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STAIR
PRIVACY POLICY

Introduction
Like most businesses, Stair Galleries & Restoration, Inc. (“STAIR” or “we”) holds and processes a range of information about its clients and other persons who may be interested in STAIRS’ services. This privacy notice applies to stargalleries.com (the “Website”) and explains the type of information that we process, why we are processing it and how that processing may affect you. This privacy policy does not apply to information collected by us offline or any third party, including through any content (including advertising that may link to or be accessible from or through the website.

We may update this privacy notice from time to time and will post any revised notice on the Website. 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

Information You Provide to Us

We collect most personal data directly from you:
• 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.

Automatic collection
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.

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 such as technical data from analytics providers, advertising networks, social media platforms, and similar applications.

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.

2. Information We Collect About You

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, postal address, email address, telephone number, financial account information, date of birth, and government IDs (“personal data”)
  • That is about you but individually does not identify you, such as your title and employer; and
  • About your internet connection, the equipment you use to access our Website, and usage details.

3. How We Use Your Personal Data

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

 

4. Disclosure of 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.

5. Retention of Your Personal Data
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.

6. Data Security
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.

7. Additional Information for Residents of the European Economic Area and United Kingdom

 Legal basis for processing your personal data

We process your personal data for the purposes outlined in the Privacy Policy. We also process your Personal Data in line with the legal bases recognized under GDPR. We may rely on the following legal bases for processing: to pursue our legitimate interests (for example, website analytics, account creation, and Website security), to process transactions requested by you to meet our contractual obligations (as necessary for compliance with a legal obligations (for example, tax reporting obligations, etc.), or on the basis of your consent, where applicable, or for any other legal bases as allowed by applicable law, including processing your personal data under the following conditions:

  • Performance of a Contract: when your personal data is necessary for the performance of an agreement that we make with you and/or for any contractual obligations thereof.
  • Legal Obligation: when your personal data is necessary for compliance with a legal obligation to which STAIR is subject.
  • Legitimate Interests: when processing your personal data is necessary for the purpose of the legitimate interests pursued by STAIR.
  • Consent: you have given your consent for processing personal data for one or more specific purposes.
  • Vital Interests: when your personal data is processed in order to protect your vital interests or those of another natural person.
  • Public Interests: when your personal data is processed relating to a task that is carried out in the public interest or in the exercise of official authority vested in STAIR.

 

Your data protection rights under the GDPR

In certain circumstances, you have the following data protection rights with respect to your personal data that we collect and process:

  • The Right to Request Access. You have the right to access, update, or delete the information we have about you.
  • The Right of Rectification. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • The Right to Object. You have the right to object to our processing of your personal data.
  • The Right to Restrict Processing. You have the right to request that we restrict the processing of your personal data.
  • The Right of Erasure/The Right to be Forgotten. In certain circumstances, you have the right to ask us to remove or delete your personal data.
  • The Right to Transfer. Upon request we will provide you (or a third-party you have chosen) the personal data we have collected about you. Your personal data will be provided in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the personal data to perform a contract with you.
  • Withdraw Your Consent. In the event we have relied on your consent to process your personal data, you have the right to withdraw your consent at any time where STAIR relied on your consent to process your personal data.
  • Be informed of your right to complain to a supervisory authority if you feel that we have not complied with applicable laws regulating your personal data. EEA authorities can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-uk. If you are a UK resident, you can file a complaint with the ICO here: https://ico.org.uk/make-a-complaint/.

You may exercise any of the rights enumerated above by contacting us at feedback@stairgalleries.com. Please note that we may ask you to verify your identity before responding to such requests.  Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.  For more information, or to make a request, please use the information below and provide your name, email address, request, and basis for your request.

We retain your personal data for as long as necessary to comply with your request, provide services, or as required by law, or as necessary to comply with legal or contractual obligations and for our legitimate purposes.

8. 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.

9. 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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