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Rago Wright, LLC Privacy Policy

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 (1)
  • NOTICES FOR CANADIAN RESIDENTS (6)
  • NOTICE FOR EU/UK RESIDENTS - GDPR PRIVACY NOTICE (6)
  • RAGO WRIGHT, LLC CALIFORNIA CONSUMER PRIVACY STATEMENT (9)
  • RAGO WRIGHT, LLC COOKIE POLICY (17)
  • YOUR RIGHT TO OPT OUT OF THE SALE OR SHARING OF PERSONAL INFORMATION

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. 


NOTICES FOR CANADIAN RESIDENTS

We and our US-based service providers may process and store your personal data in a country outside of Canada, and the governments, courts, or law enforcement of that country may be able to obtain disclosure of personal data through the laws of the foreign country. Under the laws of a foreign country, in certain circumstances, we may be required to provide your personal data in response to a search warrant or other legally valid inquiry or order.


NOTICE FOR EU/UK RESIDENTS - GDPR PRIVACY NOTICE

If you are located in the European Economic Area (“EEA”) or U.K., please read the following GDPR Privacy Notice: 

This section incorporates general provisions of the Privacy Policy, where applicable. If any provision in the Privacy Policy is inconsistent with this section (for ease of reference, “EU Policy”), the terms of this EU Policy shall apply to the processing of personal data subject to this EU Policy. Terms used in this GDPR Privacy Notice shall have the meaning ascribed to them by the applicable data protection law, including the definition of “personal data”.

Rago Wright is the data controller of the personal data we collect through this Site. We will process personal data in accordance with the purpose for which we collected it and for further purposes only if we deem them compatible with that original purpose. You are not required to provide any of the personal data; however, if you choose not to provide certain requested information, you may be unable to access some of the services, offers, and content on the Site. 

THESE RIGHTS ONLY APPLY TO RESIDENTS OF THE EUROPEAN UNION AND THE UNITED KINGDOM AND NOT TO ANY OTHER USER. 

YOUR RIGHTS UNDER THE GDPR 

We respect the confidentiality of your personal data and your right to exercise your rights under GDPR. You have the rights under this GDPR Privacy Notice and by law if you are within the EU or UK, to the following:

Request Access to Your Personal Data. You are entitled to see, access, update, correct or order us to delete your personal data. You may see and access your personal data and update or correct it or tell us to delete it by contacting us at the contact addresses at the end of this GDPR Privacy Notice. You may also receive a copy of the personal data about you in our possession. 

Correct Personal Data in Our Possession. You are entitled to tell us to correct any incorrect personal data we have about you. 

Object to Processing of Your Personal Data. You are entitled to object to our processing of your personal data. Our right to process your personal data depends on us having a legal basis for having and processing that personal data. However, you may object to that interest and the legal basis for our processing of your personal data. You may also object to our processing of your personal data for direct marketing purposes. 

Deletion of Your Personal Data. You are entitled to request that we erase or delete your personal data if there is no legitimate reason for us to continue to process it.

Request the Transfer of Your Personal Data. You are entitled to a report on your personal data in our possession that we received to perform a contract with you and automatically from your interaction with our Site or services. 

Withdraw Your Consent. You are entitled to withdraw your consent to use and process your personal data. But, if you withdraw your consent, we may not be able to provide you with access to the Site or our products and services. 

LEGAL BASIS FOR PROCESSING 

The table below explains the purposes for which we use your Personal Data, the types of Personal Data used and the legal grounds on which we process it under applicable Data Protection Legislation. Some of the capitalized words or phrases are defined in the Glossary following the table. 

Why We Collect and Use Your Personal Data Examples of Personal Data Used Legal grounds for processing
Manage Your Account. To perform services you request from us. To invite and enable you to participate in our auctions or sales. To facilitate your purchases, process orders and payments, shipments, and provide assistance. Name and contact details, such as name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, phone number, email address, account name, driver’s license number, art or property insurance policy number, passport number, or other similar identifiers. Identification, such as passport, government-issued ID, document showing proof of address. • Consent
• Perform a Contract
• Legitimate Interests
Manage Art Transactions. To examine and price your art, coordinate consignments, receive and store art. To respond to requests for information or catalogs, facilitate an art viewing, collect your bidding information, communicate with you about closing your purchase, facilitate shipment of property to you, or schedule your pickup of property. Information about 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. Agreements and related materials.  • Consent
• Perform a Contract
• Comply with Legal Obligations
• Legitimate Interests
Manage Our Communications. To answer your questions and to let you know about our company, services, events, rules, auctions, or art, and manage and respond to your comments, suggestions, and feedback. To provide information to you after you subscribe for communications and news about us, our company, the art industry, or our sales. Name and contact details. Information about your interests, including art, issues, topics, and activities. Your communication and marketing consents and preferences. Information you give us, such as when signing up with us, asking us questions, making requests, or communicating with us. Content you post to social media. All communications between you and us, such as emails, completed webforms, texts, letters, contracts, proposals, bid logs, and recordings of phone calls.  • Perform a Contract
• Comply with Legal Obligations
• Legitimate Interests
Keep You Informed. To match marketing, content, messages, and ads to your expressed areas of interest and to contact you after your visits to our Site.  Name and contact details. Your communication and marketing consents and preferences. Information you give us.  • Consent
• Legitimate Interests
Manage Our Part of the Art Industry. To  make and keep records of property we handle. To protect against fraud, theft, loss, damage, or other illegal activities. Name and contact details. Information about your property. • Perform a Contract
• Tasks in Public Interest
• Legitimate Interests
Enlist Third Party Vendors. To communicate with third parties in the course of examining property and researching property’s authenticity, provenance, condition, and title. To get services from third parties like crating, shipping, insurance, delivery, art restoration, conservation and framing, payment processing, identity verification, mailings, technology support, fraud prevention, digital marketing, and data storage. Name and contact details. Your immediate sales and purchase details. Information about your property.  • Consent
• Perform a Contract
• Comply with Legal Obligations
• Legitimate Interests
Maintain Security. To detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity. To carry out anti money laundering checks, risk screening and transaction screening and monitoring.   Recordings, such as screen shots, auction video footage, recordings of communications. Internet & Device Information, such as Internet address, browser type, operating system, and other information about how you access our Site and our services electronically.  • Comply with Legal Obligations
• Tasks in Public Interest
• Vital Interests of a person
• Legitimate Interests
Comply with Law. To comply with applicable laws such as tax reporting, investigations, and judicial proceedings.  Name and contact details. Recordings. Other personal data if required by law. • Comply with Legal Obligations
• Legitimate Interests
Protect Legal Rights. To protect our customers, business, employees, owners, contractors, vendors, consignors, and partners from jeopardy, 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, credit check agencies, judicial authorities, mediators, and arbitrators. To enforce and defend our rights and the rights of our partners and customers.  Name and contact details. Recordings. Information about your property. Information about the identity and contact information about your advisors, agents, or principals.  • Perform a Contract
• Legitimate Interests
• Vital Interests of a person
Manage our Sites. To monitor, audit and analyze use of our Site and trends; to improve user experience with our Site and our Site’s performance, to train our staff for better customer service. To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.  Internet & Device Information. Your communication and marketing consents and preferences and content.  • Consent
• Perform a Contract
• Legitimate Interests
Manage Our Business. To create, maintain and secure records of our business, history, and processes across the Rago Wright enterprise, which includes art examination, art handling, art pricing. To support potential sales, mergers, liquidations, or transfers of our assets. To monitor page, feature and report visits on our Site and bidding history. All examples of Personal Data in this table. • Perform a Contract
• Legitimate Interest

GLOSSARY

Capitalized terms in the table above have the following meanings:

"Comply with Legal Obligations" means to comply with our legal obligations, including without limitation anti-money laundering efforts, avoiding fraud and tax reporting.

"Consent" means your specific and explicit consent to do so or where we have sought and obtained your consent to send you direct marketing by email, or for the use of cookies on our website.

"Legitimate interests" means our reasonably expected or disclosed interests operating the business of Rago Wright, LLC in compliance with applicable law. 

"Perform a Contract" means to perform under a contract to which you are a party. 

"Personal Data" means any data relating to an identified or identifiable individual; an identifiable person is one who can be identified, directly or indirectly. 

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

"Tasks in the Public Interest" means necessary for the performance of a task carried out in the public interest.

"Vital Interests of a person" means necessary to protect the vital interests of a person, which generally means the life, health, or safety of a person.

TRANSFER OF YOUR PERSONAL DATA. 
Your personal data is processed at our offices and in any other places where the parties involved in the processing are located.  So, this personal data may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.  Your submission of such information represents your agreement to that transfer. We do not market our services in the EU. By using our services, you agree and understand that your personal data you provide to us will be moved to our US-based servers for processing. We maintain technical, organizational, administrative, technical, 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.

AUTOMATIC DECISION-MAKING
Our review of personal data during user intake, account set-up, order processing, risk assessment, or fraud prevention may include our analysis of your personal data using software that is able to assess risks. For example, we – and our service providers – may use automated applications to analyze personal data and generate a notice that flags accounts or activities for further review and analysis. A mismatch between a user name and user address may result in a notice from the application that more information is needed. Further, activities on our Site may produce warnings, such as multiple logins from different locations or suspicious IP addresses.   

HOW TO EXERCISE YOUR GDPR DATA PROTECTION RIGHTS. 
You may exercise any of your GDPR rights by contacting us at the contact information at the end of this GDPR Privacy Notice. We may require you to verify your identity before we respond to any communications or requests. You have the right to complain to a Data Protection Authority about our collection and use of your personal data. 

For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA. You can find the contact information for your local Supervisory Authority here: https://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. If you are located in the United Kingdom, you have the right to lodge a complaint with the UK’s supervisory authority.  

Retention. We retain your personal data only for the period of time needed to fulfill the purposes stated in the Privacy Policy, comply with applicable laws, and for our legitimate business needs.


RAGO WRIGHT, LLC CALIFORNIA CONSUMER PRIVACY STATEMENT

Effective: December 14, 2023

This California Consumer Privacy Statement (“Statement”) is a part of the Rago Wright, LLC Privacy Policy solely for California consumers. 

This Statement incorporates general provisions of the Privacy Policy, where applicable. This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (the “CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”, and together called “California Consumer Privacy Laws”). Throughout this Statement, we will refer to Rago Wright, LLC and all of our brands and companies as “Rago-Wright”, “we” or “us” or “our”; and to the websites listed in our Privacy Policy and those we operate as the “Site”. 

This Statement describes the types and categories of personal information we collect, the business purposes for which we collect, process, use, store and disclose your personal information and your rights in personal information under the CPRA. 

For purposes of this Privacy Statement, we refer to personal information according to the following definition given in the CPRA: “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information, information that is de-identified or aggregate consumer information, or information or rights that are outside the scope of the CPRA.

CATEGORIES OF SOURCES OF COLLECTION OF PERSONAL INFORMATION 
During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

  • You, when you register an account with us, when you sign up to bid, when you communicate with us to sell property through us, when you complete a purchase of property through us, or when you sign up to receive alerts and communications about our activities. 
  • Your devices when you visit our Site.
  • Automatically through cookies and tracking technologies.
  • Other people, such as when a person lets us know that you are their agent to bid for them or when a person makes an introduction of you to us.
  • Third party service providers who provide services on our behalf.
  • Publicly available information resources, when we receive information about you from  news media, art databases, government data resources and other sources. 
  • Internal recording resources.
  • Social media networks.
  • Government entities.
  • Third party auction platforms. 

CATEGORIES OF PERSONAL INFORMATION WE MAY COLLECT AND USE
The table below lists the categories of personal information we have collected, and personal information we may have collected, over the past 12 months and the categories of sources of that information. Please refer to the section above entitled “CATEGORIES OF SOURCES OF COLLECTION OF PERSONAL INFORMATION” for information about these sources. 

Categories of Personal Information Types of Information We Have Collected in Last 12 Months Categories of Sources of Information
Identifiers.  Basic identifying information such as a name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, driver’s license number, passport number, or other similar identifiers. You. Your devices when you visit our Site. Automatically through cookies. Third party service providers. Social media. Publicly available information resources. Auction partners. 
Customer Records.  Personal information described in subdivision (e) of Section 1798.80 of the California Civil Code, including without limitation name, signature, telephone number, art, or property insurance policy number.  You. Your devices when you visit our Site. Automatically through cookies. Third party service providers.
Commercial Information.   Records of items considered for purchase or bidding, items offered for consignment, shipping details, and events attended. Audio and video recordings of our communications and auctions. Your communication with our support team or with other similar contact channels. Payment information. Information about your property.  You. Your devices when you visit our Site. Automatically through cookies. Third party service providers. Publicly available information resources. Auction partners.
Protected Classification Information. Information such as age, national origin, gender, citizenship, or marital status. You. Third party service providers. Publicly available information resources.
Internet Activity.  Browsing history, search history on our Site, and information regarding your interaction with our Site, Internet address, browser type, operating system, and other information about how you access our Site and our services electronically, and log file information, webpages on our Site you visit, cookies tied to a specific browser, unique session ID, and other electronic network activity. You. Your devices when you visit our Site. Automatically through cookies and tracking technologies.
Geolocation Data. We may determine your approximate geographic location through your IP address.  Your devices when you visit our Site. Cookies.
Sensory Information.  Information detected by the senses, such as audio and visual, such as recordings of calls with us and audio/video recordings of auctions. Our communications with you.
Professional or Employee-Related Information.  Information about your place of employment, position, and other related data which we may obtain as part of verifying your identity. You. Third party service providers Social Media. Publicly available information resources.
Education Related Information.Information about your education, which we may obtain as part of verifying your identity.You. Third party service providers Social Media. Publicly available information resources.
Inferences.  Information drawn from data that is used to create a profile about a consumer’s preferences about art, furniture, objects, jewelry, or other collectibles.  You. Automatically through cookies and tracking technologies. Publicly available information resources.
Sensitive Information.  Information that may be sensitive under applicable laws, like government identification numbers, login credentials for your Rago Wright account, the geolocation of the device you use to access our Site or citizenship.  You. Your devices when you visit our Site. Cookies. Third Party Service Providers. 

BUSINESS PURPOSES FOR WHICH WE MAY PROCESS YOUR PERSONAL INFORMATION
We may use your personal information in any and all of the categories of personal information identified above for the business or commercial purposes described below and in our Privacy Policy, as well as for the business purposes specified in the CCPA:

  • To manage your account: to perform services you request from us, to invite and enable you to participate in our auctions or sales, to verify your identity. 
  • To manage art transactions: conduct auctions, collect payment, make payments to consignors, and help buyers retrieve their purchased property.
  • To facilitate your purchases: processing buyer orders and payment, facilitating shipments of the order, and providing you with technical support and assistance. 
  • Security, fraud, and legal compliance: to detect and prevent security incidents and fraudulent activity, and to protect the security of personal information and our systems and enforce and defend our rights. 
  • To enlist third party service providers: for crating, shipping, insurance, delivery, art restoration, conservation and framing, payment processing, identity verification, mailings, technology support, fraud prevention, and data storage. 
  • To improve our existing processes and offerings: to detect bugs and errors and repair them, to audit current interactions with visitors, consignors or bidders or potential bidders, to add, change or improve features on our Site.
  • Short term transient uses that are not saved in a user profile.
  • To keep records of property we handle for market and historical purposes: including ownership, sales and marketing, consignments, purchases/sales, prices, valuations, authenticity, provenance, title research, insurance information, condition, and conservation. 
  • To communicate with you: to answer your questions and let you know about our company, services, events, rules, auctions, or art. 

CATEGORIES OF THIRD PARTIES TO WHOM WE MAY DISCLOSE PERSONAL INFORMATION
We may disclose all or any of the categories of personal information in the table above to the following categories of third parties: (a) service providers that process personal information on our behalf (e.g., payment processors, identity verification providers, data storage providers, email services, Internet service providers, insurance providers, shippers, art handlers and packers, art conservators, auction platform providers, and research firms); (b) service providers, contractors and third parties for ad placement and analytics (for which you may opt out); (c) business partners (e.g., legal advisors, professional advisors, buyers of our business or equity, and consultants); (d) tax authorities, and government and law enforcement agencies and officials; and (e) advertising and marketing companies. Rago Wright requires its service providers, contractors and third parties who provide services or data processing for us or on our behalf to maintain the privacy and security of your personal information. In the past twelve (12) months, we have not disclosed the categories of personal information identified above to any outside organizations or entities who are not service providers or contractors providing services on our behalf. 

HOW LONG WE KEEP PERSONAL INFORMATION
We will retain your personal information for as long as we have a relationship with you. Once our relationship with you ends, we will keep your personal information for as long as appropriate to: (a) keep business records for audits or analysis; (b) defend or assert legal claims; (c) comply with legal requirements; (d) handle questions and comments about services; and (e) preserve historical records of property and transactions. Generally, we will keep most records for a minimum of six (6) years following the end of our relationship, but we may dispose of information earlier when we determine that it is not necessary to achieve any of the purposes identified in this Statement. Once these purposes have expired, we will delete your personal information. 

DO NOT TRACK
Do Not Track Policy as Required by California Online Privacy Protection Act (“CalOPPA”). Our Site does not respond to Do Not Track signals or opt out preference signals. However, some third-party websites do keep track of your browsing activities. If you visit websites that do respond to Do Not Track signals, then you may set your preferences in your web browser to tell those websites that you do not want to be tracked. 

KIDS
We are not targeting the Site to children, and we do not knowingly collect contact information from children under the age of 13.  California users under the age of 18 may request the removal of their content or information publicly posted on the Site by emailing us at dpo@wright20.com. 

ACCESS BY PERSONS WITH DISABILITIES
Persons with disabilities who need assistance accessing this Statement may contact us as provided below, and we will furnish this policy in an alternative format.

NO FINANCIAL INCENTIVES FOR PROVIDING US WITH PERSONAL INFORMATION
We do not offer any financial incentives such as loyalty programs, discounts, and special offers when you provide us with contact information and identifiers such as your name and email address.

YOUR RIGHTS UNDER CALIFORNIA CONSUMER PRIVACY LAWS
California Consumer Privacy Laws and other California laws provide you with the following rights:

Right to Know
You have a right to request that we tell you about any personal information we have collected, used, disclosed, shared and/or sold about you during the 12 months prior to your request. Specifically, you may request that we send you a report on: (a) the categories of personal information that we have collected about you; (b) the categories of sources from which the personal information is collected; (c) the business reasons why we collected that personal information; (d) if we disclosed any categories of personal information to third parties and, if so, the business purpose for the disclosure and the categories of third parties to whom we disclosed the information; (e) the specific items of personal information that we have collected about you; and (f) if we sold any personal information about you, the categories of personal information sold, and the categories of third parties to whom we sold it.

If your request covers a time period earlier than 12 months before the date of your request, we may deny your request as to that extended time period where it would be impossible for us to provide you with the information or involve disproportionate effort. We also may deny your request for information under certain circumstances (for instance, if we retain information solely for legal and compliance purposes).

Right to a Shine The Light Report
You have the right under California Civil Code §1798.83 to request a report on whether we disclosed your personal information to third parties for direct marketing purposes. Pursuant to California Business Code §§22575-22579, you may review and request changes to any of your personal information that we have collected. 

Right to Correct
You have a right to request we correct certain personal information we have collected about you that you believe is inaccurate.

Right to Delete
You have a right to request that we delete specified personal information we have collected about you, subject to certain exceptions and limitations. 

Right to Limit Use or Disclosure of Sensitive Personal Information
You have a right to request we limit our use of information that is “sensitive personal information” that we collected for the purpose of inferring characteristics about you, beyond what is reasonable and proportionate to provide the requested goods or services.

Rights to Opt Out
You have the right to opt out of the sale of your personal information and to opt out of the sharing of your personal information for targeted ads. See “Your Right to Opt Out of the Sale or Sharing of Personal Information” below. 

Free from Discrimination.
You have the right to be free from discrimination for exercising any of these rights. But we could deliver a different level of service or charge a different rate reasonably related to the value of your personal information.

HOW TO EXERCISE YOUR RIGHTS

Your RequestAction
To submit a request for a report on your personal information Contact us by:
• our Privacy Request Form
• phone at 1 888 445 0632
• email at dpo@wright20.com
To submit a request for a Shine the Light Report:  Contact us by: 
• our Privacy Request Form
• phone at 1 888 445 0632
• email at dpo@wright20.com
To correct or delete your personal information:  Contact us by: 
• our Privacy Request Form
• phone at 1 888 445 0632
• email at dpo@wright20.com

Include in your message: 
• all of the incorrect personal information that you wish to change or have deleted, 
• the corrected personal information, and 
• your signature authorizing such changes or deletions (if in writing). 
To limit our use of your sensitive personal information Contact us by: 
• our Privacy Request Form
• phone at 1 888 445 0632
• email at dpo@wright20.com

Include in your message: 
• a description of the sensitive personal information about you and all of the incorrect personal information that you wish to limit, 
• your signature authorizing such changes (if in writing). 
To opt out of the sale or sharing of your personal information Contact us by: 
• our Privacy Request Form
• phone at 1 888 445 0632
• email at dpo@wright20.com

Include in your message:
• The email address you registered with 
• Your first and last name
• Whether you are opting out of sale or share of your personal information or both

Please note that the effectiveness of your opt-out request may be limited by our ability to associate the cookies and/or pixels that we may collect from your web session with your identity, browser, device, and/or browsing session. As a result, your opt-out request will be more effective for future visits to our Site if you:

  • Use the same device that you used to exercise the opt-out request;
  • Have not cleared cookies from your web browser;
  • Are not using a private or "do not track" mode in your web browser; and
  • Provide the same Personal Information that you provided previously.

VERIFICATION OF REQUESTS
Once we receive your request, we will need to verify your identity. For instance, we may require you to give us a copy of your driver’s license or other government-issued ID plus your full name, date of birth and other information. If you have an online account, we may require you to sign into your account. We may also ask you to sign a declaration under penalty of perjury stating that you are the individual related to the request. 

You may appoint someone to act as your agent to submit these requests and receive the responses. For any agent you designate, we will need to verify the agent’s identity and we will need a written letter signed by you giving the agent your power of attorney. 

EXCEPTIONS TO RIGHT TO DELETE
Although you have the right to request deletion of certain personal information, we may decline to delete some or all personal information if retaining the information is necessary for us or our service provider(s) to: 

  • complete any transaction for which we need personal information, provide goods or services that you ordered, or take actions reasonably anticipated within the context of our ongoing business relationship with you. 
  • memorialize the historical record for art, art provenance and art history purposes.
  • monitor or identity security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
  • comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 
  • accomplish internal tasks that are reasonably aligned with your expectations based on your relationship with us. 
  • comply with a legal obligation. 
  • make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

YOUR RIGHT TO OPT OUT OF THE SALE OR SHARING OF PERSONAL INFORMATION
We do not “sell” your personal information in exchange for money. Occasionally, we may permit a third party sponsor of a charitable or philanthropic auction to contact you about an auction. We may permit specific service providers who provide us with analytics services to collect limited personal information through automated technologies on our website for non-monetary consideration; because we receive analytics services in exchange, that may constitute a “sale” under California Consumer Privacy Laws. We may “share” your personal information with third parties within the meanings of those terms under the California Consumer Privacy Laws (i.e., for cross-context behavioral advertising). In the past twelve (12) months, we have not shared the categories of personal information listed above with any third parties.  

Under California consumer privacy laws, if you are a resident of California, you are entitled to opt out of selling and sharing your personal information. 

HOW TO OPT OUT OF THE SALE OR SHARING OF YOUR PERSONAL INFORMATION. 
You can opt out of the sale or sharing of your personal information by sending us the email address you registered with and your first and last name and whether you are opting out of sale or share of your personal information or both:

  • using our Privacy Request Form, or
  • by phone at 1 888 445 0632, or
  • by email at dpo@wright20.com.

OUR RESPONSE TO YOUR REQUESTS
Once a request for information or a report is made, and we have verified the request, we will send you a report listing:

  • the categories of information we have collected over the previous 12 months; 
  • the purposes for collecting your personal information; 
  • if we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient obtained; 
  • the specific pieces of personal information we collected about you (also called a data portability request); and 
  • the categories of third parties with whom we shared personal information.

TIMELINESS OF OUR RESPONSES 
We will (a) confirm receipt of requests to know, data portability, to correct inaccurate information or to delete within 10 business days of the request; and (b) generally respond to requests to know, data portability, to correct inaccurate information or to delete within 45 calendar days of the request. If we need additional time to respond to your request beyond the 45 calendar days, we will provide you with a notice explaining the reasons we need more time, and we will then take up to an additional 45 calendar days to respond to your request.

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
Attn: Privacy Officer
dpo@wright20.com
1-888-445-0632
Go to our Privacy Request Form


RAGO WRIGHT, LLC COOKIE POLICY

Effective Date:  December 14, 2023

This is the Rago Wright, LLC Cookie Policy, a part of the Rago Wright Privacy Policy. This Cookie Policy is effective as of the date written above.  Throughout this Cookie Policy we will refer to Rago Wright, LLC and all of our brands and companies as “Rago-Wright”, “we” or “us” or “our”; and to the following websites listed below as our “Site”. 

www.ragoarts.com  |  www.wright20.com  |  www.lamodern.com  |  www.toomeyco.com  |  hermanmillervintage.wright20.com

WHAT ARE COOKIES?
We use cookies and similar technologies on our Site and all related domains, as explained in this cookie policy1. Below, you can find detailed information about the types of our cookies, their purposes, and your right to manage your interactions with cookies on our Site.

UNDERSTAND COOKIES.
Cookies are bits of electronic information (small text files) that a website can transfer to a visitor’s hard drive through a browser to help tailor and keep records of their visit. Cookies allow website operators to better customize visits to the site to the visitor’s individual preferences. Many commercial websites use cookies. When you visit a website, the website may send a cookie to your browser and your browser may store the cookie on your computer or mobile device. Cookies are stored for a certain period of time depending on their type. If not disabled, cookies recognize your device and collect certain information about your website visits; over time, websites can remember your actions and preferences because of cookies. 

COOKIE CATEGORIES.

  • Cookies are categorized in several ways based on their duration, source, importance, and purpose. 
  • Duration. Cookies can be persistent or session. Session cookies turn on during a session and remain active while the browser is open; they close with the browser. Persistent cookies stay on the device until they expire, or you delete them and are activated each time you visit our Site.  
  • Source. Cookies can be first party cookies or third-party cookies. First party cookies are placed directly by us and are used only by us.  Third party cookies are placed by third parties that provide services to us and/or to you. Third party cookies may be used by third parties to provide performance or analytics services to us or to place targeted ads or content for you.
  • Importance. Cookies can be essential or nonessential. Essential cookies are ones that websites need to operate, supporting essential functions. Non-essential optional cookies are those that can be turned off without losing the essential functionality of the website. Non-essential cookies are the ones that you may decide to disable or not allow to run when you are using or visiting our Site. 
  • Purpose. Cookies can be used for different purposes, including performance, functionality, or targeting. 
    1. Performance Cookies. Performance cookies (aka analytics cookies) enable us to see how easily you navigate the website and which features you use, so that we can improve your experience. 
    2. Functionality Cookies. Functionality cookies (aka Preference) enable us to provide additional functions to you on our website such as personalization and remembering your saved preferences. Some functionality cookies may be essential cookies.
    3. Targeting Cookies. Targeting cookies are placed (a) to show you ads and content tailored to your interests; (b) to limit the occurrence of ads shown to you; (c) to help measure whether the ad was effective; and (d) to help build a profile of your interests and web experience. 

WHICH COOKIES DO WE USE?

  1. Cookies We Use. We use different types of cookies on our Site, including:
  2. Technical, essential cookies that are strictly necessary to ensure the correct functioning of the Site and provide the services requested by you;
  3. Performance non-essential cookies that allow us to generate statistical reports about how you use the Site. These cookies show us when and how often you visit our Site, which pages you visit, and which links you click. 
  4. Functionality non-essential cookies that allow us to store your preferred language and location; 
  5. Targeting non-essential cookies that allow third parties, like YouTube and Dailymotion, to remember choices you make on our websites to target ads or content to you when you visit our Site. We and our advertising partners may use cookies on our Site to collect data about how you interact with our Site and other websites to improve the quality and relevance of ads on our Site and others. We and our ad partners may also use cookies to deliver ads to you when you visit our Site or after. Targeting cookies also help refine advertising and content relevant to your interests. If you deactivate these cookies, you may not be able to see or use sharing tools, play videos or use some functions on our site.  Currently, we are not using any targeting cookies.

HOW CAN YOU CONTROL YOUR OWN COOKIE USAGE?

COOKIE CONSENT. 

If you are a California resident, except for Strictly Necessary Cookies, you can accept or deactivate categories of cookies at any time by visiting our Privacy Preference Center tool. You can also control Cookies by adjusting the settings within your internet browser. Some features on our Site depend on Cookies. If you deactivate some Cookies, you may not be able to sign in or use features on our Site.  So, we may not be able to provide you with the best possible user experience on the Site if not all cookies are enabled. If you would like to refuse or opt out of our use of non-essential cookies later, you can do it at any time by deactivating cookies in your browser or device or our Privacy Preference Center. 

If you are in Europe, when we ask you to provide your consent to our use of non-essential cookies, you have the freedom not to provide such consent. If you do not provide your opt-in consent, and you are in Europe, we will not serve you our non-essential cookies. 

DEACTIVATE COOKIES. There are three ways you can deactivate cookies. 

  1. You can deactivate non-essential cookies at our Privacy Preference Center. 
  2. You can work with your browser to deactivate some or all non-essential cookies. Please consult the cookie management instructions of your browser:
    1. Apple Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
    2. Google Chrome: https://support.google.com/chrome/answer/95647
    3. Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
    4. Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
    5. Microsoft Edge: https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy
  3. You may be able to use one of the following third-party tools to decline the collection and use of information to serve you interest-based ads, although we cannot guarantee that all or any parts of our Site will respond to these signals.
    1. The NAI’s opt-out platform
    2. The EDAA’s opt-out platform
    3. The DAA’s opt-out platform

HOW CAN YOU CONTACT US?
If you have any questions about this Cookie Policy or our data protection practices, please contact us by using the following contact details:

Rago Wright, LLC
1440 West Hubbard Street, Chicago, Illinois 60640
Attn: Privacy Officer
Email: dpo@wright20.com
Toll-Free Phone: 888 445 0632
Privacy Request Form


1 The data controller that is responsible for the processing of personal data through the Website, including placing first-party cookies, is Rago Wright, LLC having a registered business address at 1440 West Hubbard Street, Chicago, Illinois 60640, the United States.

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