Privacy Policy

Last Revised: October 6, 2025

This Privacy Policy describes how Artiome LLC (doing business as Zhu Consulting™) (the "Site", "we", "us", or "our") collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from artiome.com (the "Site") or otherwise communicate with us regarding the Site (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully. By using and accessing our website (the "Site") or engaging with our consultancy services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, please do not use or access our Site or services.

Our Site, hosted on HubSpot, serves as a showcase for our consulting expertise, allowing visitors to learn about our services, subscribe to updates, and contact us for inquiries. We do not sell products directly on the Site—any digital resources are provided via third-party platforms (e.g., Substack for our blog), each with their own privacy policies. We collect limited information to facilitate communications and subscriptions only.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be indicated by an updated "Last Revised" date at the top. Any changes to this Privacy Policy will take effect when posted on this page with a new “Last Revised” date. Continued use of the Site or Services after updates are posted constitutes acceptance of those changes.

If we make material changes, we may notify you by prominently posting a notice on our Site or sending an email notification. We encourage you to review this Privacy Policy frequently to stay informed about how we protect your information.

How We Collect and Use Your Personal Information

To provide our services, we collect and have collected over the past 12 months personal information about you from various sources, depending on how you interact with us. This includes:

  • Visiting our website at https://zhuconsulting.com, or any website of ours that links to this Privacy Policy.

  • Subscribing to updates or engaging with us through inquiries, newsletters, or other communications.

In addition to the specific uses below, we may use information to communicate with you, provide or improve our services, comply with legal obligations, enforce our terms of service, and protect our rights and those of our users.

What Personal Information We Collect

The types of personal information we obtain depend on how you interact with our Site and services. When we use the term "personal information," we mean information that identifies, relates to, describes, or can be associated with you. We collect only what’s necessary to respond to your interest in our consulting services and maintain meaningful relationships.

Information We Collect Directly from You

  • Contact details: Your name, email address, and phone number, provided when you submit inquiries via our contact form or subscribe to updates.

  • Subscription information: Your email address and preferences selected for receiving consultancy insights, newsletters, or service announcements.

  • Communication records: Details you share in messages with us (e.g., via email, HubSpot contact forms, or chat), such as descriptions of your consulting needs or follow-up questions.

  • Account or profile information (if applicable): Username or secure login details for client portals or subscription management, used solely to access personalized resources or track service engagements.

Your Responsibilities

All personal information you provide must be true, complete, and accurate. Please notify us of any changes (e.g., via email or our contact form) to ensure we can deliver relevant consultancy insights and communications.

Information We Collect About Your Usage

We may automatically collect certain information about your interaction with our Site ("Usage Data") to improve your experience and analyze performance, but only if you consent via our cookie banner. We use cookies, pixels, and similar technologies ("Cookies"). Usage Data may include:

  • How you access and navigate our Site (e.g., pages viewed, time spent).

  • Device and browser information (e.g., type, operating system).

  • Network details, such as your IP address and approximate location.

  • Other interaction data, like clicks on subscription links or form submissions.

You can manage cookies via your browser settings or our cookie consent banner (see the Cookies section below). We do not sell this data.

Information We Obtain from Third Parties

We may receive limited information about you from trusted third-party vendors and service providers who support our operations, always in line with this Privacy Policy. Examples include:

  • Platform providers: Services like HubSpot, which handle opt-ins, email delivery, and basic CRM data (e.g., email interactions) for subscriptions and communications. For details on HubSpot’s privacy practices, see their Privacy Policy.

  • Content and product hosts: Platforms like Substack (for our blog), which may share basic interaction data (e.g., email confirmations) when you engage with our resources.

  • Analytics and tracking partners: Services like Google Analytics or HubSpot, which use pixels, web beacons, or cookies to monitor site visits, email opens, or form interactions—helping us refine our consultancy showcase, subject to your consent.

How We Use Your Personal Information

We process your personal information for various reasons, depending on how you interact with our Site and services, including:

  • To provide services: Respond to inquiries, manage subscriptions, send notifications related to your communications or preferences, and maintain client profiles or portals.

  • To communicate and improve services: Provide support, respond to inquiries, and resolve issues, in our legitimate interests to maintain business relationships.

  • To request feedback: Request feedback on your experience with our Site or services.

  • To market and advertise: Send consultancy insights, newsletters, or promotional emails, tailoring content to your interests. You can opt out at any time (see Your Rights).

  • To evaluate and improve: Identify usage trends, measure communication effectiveness, and enhance our Site, services, and marketing.

  • To protect our services: Keep our Site secure, including fraud monitoring. If you use account features, keep your credentials safe and contact us immediately if compromised.

  • To send administrative information: Share details about services, policy changes, or essential updates.

  • To comply with legal obligations: Meet legal requirements, respond to requests, or defend our rights.

Legal Basis for Processing (International Users):

For users in jurisdictions such as the EU, UK, or other regions with data protection regulations, our legal bases for processing your personal information include:

  • Consent: Where you have actively opted in (e.g., subscribing to communications).

  • Contractual Necessity: To fulfill our services or respond to your inquiries or client relationships.

  • Legitimate Interests: For business operations, security, site improvements, and communications — so long as they do not override your rights.

  • Legal Obligations: Where required by law, we may process your data to comply with legal obligations.

Cookies

What Are Cookies?

Cookies are small data files placed on your device when you visit a website, helping sites work efficiently and provide reporting information. "First-party cookies" are set by us; "third-party cookies" are set by partners like HubSpot or Google Analytics. Cookies can be session-based (deleted when you close your browser) or persistent (remain until deleted or expired).

Why Do We Use Cookies?

We use cookies to power and improve our Site (e.g., remembering preferences), run analytics (in our legitimate interests), and allow third parties to tailor content or advertising, but only with your consent via our cookie banner. Essential cookies are required for core functions like security and accessibility—they cannot be disabled.

What Cookies Are Used?

We use the following types of cookies, subject to your consent where noted:

  • Essential Cookies: Necessary for core functions, such as security and navigation.

  • Performance & Analytics Cookies: Analyze user behavior to improve performance (e.g., via Google Analytics or HubSpot’s site tracking).

  • Functional Cookies: Enhance experience by remembering preferences like language settings.

  • Advertising & Targeting Cookies: Make messages relevant (e.g., preventing ad repetition); used by partners like HubSpot for form and email personalization.

Third-party cookies come from services like Google Analytics or HubSpot (for site forms and email tracking), governed by their privacy policies.

How Can I Control Cookies?

You can accept or reject non-essential cookies via our Cookie Consent Manager when you visit our Site. Essential cookies cannot be rejected. You can also adjust browser settings to block or remove cookies—most browsers accept them by default. Additional controls:

  • Opting Out of Targeted Advertising: Use the Digital Advertising Alliance (DAA) or Network Advertising Initiative (NAI).

  • State-Specific Rights: California, Virginia, Colorado, Connecticut, and Utah residents can opt out of targeted advertising (see Your Rights).

  • Google Analytics Opt-Out: Visit https://tools.google.com/dlpage/gaoptout.

  • Global Privacy Control (GPC): We honor GPC opt-out signals for non-essential tracking.

Blocking cookies may limit functionality or impair tracking features.

Other Tracking Technologies

We may use web beacons (also known as tracking pixels) or similar tools to recognize visits, monitor site traffic, track email opens (e.g., in newsletters or subscription confirmations), or measure the success of our communications and campaigns. These technologies often work in conjunction with cookies and are enabled only if you provide consent through our cookie banner. Declining or withdrawing consent for cookies will impair or disable these functions. For example, if you subscribe to updates or contact us via our forms, we may use these tools to improve our services, but always in line with your preferences and applicable laws.

Flash Cookies or Local Shared Objects

We do not use Flash cookies (also known as Local Shared Objects or LSOs) on our Site, as our platform (powered by HubSpot) relies on modern technologies like JavaScript and standard cookies. If any third-party tools or linked services (e.g., Substack for our blog) use them, you can manage those via Adobe’s settings at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Do Not Track

Our Site does not automatically respond to "Do Not Track" (DNT) browser signals, as there is no universal industry standard for interpreting them. Instead, we rely on our cookie consent banner to obtain your explicit permission before enabling tracking. If you wish to opt out of tracking, you can do so via the banner when you first visit the Site, or by managing your preferences later (e.g., through browser settings or contacting us). For more information on DNT, visit https://allaboutdnt.com. We will update our practices if a recognized DNT standard emerges.

How We Disclose Personal Information

We may disclose your personal information in limited circumstances, subject to this Privacy Policy:

  • With vendors like HubSpot (for analytics, email services) or Google Analytics, who perform services on our behalf.

  • With business or marketing partners to provide services or communications (they follow their own privacy notices).

  • When you direct us to share (e.g., via links to Substack).

  • With affiliates in our corporate group, in our legitimate interests.

  • In business transactions (e.g., mergers), to comply with legal obligations (e.g., subpoenas), enforce terms, or protect rights.

Over the past 12 months, we have disclosed the following categories for these purposes:

  • Categories: Identifiers (e.g., contact details like email); California Customer Records categories (e.g., contact info); Internet activity (e.g., Usage Data); Geolocation (e.g., IP-derived).

  • Recipients: Vendors (e.g., analytics providers like Google Analytics, email and CRM services like HubSpot); Business partners; Affiliates.

We do not use or disclose sensitive personal information (e.g., financial details, government ID) without consent, nor infer characteristics from it. We do not sell personal information for profit. However, certain sharing may be considered a "sale" or "sharing" under U.S. state laws — we honor opt-outs and Global Privacy Control signals accordingly.

Third-Party Websites and Links

Our Site may link to third-party sites (e.g., Substack for our blog). We are not responsible for their privacy practices—review their policies. Sharing on social platforms is public and beyond our control. Links do not imply endorsement.

Disclaimer of Liability for Third-Party Practices

While we take reasonable steps to protect your personal information, we cannot guarantee the security or privacy practices of third parties, such as hosting providers, analytics tools, or communication platforms. Any transmission of data to or from our Site is at your own risk. We are not responsible for circumvention of privacy settings, security measures, or the actions of third parties with whom you choose to share your information.

Children’s Data

We do not knowingly collect, solicit, or market to children under 13, nor sell such information. By using our Site, you represent you are at least 18, or if 13-17, have parental consent. If we learn of unintended collection from a child under 13, we will delete it promptly (unless legally required to retain). Contact us at haoji.zhuh@gmail.com if concerned.

Security and Retention of Your Information

We prioritize your information’s security using commercially reasonable measures, but no online transmission or storage is 100% secure—use our Site in a secure environment. We also ensure that any service providers with access to personal data maintain equivalent or stronger security safeguards.

We retain personal information only as long as necessary for our purposes, legal obligations, disputes, or agreements. Usage Data is retained shorter for analysis, except for security or legal needs.

We maintain certain data that you transmit or provide to us for the purpose of managing the performance of our Services, as well as records relating to your engagement and communications with us. You are solely responsible for all data that you transmit or that relates to any activity you have undertaken using the Services.

To the fullest extent permitted by law, we shall have no liability for any loss, unauthorized access, alteration, or corruption of data transmitted to or stored with us or our service providers, whether due to technical failure, unauthorized third-party action, or other circumstances beyond our reasonable control. By using our Services, you expressly waive any right of action against us arising from any such loss or corruption of data, except where required by applicable law.

Your Rights

Depending on your location, you may have rights regarding your personal information (not absolute; we may decline per law):

  • Access/Know: Request details on your data and its use/sharing.

  • Correct: Request fixes to inaccuracies (or update via account settings).

  • Delete: Request deletion (via account or email; we may retain for legal reasons).

  • Portability: Request a copy or transfer to a third party.

  • Opt-Out of Processing: Opt out of targeted advertising, sales, profiling, or sharing (including via HubSpot-powered tools, which honor Global Privacy Control signals).

  • Restrict Processing: Limit processing in certain cases.

  • Withdraw Consent: Revoke where consent-based (doesn’t affect prior processing).

  • Appeal: Appeal denials by replying to our notice.

  • Non-Discrimination: No retaliation for exercising rights.

  • Manage Preferences: Unsubscribe from emails via the "unsubscribe" link in HubSpot-powered communications.

State-specific rights may include:

  • Access categories of data processed (e.g., Minnesota).

  • List of third-party recipients (e.g., California, Delaware).

  • Limit sensitive data use (e.g., California).

  • Opt out of voice/facial recognition collection (e.g., Florida).

  • Opt out of targeted advertising/profiling/sales (e.g., Virginia, Colorado, Connecticut, Utah).

  • Limit cookie tracking (e.g., California, Virginia).

Exercise rights via our Site or email haoji.zhuh@gmail.com. We verify identity (e.g., via email) and respond timely per law. Agents need proof of authorization.

Transfer of Your Personal Information

Your information is processed in the U.S. (our operating location). We primarily serve U.S. users but welcome international visitors—data submitted consents to U.S. transfer/storage, where laws may differ. We ensure secure transfers with adequate safeguards.

Standard Contractual Clauses (SCCs)

For data originating from the European Economic Area (EEA) or countries whose data protection laws require it, we rely on the European Commission’s Standard Contractual Clauses (SCCs) to lawfully transfer personal data out of the EEA. These clauses are integrated into our agreements with data processors and sub-processors. HubSpot, for example, incorporates SCCs automatically into its Data Processing Agreement, providing a legally recognized mechanism for transferring data under GDPR requirements.

Additional Safeguards

We apply commercially reasonable technical and organizational measures (including encryption, limited retention, and access control) to protect transferred data. Data processors such as HubSpot and Google comply with EU-U.S. Data Privacy Framework principles, where applicable.

Complaints & Appeals

For concerns, contact haoji.zhuh@gmail.com. If unsatisfied, appeal via email—we’ll review and explain denials per law. You may also contact your state attorney general or data authority.

Contact

Questions? Email haoji.zhuh@gmail.com or by post: Artiome LLC, 30 N GOULD ST STE N, SHERIDAN, WY 82801.