Privacy Policy

STAIR
PRIVACY POLICY

Introduction
Like most businesses, STAIR holds and processes a range of information about its clients and other persons who may be interested in STAIRS’ services. STAIR closely guards the privacy of its clients, including its consignors, sellers, buyers, bidders and visitors to its website and its galleries in Hudson, NY.
This privacy notice applies to STAIR and explains the type of information that we process, why we are processing it and how that processing may affect you.
We may update this privacy notice from time to time and will post any revised notice on this webpage. Where appropriate, we may notify you by email or by a notice on our website that our privacy notice has changed, but we recommend that you check this page regularly. Any changes will be immediately effective on posting.
1. How and when we collect your personal data
2. What personal data do we process and why
3. Who gets to see your personal data
4. How long do we keep your personal data
5. How do we keep your personal data secure
6. Other rights
7. Contact Information

  1. How and when we collect your personal data

Collection directly from you in response to our request
Most of the personal data we process about you comes directly from you (whether face to face, over the telephone, on a paper form, by email or online). For example:
• when you register to bid in an auction, express interest in purchasing property, agree to sell your property through STAIR or ask us to perform a valuation;
• when you express an interest in certain types of property to one of our staff or representatives;
• when you make an appointment with one of our staff, specialists or representatives;
• when you complete a mailing list form, sign up on stairgalleries.com, subscribe to our catalogues, newsletters or other publications;
• when you sign up on stairgalleries.com to receive our newsletter or complete your profile in your online account;
• when you attend a STAIR event.

Automatic collection when you telephone bid, call our offices, visit our premises or our website or attend a digital event
Your image may be collected by closed-circuit video security system when you attend our premises. We use CCTV at our galleries and offices for the protection of our staff, our visitors and the property on our premises.
• As you interact with our website, we collect data through cookies and other similar technologies together with technical data about your equipment, browsing actions and patterns. We may also receive technical data about you if you visit other websites employing our cookies.

Collection of data from other sources
We may obtain information about you and/or the property you own or wish to collect from other sources. For example:
• when someone informs us that you are authorized to bid on their behalf at STAIR or collect their property.
• when someone introduces you to us.
• when we research artwork or other objects and we find information about you in sources such as newspaper articles, exhibition catalogues, public auction results and other publicly available sources, or one of our contacts gives us feedback in relation to objects or persons they have been told about.
• Technical data from analytics providers, advertising networks, social media platforms, and similar applications.
• Identity, contact data and other information from publicly available sources such as company and electoral registries and companies that perform identification, anti-fraud and credit checks or screening for sanctions, anti-money laundering and/or negative media purposes.

Aggregated and special categories of data
We may collect, use and share aggregated data, such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect special categories of personal data unless it is necessary for us to do so to enable us to provide services or access.

  1. What personal data do we process and why
    We have set out below the types of personal data that we process, the purposes for which we use it and the legal grounds on which we process it.
    Purpose
    To provide you with requested services (for example, bidding, selling, valuations, storage, shipping, catalogue subscription, restoration, expertise)

Examples of personal data
(Please note that the list is not exhaustive)
• name, title, and contact details (including email address, postal address, telephone numbers)
• your bank account details (if we need to pay you) or payment card details or bank transfer receipt (if you need to pay us)
• the person or organization who has introduced you, and any fee they receive
• details of the property to which the services relate
• nature of the services including contractual terms
• details of your insurance if your property remains at your risk
• financial information
records of your communications with us (including bidding instructions recorded over the telephone or online bidding logs)

Legal grounds for processing
Performance of a contract

Purpose
To evidence our compliance with legal requirements, (for example, knowing our clients and preventing money-laundering, payment of taxation and customs duties, anti-discrimination) and cooperate with regulators, enforcement authorities and the courts

Examples of personal data
• your date of birth, identification documents (including photo) proof of address documents and the results of identification verification checks
• the nature of your connection to an organization (for example, your job title and whether you are a director, shareholder, partner), your source of wealth and whether you are a politically exposed person (PEP) or a family member or close associate of a PEP
• details of your past transactions (including any tax paid or tax withheld, and the source of your funds) and/or shipments (including any permits obtained or duties paid)
• any requirements relating to STAIR obligation to make reasonable adjustments to accommodate a disability or otherwise meet your specific needs (This could include sensitive personal data.)
• any information relating to a dispute or legal proceeding
Legal grounds for processing
Compliance with a legal obligation

Purpose
To keep you, our staff, and property on our premises secure
Examples of personal data
• CCTV images
• Contact details
Legal grounds for processing
Legitimate Interests

Purpose
To provide you with details about upcoming auctions, other events or types of property that interest you, and STAIR other services
Examples of personal data
• your name, email address and/or postal address
• your marketing and communication preferences
Legal grounds for processing
Legitimate Interests (for clients who have previously requested or received services)
Consent (for clients who have not requested or received services but have signed up to receive STAIR newsletter, at an event, by talking to a member of staff)

Purpose
To create and maintain records on art objects to assist us (and, in the case of our public records including our online lot pages and online and printed catalogues and the wider public) with checks on authenticity, provenance, title and object value and prevent fraud, theft or other unlawful activities
Examples of personal data
• your interest in, possession of, or ownership (historic or current) of any relevant art object, or similar object
• allegations of fraud, theft or other unlawful activities relating to an object connected to you
• communications with the police, courts, regulators or other government or law enforcement authorities in relation to you or your object
Legal grounds for processing
Legitimate Interests
Public interest

Purpose
To monitor the performance of our website and to personalize and improve your user experience
Examples of personal data
• Technical data including your internet address, your login data, your browser type, version and operating system, time zone setting and location, browser plug-in types and versions, data obtained from cookies, web logs and other similar technologies that monitor the use of our website and deliver more appropriate advertisements on or beyond our website
• the resources you access on your STAIR account and our wider website including browsing actions, online bidding activity.
Legal grounds for processing
Legitimate Interests

Purpose
To monitor your use of our services, train our staff and improve your client or user experience
Examples of personal data
• your complaints, opinions, responses to our surveys or market research
Legal grounds for processing
Legitimate Interests

  1. Who gets to see your personal data
    We do not transfer your personal data to organizations who wish to use it for their own marketing promotions or other purposes. Your personal data will only be shared with other organizations where it is necessary to enable us to provide you with the services you have requested (for example: we may transfer your data to our bank, payment card acquirers, shippers, warehouses, insurers, experts who help us authenticate or value property, companies that perform identification, anti-fraud and credit checks or screening for sanctions, anti-money laundering and/or negative media purposes, or a mailing house for direct marketing fulfillment). We may also be required by subpoena, court order or other legal process to disclose certain personal information about you with third parties that are acting on proper legal authority, including law enforcement and government agencies.
    We may need to retain and disclose certain information about you to appropriate agencies to conduct anti-money laundering and trade sanction checks, to assist with fraud and crime prevention and detection and to meet our health and safety obligations. We may also need to disclose this information to our banks, insurers or auditors for the purposes of evidencing STAIR compliance with anti-money laundering, sanctions and other relevant regulations, or to enable the bank, insurer or other regulated firm to complete its own due diligence in connection with you or your transactions.
  2. How long is your personal data retained
    We will retain your personal data for as long as is necessary to provide the relevant services, maintain business records to satisfy tax, legal and other regulatory requirements, protect and defend against potential legal claims and as long as the data is relevant to our legitimate business interest and the public interest.
  3. How we keep your personal data secure
    STAIR protects your personal information using a variety of security technologies and procedures. Please be aware that no security system is impenetrable, and we cannot guarantee that your personal information is entirely safe from unauthorized intrusion or access. You remain responsible for the security of your username and password and any information that you transmit to us.
    In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we will notify you and any applicable regulator of a breach where we are legally required to do so. You consent to our use of your e-mail address as a means of such notification.
  4. Other rights
    Rights for California residents

Under California law, California residents may request certain information with respect to any personally identifiable information that may be shared with third parties for direct marketing purposes. If you are a California resident and would like to request such information, please see Contact Information below.

  1. Contact Information
    If you have any questions, concerns, suggestions or complaints relating to the processing of your personal data please contact us atfeedback@stairgalleries.com.
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