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Home / GDPR – 2018

VELVENOIR PRIVACY POLICY UPDATE - MAY 25; 2018

We embrace these changes and have made a number of updates to our Privacy Policy, to comply with the transparency requirements under GDPR. We have also taken this opportunity to implement GDPR controls as our baseline standard for all our operations, worldwide.

PRIVACY POLICY

This Privacy Policy statement is made by DLS SCHAFER GMBH / VELVENOIR  consisting of all the entities listed here (collectively, “VELVENOIR”, “we”, “us” or “our”) and is effective as of 25th May 2018. It applies to all our divisions: VELVENOIR, THE V AGENCY, VELVENOIR BLUE CHIP BROKERAGE and CURATED by VELVENOIR.

OUR COMMITMENT TO YOU

We ask for only the least amount of information necessary, gathering only what we believe is essential for doing business, or for the specific transaction at hand. We let customers know the information we have on them and allow them to opt out of specific engagements. But, by far, our biggest commitment is that we do not make a single dollar from advertising revenue. This means we avoid the fundamental conflict of interest between gathering customer information and fueling advertising revenue and the unavoidable compromises in customer privacy that it brings.

The goal of this policy is to make explicit the information we gather on our customers and users, how we will use it, and how we will not. This policy is unfortunately longer than we would like, but we must unambiguously address all the relevant cases. We will try and keep the language simple and direct as much as possible.

Information WE collect

We collect information about you only if we need the information for some legitimate purpose. VELVENOIR will have information about you only if (a) you have provided the information yourself, (b) VELVENOIR has automatically collected the information, or (c) VELVENOIR and its team members has obtained the information from a third party or social media platforms. Below we describe the various scenarios that fall under each of those three categories and the information collected in each one.

Information that you provide us

i. Newsletter signup : When you sign up for our newsletter we ask for information like your name and email address. After signing up, you will have the option to opt out from every single newsletter.

ii. Event registrations and other form submissions: We record information that you submit when you (i) register for any event, including webinars or seminars, (ii) subscribe to our newsletter or any other mailing list, (iii) submit a form in order to receive a tailored art proposal, or other materials, (iv) participate in contests or respond to surveys,  or to contact VELVENOIR for any other purpose.

iii. Payment processing : When you buy something from us, we ask you to provide your name, contact information, and credit card information or other payment account information. When you submit your card information, we store the name and address of the cardholder, the expiry date and the last four digits of the credit card number. We do not store the actual credit card number. For quick processing of future payments, if you have given us your approval, we may store your credit card information or other payment information in an encrypted format in the secured servers of our Payment Gateway Service Providers.

iv. Testimonials : When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial. You will be given an opportunity to review and approve the testimonial before we post it. If you wish to update or delete your testimonial, you can contact us at info@velvenoir.com.

v. Interactions with VELVENOIR: We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.

Information that we collect automatically

i. Information from browsers, devices and servers : When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites.

Information that we collect from third parties

i. Referrals: If someone has referred any of our artworks or services to you through any of our referral programs, that person may have provided us with your name, email address and other personal information. You may contact us at any time via info@velvenoir.com  to request that we remove your information from our database. If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us.

iii. Information from our art consultancy partners and other partners.  If you contact any of our partners and VELVENOIR consultants, or otherwise express interest in any of our artworks or services to them, the reselling partner may pass your name, email address, company name and other information to VELVENOIR. If you register for or attend an event that is sponsored by VELVENOIR, the event organizer may share your information with us. VELVENOIR may also receive information about you from review sites if you comment on any review of our products and services, and from other third-party service providers that we engage for marketing our products and services.

iv. Information from social media sites and other publicly available sources : When you interact or engage with us on social media sites such as Facebook, Twitter, Linkedin, Google+ and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our products, or better understand user reactions and issues. We must tell you that once collected, this information may remain with us even if you delete it from the social media sites. VELVENOIR may also add and update information about you, from other publicly available sources.

Legal bases for collecting and using information

Legal processing bases applicable to VELVENOIR : If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of VELVENOIR or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.

Withdrawal of consent : Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.

Legitimate interests notice : Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.

Your choice of information we use

Opt out of non-essential electronic communications : You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails.

Disable cookies : You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.

Optional information : You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites.

Who we share your information with

At VELVENOIR we have access to the information covered in Part I. We do not sell any personal information. We share your information only in the ways that are described in this Privacy Policy, and only with parties who adopt appropriate confidentiality and security measures.

Employees and independent contractors : Employees and independent contractors of VELVENOIR have access to the information covered in Part I on a need-to-know basis. We require all employees and independent contractors of VELVENOIR to follow this Privacy Policy for personal information that we share with them.

Third-party service providers : We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.

Retention of information

We retain your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted or required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

Data Protection Officer

We have appointed a Data Protection Officer to oversee our management of your personal information in accordance with this Privacy Policy. If you have any questions or concerns about our privacy practices with respect to your personal information, you can reach out to our Data Protection Officer by sending an email to admin@velvenoir.com or by writing to: Data Protection Officer, VELVENOIR, Alexandra Schafer, Auerspergstraße 37, 5020 Salzburg, Austria – Europe.

Locations and international transfers

We share your personal information and service data within VELVENOIR. By accessing or using our products and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the United States of America, the European Economic Area (EEA) and other countries where VELVENOIR and its consultants are operating. Such transfer is subject to a group company agreement that is based on EU Commission’s Model Contractual Clauses.

Data processing addendum

To enable you to be compliant with the data protection obligations under the General Data Protection Regulation, we are prepared to sign a Data Processing Addendum (DPA) that is based on Standard Contractual Clauses. You can request a DPA from VELVENOIR by emailing info@velvenoir.com.  Once we get your request, we’ll forward the DPA to you for your signature.

Do Not Track (DNT) requests

Some internet browsers have enabled ‘Do Not Track’ (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don’t wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.

External links on our websites

Some pages of our websites may contain links to websites that are not linked to this Privacy Policy. If you submit your personal information to any of these third-party sites, your personal information is governed by their privacy policies. As a safety measure, we recommend that you not share any personal information with these third parties unless you’ve checked their privacy policies and assured yourself of their privacy practices.

Payments at CURATED by VELVENOIR

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Stripe
Their Privacy Policy can be viewed at https://stripe.com/us/privacy

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

Social media widgets

Our websites include social media widgets such as Facebook “like” buttons and Twitter “tweet” buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website, and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.

Disclosures in compliance with legal obligations

We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements.

Enforcement of our rights

We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.

Business Transfers

We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honour our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.

Compliance with this Privacy Policy

We make every effort, including periodic reviews, to ensure that personal information you provide is used in conformity with this Privacy Policy. If you have any concerns about our adherence to this Privacy Policy or the manner in which your personal information is used, kindly write to us eva@velvenoir.com We’ll contact you, and if required, coordinate with the appropriate regulatory authorities to effectively address your concerns.

Notification of changes

We may modify the Privacy Policy at any time, upon notifying you through a service announcement or by sending an email to your primary email address. If we make significant changes to the Privacy Policy that affect your rights, you will be provided with at least 30 days’ advance notice of the changes by email to your primary email address. If you think that the updated Privacy Policy affects your rights with respect to your use of our products or services, you may terminate your use by sending us an email within 30 days. Your continued use after the effective date of changes to the Privacy Policy will be deemed to be your agreement to the modified Privacy Policy. You will not receive email notification of minor changes to the Privacy Policy. If you are concerned about how your personal information is used, you should check back at this page periodically.


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