Privacy Policy

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Romanian Version

ARTFIRST, SRL (“ARTFIRST”) is a company based in Bucharest, Romania. ARTFIRST provides art exhibition events and software services to parties who participate in, or have an interest in art related events.

Our policies have been developed with the recognition that Internet technologies and underlying business models are rapidly evolving. Accordingly, our policies are subject to change. Any such changes will be posted on this page. If the changes represent a material departure from our current practices with respect to the use of personal information, the changes will be posted on this page thirty days prior to taking effect, and registered users will be notified as appropriate.

As a condition of using ARTFIRST.ro, users must confirm their adult status. In accordance with the Children’s Online Privacy Protection Act (COPPA), ARTFIRST.ro does not collect or store any personal information, even in aggregate, about children under the age of 13.

EU DATA SUBJECTS (USERS)

The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union, effective May 25, 2018. It also addresses the export of personal data outside the EU. The GDPR replaces the 1995 Data Protection Directive. For US companies it is in effect in conjunctions with Privacy Shield, which is still in full effect, see below. EU DATA SUBJECT WISHING TO SEE HOW WE COMPLY WITH THESE REGULATIONS ARE DIRECTED TO OUR GDPR PRIVACY POLICY ADDENDUM

TABLEOF CONTENTS

Please read this Privacy Policy carefully so that you understand our online privacy practices regarding:

1) INFORMATION WE COLLECT AND HOW WE COLLECT IT
2) HOW YOUR INFORMATION WILL BE USED
3) HOW YOU CAN CORRECT INFORMATION
4) OUR E-MAIL POLICIES
5) SECURITY AND PROTECTION OF YOUR INFORMATION
6) HOW TO CONTACT US

1) INFORMATION WE COLLECT AND HOW WE COLLECT IT

The information we gather on our site falls into two categories: (1) tracking information collected as you navigate through our website and mobile apps, and (2) personal information you supply when you register or subscribe:

Tracking Information

Tracking information is collected and stored whenever a request is made for any page or image on our servers. This information can be analyzed and presented in the aggregate or organized by user sessions. We use it for analysis and reporting on site activity. For example, we may want to know how long the average user spends on our site, or which pages or features get the most attention.

Personally Identifiable Information

To use certain features on our site, we ask you to register and subscribe. When you register, we collect personally identifiable information about you such as your name, mailing address, e-mail address, telephone number, user name, password, and other information about your interest in our site and services. In addition, when you subscribe, we collect credit card details necessary for our billing process.

A Note on Cookies

A “cookie” is a small amount of data that is sent to your browser from a web server and is sometimes stored on your computer’s hard drive, although not always. Our site uses cookies primarily for features available only to logged in users, but also for things like remembering that we’ve shown you a particular message and not to show it again. For logged in users, our cookies contain unique numbers that allow our site to recognize your computer as you move about our site during a session or period of use. These cookies are necessary for our site to work properly. For example, cookies allow us to remember that you are logged in when you move from between pages on the site.

The help function on most browsers contains information on how to set your browser to notify you before accepting cookies or to disable cookies entirely. However, if you don’t accept cookies, you won’t be able to use any feature that requires registration or subscription.

ARTFIRST, along with third-party vendors, Google and Facebook, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Facebook cookie) together to inform, optimize, and serve ads based on past visits to our website.

To opt-out of receiving advertising like this from Google, you can manage these settings by visiting the Google Ads Preferences Manager

For more information on our cookie use and policy see our full Cookie Policy

2) HOW YOUR INFORMATION WILL BE USED

ARTFIRST uses personally identifiable information in a limited number of ways, in general falling into the following categories:

Our Communications Features

Our site and mobile apps offer users the ability to forward along objects of interest to others, and in some cases to communicate with an auction house concerning an object offered in an upcoming auction. In order to facilitate this communication, a registered user’s email of record must be accessed.

Communications with Our Artists, Customer Support, and Promotional E-mail

From time to time, it may be necessary to notify subscribers of impending event cancellations, account or credit card issues, transactions completed, and in the case of registered users terms agreement or policy changes. While such communication will typically be conducted through email, as appropriate, mail or phone may also be used. We may also use your personal information to send you e-mail newsletters and other promotional emails about services and products that we believe may be of interest to you.

Compliance with Legal Process

We may disclose personal information if we are required to do so by law, or in good faith believe that such action is necessary to: 1) comply with the law or with legal process; 2) protect and defend our rights and property; 3) protect against misuse or unauthorized use of ARTFIRST.ro data; or 4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).

Compelled disclosure

Note: ARTFIRST may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements

Sharing Your Personally Identifiable Information

In some instances, we use third party companies to help us provide our products and services to you, like a shipping company that delivers a package or an e-mail delivery service that sends out our e-mails or e-newsletters. In those instances we need to share your information with them. We require that those companies use the information only to deliver our product or service.

ARTFIRST will share some or all of your personal information with another business entity should we plan to merge with or be acquired by that business entity. In the event that such a combination occurs, we will require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information will be used contrary to this policy, you will receive prior notice in as provided in Section 2 above.

If it is clear from the information that you provide us that you are a member of the antiques, art, auction or related trades we may, in our sole discretion list you in directories, or other areas of our site, and may use the name of your firm and your relationship to us in marketing or advertising on our site, or in our promotional materials, paid advertising, or other media in order to promote our services. We will not display the content of your email submissions about our services as testimonials for promotional purposes without your express permission.

Onward Data Transfer Liability

In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US Privacy Shield and Swiss-US Privacy Shield, ARTFIRST is potentially liable.

General Data Protection Regulations (GDPR)

Effective May 25, 2018 EU Data Subjects, or Users will have new rights relative to Information one of which is greater awareness of our use of data from Users. While our use of data for all global users is the same, and described above and in in our GDPR policy amendment, the actions and rights of objection and arbitration are as set for by prevailing local laws. Please see the GDPR amendment for more information specified in the manner compliant with the EU GDPR.

3) HOW YOU CAN CORRECT INFORMATION

Except for tracking and aggregated information, or as outlined in the section 5) below on Security and Protection of Your Information, all your information is available to you for review and update by emailing us at contact@artfirst.ro. Effective May 25, 2018, our handling of information related to EU Data Subjects is regulated by the GDPR, our observance of which is outlined in our GDPR addendum.

4) OUR E-MAIL POLICIES

Account and Services Related E-mail

We will send you e-mails relating to your account. These include order confirmations, renewal/expiration notices, and credit card problem notifications.

If you send artists emails with a question, or requesting more information about an object, the auction house may respond by email at your registered email address. Similarly, if you send emails to others to forward objects on ARTFIRST, the recipients of those emails may respond by email to your registered email address.

If we offer, and you have registered for upcoming auction alerts or online discussions, you may receive emails specific to your participation online.

eMail Newsletters

We may offer eMail newsletters. If you do not wish to receive newsletters, you can either (1) follow the ‘unsubscribe’ instructions located near the bottom of each newsletter, or (2) emailing us directly from the email address you want to unsubscribe and mentioning ‘OPT OUT’ in the subject line.

Promotional eMails

We may eMail you messages that we think may be of interest to you about other products and services. You can choose not to receive additional future messages by either (1) following the ‘unsubscribe’ instructions located near the bottom of each e-mail, or (2) emailing us directly from the email address you want to unsubscribe and mentioning ‘UNSUBSCRIBE’ in the subject line.

5) SECURITY AND PROTECTION OF YOUR INFORMATION

We take very seriously our commitment to protect your personal information. To this end, we maintain a secure process to collect, transmit and store your personally identifiable information including credit card details.

Subscribers can review or change their registration, subscription or credit card information at any time through the secure My ARTFIRST page with the exception of card number and card verification number which cannot be viewed or changed by any means.

We urge you to keep your password in a safe place and not to divulge it to anyone. Also remember to sign off your account and close your browser window when you have finished your visit. This ensures that others cannot access your account, especially if you are sharing a computer with someone else or using a computer in a public place.

As a dynamic and growing Site, ARTFIRST may contain links to other sites that are not under our control. Those Web sites have their own policies regarding privacy. For your own protection, you should review their policies upon visiting these other sites to make sure they meet your expectations of privacy.

DATA FROM THE EUROPEAN UNION AND SWITZERLAND & PRIVACY SHIELD

ARTFIRST complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the Romanian Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland, respectively. ARTFIRST has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page once it is available, please visit https://www.privacyshield.gov.

In compliance with the EU-US and Swiss-US Privacy Shield Frameworks, ARTFIRST commits to resolve complaints about your privacy and our collection or use of your personal information. Persons from the European Union and Switzerland who have inquiries or complaints regarding this privacy policy should first contact us via email at: contact@artfirst.ro

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. EFFECTIVE MAY 25, 2018 THE GENERAL DATA PROTECTION REGULATIONS TAKE EFFECT, GOVERNING THE PRIVACY RIGHTS OF DATA SUBJECTS ACCESSING OUR SERVICES FROM WITHIN THE EUROPEAN ECONOMIC AREA. FOR MORE INFORMATION ABOUT PRIVACY AS IT RELATES TO THE GDPR FOR EU USERS PLEASE READ OUR GDPR PRIVACY POLICY ADDENDUM.

6) HOW TO CONTACT US

If you feel that we have not followed our privacy policy, or if you have any questions or concerns about the ARTFIRST Privacy Policy or its implementation, please contact us by email at: contact@artfirst.ro, or by mail at:

ARTFIRST, SRL
Attention: Privacy Officer
str. Nucului, nr. 6, bl. V-106, sc. 2, et. 3, ap. 41, Sector 3

7) ONLINE PLATFORM PRIVACY POLICY

This ARTFIRST Online Platform (“Web Site” or “Mobile Apps”) is published and maintained by ARTFIRST. If you are a registered user of ARTFIRST, the ARTFIRST Privacy Policy governs your agreement with ARTFIRST with respect to ARTFIRST collection, use, storage, and disclosure of your personal information.

By registering to bid in the ARTFIRST auction on the ARTFIRST Online Platform, you consent to and accept the terms of this Privacy Policy as they may be amended from time to time, and you consent to ARTFIRST collection, use, disclosure and retention of your personal information on the terms set forth in this Privacy Policy. As we update and expand our services, this Privacy Policy may change, so please review this Privacy Policy before registering to bid, accessing and/or participating in any ARTFIRST auction conducted on the ARTFIRST Online Platform. This Privacy Policy is incorporated into our Terms and Conditions posted online at http://www.artfirst.ro/terms, which governs your relationship with ARTFIRST when you access ARTFIRST auctions through the ARTFIRST Online Platform.

Marketing Preferences

You have the right to “opt in” and “opt out” of certain of our uses of your Personal Information and may change your preferences regarding such uses at any time. For example, you may have the opportunity to elect whether or not to receive commercial correspondence from us related to certain auctions, sales and other services. You may also opt-out of ARTFIRST promotional e-mails by clicking on the opt-out link within the e-mail you receive from us, or of ARTFIRST postal mailings by following the directions in such mailings. Please be aware that it may take up to 10 business day(s)for ARTFIRST to update your preferences. During that time, you may continue to receive messages from us.

Please understand that if you opt-out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us on the ARTFIRST Online Platform.

Do we share Personal Information and Web Site Usage Information with others?

ARTFIRST does not sell, lease or give your Personal Information we receive relating to the ARTFIRST Online Platform to any other company, except as otherwise described herein.

Service Providers

ARTFIRST may use third party partners to provide products or services to you. We, may, when necessary to do so, share your Personal Information with our affiliates, service providers or other third parties that provide products or Services for or through this Web Site or for our business purposes (such as Web site or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies, and other similar service providers that use such information on our behalf). These third party partners are obligated to protect the security and confidentiality of your information.

Aggregate Statistics

We may disclose aggregate statistics regarding user behavior as a measure of interest in, and use of, this Web Site and e-mails to third parties in the form of aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user. Aggregate statistics we disclose in this manner do not contain your Personal Information.

Legally Compelled Disclosures

We may disclose user information to government authorities or other third parties when we believe such disclosure is required by law. We may also disclose user information as necessary to enforce the ARTFIRST Terms and Conditions, in connection with investigations, or when we believe disclosure is necessarily incident to the provision of ARTFIRST services or to the protection of the rights, property or safety of ARTFIRST or others.

Business Transfer

ARTFIRST regards its databases of customer information (which will include your Personal Information) as a valuable asset. In the event that ARTFIRST, or substantially all of its or their assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, such databases containing Personal Information may be one of the transferred assets. In addition, such a transfer may mean that your Personal Information is transferred to countries outside the European Economic Area (“EEA”) even if you are located within the EEA. By using the Services you consent to such transfer of your Personal Information.

Your Access Rights

You may review and edit the Personal Information that is stored by ARTFIRST by contacting ARTFIRST via the email address at the end of this policy. We will endeavor to respond to your request as soon as practicable. Before we are able to provide you with any information, correct any inaccuracies or delete any information, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. In addition, you have the right to request access to the Personal Information that we hold about you at any time.

Security

ARTFIRST will take reasonable steps to protect the security and integrity of the Personal Information ARTFIRST shares with us, including by making your Personal Information available to our employees and agents only on a need-to-know basis. However, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

If you contact us by e-mail or a “contact us” or similar feature on our Web Site, you should be aware that your transmission might not be secure. A third party could view information you send by these methods in transit.

We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties.

In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to do so as promptly as possible under the circumstances, and, if we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification.

Phishing

With identity theft a continuing problem, it has become increasingly common for unauthorized individuals to send e-mail messages to consumers, purporting to represent a legitimate company such as a bank or on-line merchant, requesting that the consumer provide personal, often sensitive information. Sometimes, the domain name of the e-mail address from which the e-mail appears to have been sent, and the domain name of the web site requesting such information, appears to be the domain name of a legitimate, trusted company. In reality, such sensitive information is received by an unauthorized individual to be used for purposes of identity theft. This illegal activity has come to be known as “phishing.”

ARTFIRST will never request your password or social security number via e-mail. If you receive an e-mail or other correspondence requesting that you provide any sensitive information (including your password for the Platform or your credit card information) via e-mail or to a web site that does not seem to be affiliated with ARTFIRST, or that otherwise seems suspicious to you, please do not provide any information in response to the request, and report such request to us.

Changes to this Privacy Policy

ARTFIRST reserves the right to change or update this Privacy Policy, or any other of our policies or practices, at any time, and will notify users of this Web Site by posting such changed or updated Privacy Policy on this Web Site, or by otherwise making such changed or updated Privacy Policy accessible to affected users. Any changes or updates will be effective immediately upon posting to this Web Site, or upon such other notice by us. Under certain circumstances, we may also elect to notify you of changes or updates to our Privacy Policy by additional means, such as by sending you an e-mail.

If you have any questions or comments regarding our privacy practices or wish to verify or change the information in our files, you may contact us at contact@artfirst.ro. You may also send mail to us with any comments, questions or concerns at:

ARTFIRST SRL
str. Nucului, nr. 6, bl. V-106,sc. 2, et. 3, ap. 41, Sector 3

This policy document 1.00 was last revised effective Aug 11, 2018.