This Policy covers information that you give us when you register or purchase something from us or consign art work or other goods to us, register for or attend any of our live events around the world, visit or register for any of our New San Cai branded websites or apps, request a catalog, sign up for any of our print or online publications or newsletters or publish information on New San Cai pages on social media platforms. We will publish a link to the Policy at the bottom of online properties to which it applies and as often as possible, will include its URL on paper forms to which it is applicable.
How New San Cai collect information about you
Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified. We will collect personal information from you directly (e.g. when you contact us), information we collect about you from other sources and information we collect automatically from you, as described below:
Information we collect directly from you
The categories of information that we collect directly from you are: Personal details (e.g., name, date of birth), contact details (e.g., phone number, email address, postal address), transaction information (e.g., bidding records, shipping details, information about items you purchase), limited financial information (e.g., tokenized payment information in connection with your purchases, wire instructions), username and password, and identification information.
We rely on the information you provide to us or that we collect or observe about your individual interactions with us. For example, if you attend a live event, participate in one of our sales events, become a client, or register online. If you have registered with us online, we use data collection technologies to collect information that indicates your individual interests in our websites, online platforms and apps, and your response to our emails and marketing campaigns.
Information we collect from other sources
We may add public information about you from external sources, including social media sites. The categories of info we collect about you from other sources are your public profile information, family relationships, and organizational affiliations. We may work to expand our customer base by acquiring names, contact data, financial information, affiliations, and demographic information from other sources such as private companies, public registers, and social media sites.
We may make video recordings of our events, gallery spaces, and certain live events.
Information we collect automatically
We may use common data collection technologies as you visit our websites or apps or interact with our emails:
– Our logs gather date, time, information about your browser and system or device configuration, information about how you interact with our digital properties, and an IP address for all visitors to our sites. We use this information for our internal security purposes, for trend analysis and system administration, and to gather general information about our audiences and their geographic locations.
– In general, our app will funnel data you provide about yourself. For example, registration or artwork data, back to our data bases and systems. An app may however, rely on other data collection technologies to recognize the device you use for viewing and personalize your experience. If our app relies on additional data collection technologies that collect or use data about individual users, we will include additional notice either within the app or in a policy that accompanies it.
– We also use and allow certain other companies to use technologies that are similar to cookies (for example pixels and gifs) when we send you emails. This helps support the delivery of Internet-based content and advertisements to you.
The way we analyse personal information for advertising and marketing purposes and for client development, risk assessment, or fraud prevention may involve profiling, which means that we may process your personal information using software that is able to evaluate your personal aspects and predict risks or outcomes. For example, we may use the information we collect (e.g., bidding information, browsing history, and consignment history) to infer your interests. And we may use those inferences to support automated decisions about the content, recommendations, and offers we present to you on our digital properties. We may use automated tools to flag for further review suspicious activities associated with our digital services (e.g., multiple logins from different locations within a short period of time or activities associated with suspicious IP addresses). These automated activities will not, in themselves, have legal or similar effects for you.
How New San Cai uses information about you
New San Cai uses data about you for the following purposes:
– manage and assure the integrity of our services.
– fulfill your orders, facilitate artwork sales, provide the services, publications, catalogs, and information you request, and manage your account, enquiries and requests and to manage your relationship with us.
– send you information about upcoming events and content that you may be interested in.
– improve and personalize our website and services.
– expand our online audiences.
– provide, maintain, and protect our digital offerings.
– protect against risk of fraud by clients.
– protect and defend our rights and property, you, or third parties.
– comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies.
– use information for any other purpose that we tell you about specifically when you register or provide data about yourself to us.
When New San Cai may disclose information that identifies you
New San Cai may only disclose or transfer relevant data that identifies you to other companies or entities only as follows:
– business partners and vendors that work on our behalf to provide services such as item shipments, mailings, customer account and technology support, secure payment processing, fraud prevention, digital marketing management, and data storage.
– our online partners.
– consigners and others as needed to facilitate a consignment.
– organizations we partner with to host events.
– other companies affiliated with New San Cai for marketing, business development purposes and internal reporting.
– law enforcement or other entities that present valid legal process or in our discretion, unless otherwise prohibited by law, to protect human safety, our rights, or the rights of others.
– meet certain legal compliance requirements for example, under AML (anti-money laundering) laws, or customs laws and regulations.
– part of a sale, merger, liquidation, or transfer of our business assets.
– disclose information about you to companies not affiliated with New San Cai.
You have a choice about and control over:
– receiving marketing messages from us. We may contact you by email, text, or SMS messaging.
– you may also stop email marketing by using the “opt out,” or “unsubscribe” mechanism at the bottom of our email marketing messages. In most cases, we will give you a choice about stopping just one kind of email or opting out of all email marketing from us.
– if you have provided data about yourself to a member of New San Cai and reside in the European Union (EU) you have the legal right to ask us not to process that personal data about you for marketing purposes and to revoke your consent at any time. To make such a request, please contact us.
– whether your account is up to date. You may review and edit the Personal Information that is stored in your user account on our website (e.g., your passwords and other contact information) by visiting the “Profile” area of your account on our website or by contacting New San Cai 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.
Information security and storage
New San Cai is a global company. We receive data collected locally by members of the New San Cai and collect data online directly from individuals in countries around the world. We may process that data on servers globally.
We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Please be aware, though, that no security measures are perfect or impenetrable. You remain responsible for protecting your username and password and for the security of information you transmit to us over the Internet.
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
– maintain business records for analysis and/or audit purposes.
– comply with record retention requirements under the law or other relevant legal or regulatory requirements.
– defend or bring any existing or potential legal claims.
– deal with any complaints regarding the services.
– preserve historical records of transactions and property.
We will delete your personal information when it is no longer required for these purposes.
Our websites are directed to adults, including young adults. They are not directed to children, particularly under those under the age of 13. We do not accept them as clients or knowingly collect data about them.
Our websites may contain links to other websites not owned or controlled by New San Cai. New San Cai is not responsible for their practices or content.
How to contact us
New San Cai
Suite 700, 100 Wiltshire Boulevard
Santa Monica CA 90401, USA
What is the legal basis on which New San Cai relies to process your data?
On some occasions, New San Cai processes your data with your consent (e.g., when you agree that we may place cookies, or if you ask New San Cai to send you information about upcoming events).
On other occasions, New San Cai processes your data when we need to do this to fulfill a contract with you (e.g., for billing purposes) or where we are required to do this by law (e.g., where we have to fulfill anti-money laundering requirements). If it is mandatory for you to provide data for these purposes, we will make this clear at the time and will also explain what will happen if you do not provide the data (e.g., that we will not be able to process a bid at auction).
New San Cai also processes your data when it is our legitimate interests to do this and when these interests are not overridden by your data protection rights.
For example, New San Cai has a legitimate interest in ensuring the security and integrity of our auctions, in learning about the interests and preferences of our current and prospective clients, in developing new business opportunities, in maintaining accurate business and provenance records, and in ensuring that our websites and apps operate effectively. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
You may ask New San Cai for a copy of your personal information, to correct it, erase it, restrict our use of it, or to transfer it to other organizations at your request subject to local law. You also have rights to object to some processing and, where we have asked for your consent to process your data, to withdraw this consent. In particular, you have rights to object to direct marketing at any time. Where we process your data because we have a legitimate interest in doing so (as explained above), you also have a right to object to this. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data.
If you would like to discuss or exercise such rights, please contact us at the details above. We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. We will contact you if we need additional information from you in order to honor your requests.
We hope that we can satisfy queries you may have about the way we process your data. We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. However, if you have unresolved concerns and believe that we have not been able to assist with your complaint or concern, you also have the right to complain to data protection authorities.
Changes to this Policy
You may request a copy of this Policy from us using the contact details set out above. We may modify or update this Policy from time to time.
If we change this Policy, we will notify you of the changes by updating this Policy on our website. Where changes to this Policy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g., to object to the processing if you are located in the EEA or Switzerland).
Effective May 25, 2018
Cookies help us to improve our site and to deliver a better and more personalized service, for instance by storing information about your preferences and allowing us to recognize you when you return to our site.
Our sites use the following types of cookies:
These cookies are essential in order to enable you to move around the sites and use their features, such as accessing secure areas of the sites. Without these cookies, services like enabling appropriate content based your type of device cannot be provided.
These cookies collect information about how visitors use the sites, for instance which pages visitors go to most often, and if they get error messages from web pages. All information these cookies collect is aggregated and is only used to improve how the sites work.
These cookies allow the sites to remember choices you make (such as your language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymized, and they cannot track your browsing activity on other websites.
These cookies are used when you share information using a social media sharing button on the sites. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
These cookies are used to deliver advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations, such as advertisers.
Your choices about cookies
We require your consent for cookies to be placed on your device as you visit our sites. You have the right to decide whether or not to accept cookies. However, they are an important part of how our sites work, so you should be aware that if you choose to refuse or remove cookies, this could affect the availability and functionality of the sites.
If you do not want to allow cookies at all, or only want to allow use of certain cookies, please refer to your browser settings.
If you are in the European Union and would like to opt out of third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
In the United States, the Network Advertising Initiative offers a means to opt out of a number of advertising cookies. Please visit http://www.networkadvertising.org/choices to learn more.