3.2. Contractual relationship with our registered users


When you register as a user (either user or collaborator), we request the personal data that we need for the management and fulfillment of our contractual relationship with you.

We do not request, collect or process any special categories of personal data (those that reveal ethnic or racial origin, political opinions, religious or philosophical convictions, union membership and information on health, orientation and sexual life, genetic or biometric data).

When you are requested to provide personal data that is deemed as necessary, due to legal obligation or in accordance with our contracting conditions, and you refuse to provide them, we may not be able to formalize said contract or provide the service, which will be communicated to you properly.

 • Personal data processed: username, email address, name, address. Only the email address and username are required.


3.3. Models included in our content


If you appear as a model of images or videos offered as content on our website, we process your personal data included in the legal documentation and your image is incorporated into our products for marketing on our websites, based on your contract with the external creator or directly with us, as the case may be.

Your image may be used for purposes of development, training, testing, or improvement of software, algorithms, and machine learning models in combination with other images, texts, graphics, films, audios, and audiovisual works, always in an aggregated form, without the processing pursuing or making it possible to uniquely identify you.


3.4. Support requests


When you contact us requesting information or support, we process your data in order to assist you, based on your consent expressed in your own request.

 • Personal data processed: contact information that you provide us with in order to respond to your request and the content of your request.


3.5. Legally binding processing


When in some cases we are legally bound by different regulations (regardless of whether or not you give your consent), to process and / or transfer certain personal data to different entities. For example, to the Tax Authority, or the law enforcement authorities, at their request. 

 • Personal data processed: those set forth in the applicable regulations.


4. For how long do we keep your data


We process your personal data only for the necessary period of time, depending on each case. Once our processing has terminated, we keep your data blocked for different periods of time (in general, until the prescription of the responsibilities that may have arisen from our interactions). The relevant deadlines in each case are listed below:

1. In relation to processing carried out to guarantee and maintain the security of our Websites and anti-fraud measures, we will keep your data for thirteen months.

2. In relation to the data necessary to provide the contracted service and the contractual relationship, your personal data will be stored while the contractual relationship is still active, and it will subsequently be kept blocked for five years (until the prescription of any contractual liability, or any intellectual property rights claim) and for a period of six years (regarding accounting information).

3. In relation to the data necessary to manage and fulfill our contractual relationships with our external designer, your personal data is processed while the validity of the intellectual property rights license remains in force, and they are kept blocked for five more years, (up to the prescription of possible contractual liabilities).

4. In relation to the sending of commercial communications by email, the data will be processed for 3 years from the last interaction with you or until you decide to object, whichever is the earliest.

5. We process your data to offer you surveys for the duration of our contractual relationship, unless you have objected to receiving them.

6. In relation to your non-commercial inquiries, the data will be deleted once they have been answered.

7. We will process the data provided for your application process for a period of one year from


8. Regarding the processing of data of the models incorporated in the available content, they will be processed for the duration of the contractual relationship with the external creator, and subsequently retained for a period of five years for the purpose of managing possible liabilities arising from the processing.

9. In relation to the processing of data for professional contact, up to a maximum of 3 years from the last interaction or until you object to the communication, whichever is the earliest.

10. We will keep your data in relation to the fulfillment of any legal obligation, in general, during the limitation periods of the possible responsibilities derived from our data processing, and specifically during the periods imposed by the regulation in each case.


5. Data Update


We ask that you to immediately notify us of any changes to your data so that the information contained in our systems is up-to-date at all times and does not contain errors. In this sense, you represent and guarantee that the information and data that you have provided us is accurate, current and truthful.


6. Disclosure of data


We do not transfer nor share collected personal data with third parties external to the company.


Access by third parties providing services to us

We may disclose personal information of our Users to third parties only in cases when it is strictly necessary for Us to perform their functions and to comply with the Terms of Use. We may also share personal information with other third parties to ensure compliance with applicable laws, including:

• Service providers, to manage systems and information technology such as hosting, broadband, IT security or web analytics providers.

• Payment platforms, banks and companies involved in the transaction process, to ensure the fulfilment of the necessary transactions.

• Advertising platforms, CRM and other marketing tools.

• User support management platforms.

• Lawyers, auditors, legal and accounting consultancy services and financial institutions.

These services provided by third parties are necessary for the development of the Company’s business activity. The processing of personal data is at all times subject to a contract which establishes the duties of the data processor towards the data controller (us). Under no circumstances will personal information be used for other purposes and it will be managed in compliance with our policy guidelines, their privacy policy and the applicable data protection regulation.


7. Rights of the user


You can exercise the rights described below in the following ways: logging in the User account,

through the support contact available on the Website or by emailing us at


Please note that the Company may require you to verify your identity before taking action on the request for the exercise of rights.


You have the following rights:

1. Transparency and information on how we process your personal data (right to be informed). Right that we satisfy, for example, through this legal text.

2. Right to request a copy of the information we hold, which will be provided to you within a month (right of access).

3. Right to update or modify the information we have if it is incorrect or inaccurate (right of rectification).

4. Right to request us to stop processing your information while a complaint is being resolved, among other cases (right to limit processing).

5. Right not to be subject to a fully automated decision based solely on the processing of your data, which produces legal effects concerning you or significantly affects you (right not to be subject to automated individual decisions).


Additionally, when we process your personal data based on your consent or on our contractual relationship with you:


1. Right to request that we delete personal data from our records (right to erasure or "to be forgotten"). You can carry out this request at any time by closing your account, through your profile section.

2. Right to obtain and reuse personal data for your own purposes (right to data portability).

3. Right to revoke at any time the consent previously given to any of our processing of your personal data.


8. Data security


We have implemented strong security controls to safeguard User’s personal information against loss, misuse, unauthorized access, disclosure or alteration.


For example, to protect your personal data, Secure Socket Layer (SSL) technology is used during the transmission of data. This means that an approved encryption procedure is used for communication between your computer or device and our servers, as long as your browser supports SSL.


9. Complaint submission


If you, the User, do not agree with the way ARSENAL TRADING LIMITED processes your personal data, you can contact us by sending an email to

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