This policy was last updated May 2018
Cincala Art Advisory ("CAA") believes that protecting the privacy of your personal information is important, and we are committed to maintaining the privacy of any such information in our possession. We may, in the course of our business, collect information from you, including your name and email address, in order to provide you with services. Examples of such data may include: contact information (such as name, postal and email address, and telephone number); information about your transactions with us; signatures; and other personal information you provide to us, such as through emails, agreements and other documents (that may include Social Security numbers, tax ID numbers or other government-issued identification numbers, to the extent permitted by applicable law), and other forms and documents you provide or that are provided by others on your behalf.
We will use your personal data in the course of business where it is in our legitimate interests to: respond to requests; send information about us that may be of interest; provide or manage our services; send newsletter and other communications; perform accounting, auditing, billing and reconciliation activities and other internal functions; protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities; conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms; and for other purposes required or authorized by law. We also may use the personal information obtained in other ways for which we provide specific notice at the time of collection.
We do not sell or otherwise share personal information about you, except as described in this notice. For those third parties with which we may share data in the course of providing agreed-upon services to you (e.g., auction houses, insurance specialists, logistics firms such as shipping companies), we do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements. In addition, we may share your personal information with your authorized representatives, as instructed.
CAA also may disclose information about you (1) if CAA is required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government entities based on a lawful disclosure request; (3) to establish, exercise or defend CAA's legal rights; (4) when CAA believes disclosure is necessary or appropriate to prevent harm or financial loss; (5) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (6) otherwise with your consent. We reserve the right to transfer personal information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution or liquidation).
Security and Retention
CAA will take reasonable steps to protect your personal data against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification, regardless of the format in which it is held. To the extent permitted by applicable law, we retain personal information about you as long as: (i) it is needed for the purposes for which we obtained it, in accordance with the provisions of this notice; or (ii) we have another lawful basis for retaining the data beyond the period for which it is necessary to serve the original purpose for collecting the data.
This notice and the policies described in this notice may be updated periodically and without prior notice to you to reflect changes in CAA’s privacy practices or in applicable law, rules or regulations. The date as of which this notice was last updated appears at the beginning of the notice.