Effective Date: December 14, 2023
Like many companies, we collect personal data from and about our customers and visitors. We are committed to maintaining the privacy and security of your personal data in compliance with all applicable laws. We collect and process your personal data fairly and lawfully and in order to carry out our lawful business activities. This Privacy Policy (“Privacy Policy”) describes the personal data that we collect and process, what we do with it, how we protect it, when we disclose it to third parties, and your rights related to it.
Table of Contents
RAGO WRIGHT, LLC PRIVACY POLICY
WHO WE ARE
Our company, Rago Wright, LLC, is a limited liability company organized in Delaware. Throughout this Privacy Policy we will refer to Rago Wright, LLC and all of our brands and companies as “Rago Wright”, "Wright", Rago”, “LAMA”, “Toomey”, “Toomey & Co”, “Poster Auctions International”, "PAI", “we” or “us” or “our”; and to the websites listed below as the “Site”.
www.ragoarts.com | www.wright20.com | www.lamodern.com | www.toomeyco.com | hermanmillervintage.wright20.com
We operate auction houses with offices in New Jersey, Illinois, and California.
New Jersey: 333 N Main Street Lambertville, NJ 08530 | Illinois: 1440 West Hubbard Street Chicago, IL 60642 | California: 16145 Hart Street Van Nuys, CA 91406 |
NOTICE FOR CALIFORNIA RESIDENTS
Please note that this Privacy Policy contains a section devoted to the rights of California residents under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”). If you are a California resident, please see our California Consumer Privacy Statement for additional disclosures and privacy protections.
CHANGES TO THIS PRIVACY POLICY
From time to time, we may change our privacy practices or implement new privacy policies. We reserve the right to change, add, subtract, update, or amend all or any part of this Privacy Policy at any time without notice to you. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice. Each version of this Privacy Policy will be identified at the top by its effective date. All changes will be effective immediately when we provide notice of them.
TYPES OF PERSONAL DATA WE COLLECT AND PROCESS THROUGH THE SITE
For purposes of this Privacy Policy, “personal data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. Personal data does not include information that is anonymized.
Below is a list of types of information, which may constitute personal data, that we may collect from you through the Site or the Internet.
- Name and contact details, such as name, address, phone number, email address, account name, driver’s license number, passport, government-issued ID, and document showing proof of address; information about the identity and contact information about your advisors, agents, or principals.
- Agreements you enter into with us.
- All communications between you and us, such as emails, completed webforms, texts, letters, contracts, proposals, recordings of phone calls, and logs of bids.
- Information about your property that you present to us for examination or sale, sell through us, or buy through us (“your property”), such as ownership, sales and marketing, prices, valuations, authenticity, provenance, title research, insurance information, condition, conservation efforts, import/export documents, tax information and shipping information.
- Information you give us when signing up with us, asking us questions, making requests, or communicating with us; information about your interests, including art, issues, topics, and activities.
- Content you post to social media.
- Internet & device Information, such as Internet Protocol (IP) address, browser type, operating system, and other information about how you access our Site and our services electronically.
- Recordings, such as screen shots, auction video footage, recordings of communications.
- Your communication and marketing consent and preference instructions and directions.
- Your payment preferences and payment details for payments we make to you, and payments you make to us.
WHY WE COLLECT AND USE PERSONAL DATA
We collect personal data for many purposes, including the following:
- To manage your account, to perform services you request from us, and to invite and enable you to participate in our auctions or sales.
- To manage art transactions, including examination of property, dealing with receipt and facilitation of property shipments, and communicating information about property for sale.
- To facilitate your purchases, including processing your order and payment, shipments, technical support, and assistance; communicating with you about how you can close your sale or purchase of property.
- To manage our communications, answer your questions and let you know about our company, services, events, rules, auctions, or art; and to communicate with you about Rago-Wright and our activities and about issues or offerings in which you may have expressed an interest.
- To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or communications concerning sales, lots, services, or products you have contracted for, security updates, or your experience with the Site or our products/services. Please see our SMS Terms and Conditions for more information.
- To make and keep records of property we handle, including ownership, sales and marketing, consignments, purchases/sales, prices, valuations, authenticity, provenance, title research, insurance information, condition, and conservation; and to protect against fraud, theft, loss, damage, or other illegal activities.
- To enlist third party vendors for crating, shipping, insurance, delivery, art restoration, conservation and framing, payment processing, identity verification, mailings, technology support, fraud prevention, digital marketing, and data storage.
- To maintain the security, safety and integrity of our Site, databases, records, and other technical assets.
- To comply with the laws and regulations such as tax reporting, complying with law enforcement investigations and judicial proceedings and to carry out appropriate anti money laundering checks, risk screening and transaction screening and monitoring.
- To protect our customers, business, employees, owners, contractors, vendors, consignors and partners from liability or loss, to seek and receive advice on the legal rights and obligations of these parties which may include providing information to legal and tax advisors, law enforcement, judicial authorities, mediators, and arbitrators, and to enforce and defend our rights and the rights of our partners and customers.
- To help us improve your experience on the Site, to enable us to give you convenient access to services, and for analytics purposes, such as to understand how you use our Site, understand your preferred method of purchasing with us, determine which browser and devices you use to visit our Site, and to evaluate and improve our products, services, communications, and Site.
HOW WE COLLECT personal data
In most cases, we collect personal data directly from you. However, we may also obtain limited personal data about you from a device associated with you or your household, or an external third-party source. Below is a discussion of how we collect this information.
INFORMATION WE GET FROM YOU VOLUNTARILY
We will collect the personal data that you voluntarily provide to us when you use this Site. For example, if you sign up with us, or submit information through a form on our site or similar page, or send us any message, we will collect information that you provide to us in such a request, submission, or message.
This includes information you choose to provide when you:
- register and create, update, or change an account with us on our Site.
- subscribe to receive emails, SMS texts, or other marketing communications from us.
- arrange to bid at an auction or offer to buy property through our Site.
- complete a purchase or other transaction with us, including the information we need to process payments, complete the transaction, and facilitate pickup or shipment of the property you purchased from or through us.
- communicate with us about consignment or sale of your property.
- ask us a question, request customer service, provide feedback, or otherwise contact us, including through online forms, email, mail, and telephone.
- engage with us on social media platforms (Facebook, Instagram, Twitter, Pinterest, YouTube, TikTok, Google+).
- participate in a promotion or survey.
INFORMATION COLLECTED AUTOMATICALLY
Our Site automatically collects certain information, some of which may be personal data.
Cookies. Like many operators of websites, we may use tracking software and similar technology that automatically collects information about your computer hardware and software, and your use of the Site and your browsing trajectory on our Site. The information collected may include, without limitation, information about your device, such as the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your device, as well as date/time stamp, IP address, webpages visited, actions taken on webpages, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from (referrer URL), and other data. Some of this information may be collected by our web server software, which generates log files — text files that record one line of data each time a browser request is made. Data also may be automatically collected using cookies and similar technologies. Cookies are small text files placed on your device to store data that can be recalled by a web server in the same domain that placed the cookie. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well. To learn more about our use of cookies and your choices to restrict cookies, please visit our Cookie Policy.
Recordings. Your voice may be recorded during a call with us for customer service or to place an auction bid. We also may make audio/video recordings of our auctions and art viewings, so it is possible that your presence could be recorded.
INFORMATION FROM OTHER SOURCES
We may collect information from the third parties who we engage to provide us with services related to the operation of our business such as shipping, crating, insurance, auction management, auction facilitation, marketing, analytics, and payment processing. Please see “When We Disclose Personal Data” below.
We may also obtain your personal data from any of the online auction providers that stream, display or promote our auctions on their platform. If you access our auctions, sales, or offerings on one of these other auction platforms, your delivery of that information will be subject to that platform’s privacy policy. We have no control over how the other auction platforms use your personal data collected. Be sure to review the privacy policy published by the auction platform you engage in and contact them directly if you have questions as they may have privacy terms that differ from our Privacy Policy.
SOCIAL MEDIA AND SHARE LINKS
When you mention us or interact with us on Facebook, LinkedIn, Twitter, or other social media sites, we may collect your information. This information may include your name, image, email address, social media handle(s) and any comments or content you post relevant to us. We have no control over how any social media company uses your personal data. Be sure to review the privacy policy published by the social media company you use and contact them directly if you have questions as they may have privacy terms that differ from our Privacy Policy.
HOW WE PROTECT PERSONAL DATA
When we collect information including personal data, we include it in our computerized databases and records of customers and potential customers. We maintain technical, organizational, administrative, and physical measures and safeguards that are intended to appropriately protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure or access, misuse, and any other unlawful form of processing of personal data in our possession. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and who are required to keep the information confidential. However, because no information system can be 100% secure, we cannot guarantee the absolute security of your information.
You will be required to create a password to create and use an account with us on our Site. Your password is encrypted, and we do not have access to your encrypted password. You are solely responsible for remembering your password and keeping your password secret.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Our US-based operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, all located in the United States. Your personal data may be transferred, stored, and processed anywhere in the world, including but not limited to, the United States. By using our Site or otherwise providing us with personal data, you consent to your personal data being transferred to countries outside of the country where you access and use our Site, including countries/regions that have different data protection rules than your country.
WHEN WE DISCLOSE PERSONAL DATA
NO SALE
We will not sell any of the personal data about you we collect to any third party.
SERVICE PROVIDERS
Our business involves facilitating the sale of consigned works of art, design and collectibles to bidders and buyers. We may allow access to your personal data to third parties who are enlisted to perform services for us, but only for the purpose of and to the extent necessary to perform those services. These service providers are contractually prohibited from using personal data for any other purpose. While we may seek to require service providers to follow appropriate privacy policies and will not authorize them to use your personal data except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties. Our service providers include our technology providers and consultants, webmasters, as well as customer service representatives and contractors who we engage or partner with to provide products, services, support and marketing to our customers and potential customers, such as collecting bids and offers, fulfilling orders, delivering packages and communications, analyzing customer data, providing marketing assistance, providing insurance, processing payments, investigating fraudulent activity, and providing customer service.
TRANSACTION
We may disclose some of your personal data to third parties who are parties to a contract with you. For instance, if you are consigning property to us, then we may disclose your name to a buyer of the property unless you instruct us to keep your name confidential. Our general practice is to not disclose such information if you advise us to keep that information confidential. However, we may disclose your name or personal data to address any questions or disputes.
SHIPPERS
We also may disclose your personal data to third parties who provide shipping, fulfillment, and storage in connection with the transport and sale of your property.
PAYMENTS
We generally enlist third-party vendors to handle all aspects of the payment process (e.g., payment processors). Payments will be processed by a third-party processor and are not stored on Rago Wright servers. As a result, we usually will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal data is governed by their privacy policies. These payment processors agree to adhere to the standards set by PCI DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI DSS requirements help ensure the secure handling of payment information.
By providing payment information, you agree to the processing of that information and the transfer of that information to any of the third parties below to process your payment. All such information will be transferred by you directly to the applicable third-party and not retained, stored, or used by Rago Wright.
All such transferred information is subject to the privacy policy of the third-party transferee. Be sure to review all privacy policies published by our third-party providers and contact them directly if you have questions as they may have privacy terms that differ from our Privacy Policy.
SUCCESSORS
We may disclose your personal data to a successor-in-interest of ours, such as a company that acquires us, merges with us, or acquires our business, or that we acquire.
EMERGENCY
We may disclose your personal data to prevent an emergency, to protect or enforce our rights, to protect against suspected credit card fraud, to protect or enforce the rights of a third party or as required or permitted by law (including, without limitation, to comply with a subpoena or court order).
AGGREGATE INFORMATION
We may share aggregate information about our customers for educational, research, analytic or benchmarking purposes. When shared in this form, no individual customer is identified.
WITH OTHER USERS
When you share personal data or otherwise interact in the public areas with other users, that information may be viewed by all users and may be publicly distributed outside the Site. If you access the Site through a third-party social media service, your contacts on that third-party social media service may see your name, profile, pictures, and activity information; and other users may be able to view the same personal data.
LAW ENFORCEMENT
We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
OTHER LEGAL REQUIREMENTS
We may disclose your personal data in the good faith belief that such action is necessary: (a) to comply with a legal obligation; (b) to protect and defend the rights or property of Rago Wright; (c) to prevent or investigate possible wrongdoing; (d) to protect the personal safety of users of the Site or the public; (e) to protect against legal liability.
HOW LONG WE KEEP YOUR PERSONAL DATA
We retain personal data for no longer than necessary to fulfill the purposes for which it was collected and used, as described in this Privacy Policy, unless a longer retention period is required or permitted under applicable law. As permitted under applicable law, even after you stop using the Site or our services, we may still retain your personal data so long as necessary to provide you with customer support, keep business, tax and art records, and deal with any legal claims.
To memorialize and protect art history and the art market, we will retain all records related to art, art ownership, consignments, purchases/sales, prices, valuations, authenticity, provenance, title research, insurance information, condition, and conservation for so long as such records are in our legitimate business interests and/or in the public interest, unless otherwise required by law. We also generally do not erase or change property information once published on our Site or in our catalogs. This information, like all information about property we handle, is in the interests of the art market and art history.
ABOUT CHILDREN’S PERSONAL DATA
We are not targeting our services or this website to children, and we do not knowingly collect contact information from children under the age of 13. If you are under the age of 13, please do not email us, contact us, attempt to use the website, submit information to the website or ask us to email you.
LINKS TO OTHER WEBSITES
The website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's website. We strongly advise you to review the privacy policy of every website you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.
CONTACT US
If you have any questions about our privacy or security practices, you can contact us using the information below:
Rago Wright, LLC
1440 West Hubbard Street
Chicago, Illinois 60640
dpo@wright20.com
Toll-Free Phone: 1 888 445 0632
Attn: Privacy Officer
GOVERNING LAW
This Privacy Policy and all rights and obligations relating to it will be governed by the laws of the State of New Jersey and specifically excluding conflict of laws principles and the UN Convention on Contracts for the International Sale of Goods.