Privacy Policy

INTRODUCTION

Welcome to White Cube’s privacy notice.

We respect your privacy and we are committed to protecting your personal information.

This privacy notice applies to all White Cube operations. It explains the type of information that we collect and hold about you and our reasons for doing so, as well as your privacy rights and how the law protects you.

Please use the Glossary to help you understand the meaning of some of the terms used in this privacy notice, such as “data” and “processing”.

We may update this privacy notice from time to time and will post any revised notice on this web page. Where appropriate we may notify you by email or by a notice on our website if there are material changes to our privacy notice.

This version was last updated on 16 May 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This privacy notice is sub-divided under the following headings:

WHO WE ARE
HOW DO WE COLLECT INFORMATION ABOUT YOU?
WHAT PERSONAL INFORMATION DO WE PROCESS AND WHY?
WHO SEES YOUR PERSONAL INFORMATION?
IS YOUR PERSONAL INFORMATION TRANSFERRED OUT OF THE EEA?
HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
WHAT STEPS DO WE TAKE TO KEEP YOUR PERSONAL DATA SECURE?
YOUR LEGAL RIGHTS
CONTACT INFORMATION AND COMPLAINTS
GLOSSARY
CALIFORNIA CONSUMERS AND THEIR PRIVACY RIGHTS

1. WHO WE ARE

White Cube consists of White Cube Limited and several other companies located inside and outside the EEA. The principal operating companies are:

White Cube Limited, a company registered in Jersey at 2nd Floor, Gaspe House, 66 - 72 Esplanade, St Helier, Jersey, JE1 1GH, Channel Islands, under registration no. 123395, whose principal place of business is 144-152 Bermondsey Street, London, SE1 3TQ, which is the primary Data Controller under the applicable EU data protection law, namely the General Data Protection Regulation (EU) 2016/679(the GDPR);

White Cube Hong Kong Limited, registered in Hong Kong at 50 Connaught Road, Central, Hong Kong under registration no. 1629287;

White Cube Inc., registered in the State of Delaware at 251 Little Falls Drive, Wilmington, DE 19808, USA, under registration no. 5870240;

White Cube Paris SARL, registered in Paris at 10 Avenue Matignon, 75008 Paris, France, under registration no. 823 397 690.

White Cube Art Limited, registered at 144-152 Bermondsey Street, London SE1 3TQ under registration number 08971144.

This privacy notice is issued on behalf of the White Cube group, so that when we mention “White Cube”, “we” or “us” in this privacy notice, we are referring to the relevant company in the White Cube group that is responsible for processing your data.

2. HOW DO WE COLLECT INFORMATION ABOUT YOU?

Direct Interactions

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, we collect data from you directly:

when you express an interest in buying or selling an artwork to one of our staff or representatives;
when you attend a White Cube event;
when you visit us at an art fair;
when you purchase an artwork;
when you purchase goods from our shop;
when you subscribe to receive news about upcoming shows and events;
when you ask us to send you information, including about artists and their works; and
when you visit the Website

Your image may be collected by White Cube if you attend our premises; in particular, we use CCTV on our premises, including in our gallery spaces, for the security of our staff, our visitors and the artworks that we exhibit and sell. We may also have staff photographers documenting events.

Collection from other sources

We may also obtain information about you and/or the artworks that you own or wish to buy or sell or collect from other third party sources; for example:

Identity and contact data, when someone introduces you to us (e.g. because they believe an artist or work may interest you);
Identity and contact data, when we research artworks and we find information about you in sources such as newspaper articles, exhibition catalogues, public auction results, or one of our contacts gives us feedback in relation to artworks or persons they have been told about.

We may receive or obtain:

Contact, transaction and financial data from providers of technical, payment and delivery services;
Identity and contact data from publicly availably sources, such as Companies House and the Electoral Register;
Identity and contact data from art platforms such as Artsy;
Usage data (being information about how you use our website and/or about recipients of our mailshots) from third parties, such as Google Analytics.

We also collect, use and share aggregated data, such as statistical or demographic data, for any purpose (Aggregated Data). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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.

Personal data collected through the Website

Among the types of personal data that the Website collects, by itself or through third parties are: trackers; usage data; first name; email address.

You may freely provide your personal data. Usage data is collected automatically when using the Website.

Unless specified otherwise, all data requested by the Website is mandatory and failure to provide this data may make it impossible for the Website to provide its services. In cases where the Website specifically states that some personal data is not mandatory, you are free not to communicate this personal data without consequences to the availability or the functioning of the Website.

You are responsible for any third-party personal data you publish or share through the Website and confirm that you have the third party's consent to provide their personal data to White Cube.

The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the White Cube, in some cases, the personal data may be accessible to certain types of persons involved with the operation of the Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by White Cube. The updated list of these parties may be requested from the White Cube at any time.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

The Website users trackers. To learn more, please consult the Cookie Policy.

3. WHAT PERSONAL INFORMATION DO WE PROCESS AND WHY?

We will only use your personal data when the law allows us to do so.

Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you;
Where it is necessary for our Legitimate Interests, or those of a third party, and your interests and fundamental rights do not override those interests;
Where we need to comply with a legal or regulatory obligation;
With your consent.

The Glossary contains more information about the legal grounds for processing.

We have set out below the types of personal data that we process, the reason for doing so and the legal grounds for processing.

Purpose/activity

Types of personal data

(please note that the list contains examples and is not exhaustive)

Legal grounds for processing

To add you to our database or register you as a new client

Name, title, and contact details (including email address, postal address, telephone numbers)

Performance of a contract (e.g. where performing the contract we are about to enter into with you (upon a sale) will require your contact data to be added to our records)

Legitimate Interests (in the event that you provide us with a business card at an event such that you want us to record your details on our database)

Consent (in the event that you express an interest in White Cube or one of our artists’ artworks and agree to being added to our database)

To provide you with requested goods or services

(for example, sales, storage, shipping, loans, insurance)

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)

Information about the person or organisation who has introduced you, and any fee they receive

Details of the artwork to which a transaction relates

Details of the nature of the services including contractual terms

Performance of a contract

To evidence our compliance with legal requirements (for example, knowing our clients and preventing money-laundering, payment of taxation and customs duties, anti-discrimination)

Your date of birth, identification documents (including photo) and the results of identification verification checks

Records of your past transactions (including any tax paid or tax withheld) and/or shipments (including any permits obtained or duties paid)

Information about any requirements relating to White Cube’s obligation to make reasonable adjustments to accommodate a disability or otherwise meet your specific needs

Any information relating to a dispute or legal proceedings

Compliance with a legal obligation

To photograph and film White Cube’s exhibitions and artist performances

Images and footage of you

Legitimate Interests

To keep you, our staff, and artworks on our premises secure

CCTV images

Legitimate Interests

To provide you with details about White Cube, its upcoming exhibitions, other events or works that may interest you

Name, title, and contact details (including email address, postal address, telephone numbers)

Artistic data such as information about artistic preferences and collections;

Your marketing and
communication preferences

Legitimate Interests (for clients who have previously requested or received services)

Consent (for clients who have not previously requested or received services but have asked online, at an event, or when talking to a member of staff, to receive information from White Cube)

To create and maintain records on artworks to assist with checks on authenticity, provenance and title and to prevent fraud, theft or other unlawful activities

Information about your interest in, possession of, or ownership (historic or current) of any relevant artwork

Allegations of fraud, theft or other unlawful activities relating to an artwork connected to you

Communications with the police, courts, regulators or other government or law enforcement authorities in relation to you or your artwork

Legitimate Interests

Compliance with a legal obligation

Public interest

To collect and recover money owed to us

Name, title, and contact details (including email address, postal address, telephone numbers)

Details of the property to which the debt relates

Financial data

Legitimate Interests (in recovering debts due to us) and performance of a contract

To monitor your use of our services, train our staff and improve your client experience and to manage and develop our relationship with you

Name, title, and contact details (including email address, postal address, telephone numbers)

Your expressions of interest in artists and artworks

Offers of artworks made and your responses

Details of purchases you have made

Information relevant to your opinions and preferences and your collecting habits, which may inform what works to offer to you

Legitimate Interests. As a business, we have a legitimate interest in holding information about clients as relationships often develop over many years and your experience with us is improved if we retain records which help us to understand you and your preferences, including how those may have developed over time.

To host and entertain you at our events

Name, title, and contact details (including email address, postal address, telephone numbers)

Information about those you wish to accompany you to White Cube events

Any dietary requirements (allowing us to ensure that our events are tailored to your needs )

Any details which require us to make specific arrangements for your comfort and enjoyment of our events

Your personal preferences

Your expressions of interest in artists and artworks

Any offers of artworks made and your responses

Details of purchases you have made

Records of invites issued to you and details of your attendance at other events

Legitimate Interests. As a business, we have a legitimate interest in holding information about clients to ensure that you have the very best experience possible at our events.

To arrange your attendance at external events, such as art fairs and events which we host / co host

Name, title, and contact details (including email address, postal address, telephone numbers)

Information about those you wish to accompany you

Any dietary requirements

Legitimate Interests (where you have indicated that you wish to attend an external event, such as an art fair, we have a legitimate interest in sharing your name and contact details with the organiser of that event)

To facilitate a more personalised use of the Website

Trackers, usage data, names and email addresses

Legitimate Interests (in running our business, provision and administration of IT services, network security and the functionality of the Website)

Consent

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting) and to improve the functionality of our website

Information about your computer (systems logs) and your usage of our website, including using cookies to allow the website to function properly

Legitimate Interests (in running our business, provision and administration of IT services, network security and the functionality of the website)

4. WHO SEES YOUR PERSONAL INFORMATION?

Within the White Cube Group

Your personal data will be processed by the company within the White Cube group that initially receives it, and may also be transferred to and processed by other companies within the White Cube group. White Cube uses EU Commission approved standard contractual clauses to regulate the transfer and processing of data between group companies.

Outside the White Cube Group

We do not transfer your personal data to organisations who wish to use it for their own marketing promotions or other purposes.

We will transfer your personal data to other organisations 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 with artworks (such as conservators), photographers, IT consultants and IT systems and cloud storage providers, online viewing platform and virtual exhibition providers, our email marketing provider Mailchip, our online e-commerce platform Shopify, professional advisers, regulatory bodies, event venues, including art fairs (where you wish to have a pass), and caterers and direct marketing fulfilment and distribution. Where we do so it will be on the basis that these organisations are required to keep the information confidential and secure, and they will only use the information to carry out the instructed services. Some of these organisations may be located outside the EEA and you should refer to the section “Is your personal information transferred out of the EEA?” for more information.

We may also need to keep and disclose certain information about you to appropriate agencies to conduct anti-money laundering and trade sanction checks and to assist with fraud and crime prevention and detection.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

In the case of clients, we may share a copy of your invoice for a particular artwork with the artist who made it for their provenance records.

Our online viewing rooms and virtual exhibitions are hosted by Artlogic. Artlogic provides us with a platform that allows people to view artworks and content relating to art and our artists online. Any personal data that you provide when accessing our viewing rooms and virtual exhibitions will be shared with, and processed by, Artlogic only for the purpose of providing the instructed services (and not for their own purposes).

5. IS YOUR PERSONAL INFORMATION TRANSFERRED OUT OF THE EEA?

In the course of our normal business, White Cube may transfer your personal data outside of the EEA to White Cube offices and representatives and to other organisations who need to process your data in connection with the services that White Cube provides to you (see the section “Who sees your personal information?”).

Non-EEA countries offer varying standards for the protection of personal data and your privacy rights and in some cases these standards are lower than equivalent EEA standards. When we send your personal data outside the EEA, we seek to put in place the EU Commission-approved standard contractual clauses in the form of an appropriate data transfer agreement. If you have any questions or would like further information about how we make personal data available to non-EEA countries please contact us.

6. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

We will retain your personal data for as long as we consider necessary to provide the relevant services and to maintain business records for tax, legal and regulatory reasons.

In the context of our research and records relating to sales and ownership of artworks to assist with checks on authenticity, provenance and title, we will keep this data for as long as the record is relevant to our legitimate business interest and the public interest.

We keep an archive, which documents artists, their practices, exhibitions and events over a number of years. All information stored in the archive is kept securely. Information in the archive is held by White Cube indefinitely consistent with our legitimate interest in documenting the careers of artists represented by White Cube.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. WHAT STEPS DO WE TAKE TO KEEP YOUR PERSONAL DATA SECURE?

We use appropriate technical and organisational measures to protect the security and integrity of your personal information.

Although we have in place modern security systems and procedures, we cannot guarantee the complete security of personal data held in our systems, nor that that information you supply through the internet or any computer network is entirely safe from unauthorised intrusion, access or manipulation during transmission. Any transmission is at your own risk and we will not be liable for any resulting misuse of your personal data.

White Cube’s emails and websites may contain links to third party websites not operated by us. Those third party websites may collect and share personal information about you in accordance with their own privacy practices. White Cube cannot accept any responsibility for the privacy practices or content of those websites. We encourage you to read the privacy notice of every website you visit

8. YOUR LEGAL RIGHTS

We aim to be as transparent as we can be about the data that we process and encourage you to ask us if you have questions about the data we hold on you.

Your rights

If you are a resident of the EU, you have the legal right to request access to your data (commonly known as a “subject access request”). If you exercise this right and we process personal data about you, we are required to provide you with a description and copy of that personal data, and to tell you why we are processing it.

As well as your subject access right, you may have the right to have your personal data rectified or deleted, to object to its processing or have its processing restricted. You may also request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a commonly used, machine-readable format.

You may withdraw consent at any time where we are relying on consent to process your personal data.

Where personal data is processed for a public interest, in the exercise of an official authority vested in White Cube or for the purposes of the legitimate interests pursued by the White Cube, you may object to such processing by providing a ground related to your particular situation to justify the objection.

You should know that, however, should your personal data be processed for direct marketing purposes, you can object to that processing at any time, free of charge and without providing any justification. Where you object to processing for direct marketing purposes, the personal data will no longer be processed for such purposes.

Please contact us at dataprivacy@whitecube.com if you would like to exercise any of the rights set out above in relation to your personal data.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

Should you want to exercise your right to access your personal data (or to exercise any of your other rights) we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. CONTACT INFORMATION AND COMPLAINTS

If you have a query or complaint in relation to White Cube’s processing of your personal data, please contact us at dataprivacy@whitecube.com. You may raise a complaint with the UK Information Commissioner (https://ico.org.uk/) or your local regulator if you consider that we have infringed applicable data privacy laws when processing your personal data. However, we would appreciate the chance to deal with your concerns before you approach the ICO or your local regulator, so please contact us in the first instance.

10. GLOSSARY

Compliance with a legal obligation - processing is necessary to ensure we comply with our legal and regulatory obligations.

Consent – you have given specific consent to the processing of your personal data.

Data Controller – the person who determines the purposes and means of processing personal data.

EEA – the European Economic Area which comprises countries that are members of the European Union and Norway, Iceland and Liechtenstein.

Legitimate Interests - processing is necessary for our legitimate interests in carrying on, managing and administering our business effectively and properly and giving our clients the best service possible. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a contract – processing is necessary to carry out our contractual duties, exercise our contractual rights or otherwise perform our contract with you, or to take steps at your request to enter a contract.

Personal Data - any data relating to an identified or identifiable natural person.

Processing - any operation performed on personal data, such as collection, recording, storage, retrieval, use, combining it with other data, transmission, disclosure or deletion.

Public Interest – processing is necessary for the performance of a task carried out in the public interest.

Website – White Cube's website at whitecube.com

11. INFORMATION FOR CALIFORNIAN CONSUMERS

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act (CCPA/CPRA).

Notice at collection
Categories of personal information collected, used, sold, or shared

In this section we summarize the categories of personal information that we've collected, used, or shared and the purposes thereof.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers and internet information.

We do not collect sensitive personal information.

We will not collect additional categories of personal information without notifying you.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of the Website and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes, as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

How long do we keep your personal information?

We will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.

How we collect information: what are the sources of the personal information we collect?

We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use the Website.

For example, you directly provide your personal information when you submit requests via any forms on the Website. You also provide personal information indirectly when you navigate the Website, as personal information about you is automatically observed and collected.

Finally, we may collect your personal information from third parties that work with us in connection with the functioning of this Website and features thereof.

How we use the information we collect: disclosing of your personal information with third parties for a business purpose

For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.

We disclose your personal information with the third parties grouped and categorized in accordance with the different purposes of processing.

Sale or sharing of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.

This means that, for example, a sale can happen whenever an Website runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA. Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.

Your right to opt out of the sale or sharing of your personal information and how you can exercise it

We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request. To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Website.

If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.

Your privacy rights under the California Consumer Privacy Act and how to exercise them

The right to access personal information: the right to know and to portability

You have the right to request that we disclose to you:

the categories of personal information that we collect about you;
the sources from which the personal information is collected;
the purposes for which we use your information;
to whom we disclose such information;
the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:

the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Website, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.

The right to correct inaccurate personal information

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information

You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.

The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)

We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Latest update: May 22, 2023