PRIVACY POLICY

1-WHO IS THE DATA CONTROLLER OF YOUR DATA PROCESSING?

The data controller and the owner of the website https://www.gorgeovs.com is GORGEOV’S FINE ART, SL. whose registered office at Pau Alcover 60, 08017-Barcelona (Spain), with tax identification number B10646594, registered at the Commercial Registry of Barcelona, volume 48322, page 580034, sheet 55, Inscription 1 (hereinafter Gorgeov’s)

Gorgeov’s has taken the necessary technical and organizational measures to comply with the data protection regulations.

The contact details of Gorgeov’s, related to privacy and protection of your personal data is:

privacy@gorgeovs.com

2- PERSONAL DATA WE PROCESS AND PURPOSES

1-Types of personal data we collect and process We may collect and process the following categories of personal data:

a. If you contact us to request information, we will process your contact details in order to answer your query or send you the requested information: Name, title, gender, and e mail.

b. If you agree to Gorgeov’s sell your piece or lot, or when you register to bid in an auction, or purchase a piece or a lot, or ask us to perform a valuation, your contact details, like Name, title, gender, VAT number, phone number, e mail, and location of the piece and any information relating to a dispute or legal proceeding, and other data necessary to proceed with the purchase, sale, auction, etc;

c. Economical or Financial information and information related to compliance of money laundering regulations; If you act representing a Company or Organization, your contact details, like Name, title, gender, phone number, e mail and your job title and whether you are a director, shareholder or partner.

d. If you want to buy a piece or lot exhibited in our direct sales rooms or through the auctions that we organize, as many details as are required to identify you and register as well as for the purchase, payment, and subsequent shipment, such as name, address, telephone, email, financial details and invoicing details.

e. We record your communications with us made by email or others.

f. When you sign up on Gorgeovs.com to receive news about upcoming sells, auctions and events relating to particular areas or complete your profile in your online account.

g. Information collected when you use our website and other digital media, if applicable. When you visit our website, we may record your IP address, browser type, operating system, originating website and web browsing behavior.

h. Information related to social networks.

Depending on your social network settings, we may receive information from your social network provider. For example, when you identify yourself with a social network account to use our services, we may receive your social network profile including contact details, interests, and contacts. For more information on the personal data, we receive from your social network provider and how to modify the settings, please refer to the website and privacy policy of your social network provider.

i. Information you choose to share with us. You can choose to share information with us, for example by giving us a comment through social media, completing a customer survey, or submitting data for an event.

j. Information that you provide us to initiate a staff recruitment process including your CV and other personal or professional information.

k. Gorgeov’s in the normal course of its business will not process any special category data.

2-Your personal data will only be used for the following purposes: a. Register your personal data in our database if you contact us, register your profile in your online account, or perform any transaction with Gorgeov's.

b. Carry out the necessary commercial and administrative procedures with the users of the web and our clients or suppliers. c. Contact you for contractual negotiations and to process your inquiries. d. In case of formalizing contracts, purchases or sells, the data shall be used to process the corresponding contracts. e. Communications with the police, courts, regulators or other government or law enforcement authorities in relation to you or your object, when mandatory. f. To send commercial advertising communications by email, social network or any other electronic or physical way, if you have expressly consented to the sending of said commercial communications electronically. If you are a client of Gorgeov’s, we may send you commercial information related to our special direct sells, auctions or the services that you have contracted. Communicate with you to answer your questions and process your complaints. g. Communicate with you to obtain your opinion on the service provided or the quality of our services. h. Likewise, the data collected during browsing is processed in order to provide access to the online content of the website, as well as to respond to the requests of the website users, to keep a record of visit statistics (IP addresses, browser data, country, page accessed, etc.) in order to help us develop better services and products, optimize our offer and provide more effective customer service and improve the design and content of our websites. i. The data of Clients and or Suppliers will be processed, within the contractual relationship that binds them with the person in charge, in compliance with the administrative, fiscal, accounting and labor obligations that are necessary under current legislation. j. Objection or revocation. You can object or revoke your consent to receive marketing communications at any time by following the instructions in the relevant marketing communication or by contacting us at privacy@gorgeovs.com k. If you fill in any of the forms provided on our website or in any other way, it will be necessary to provide certain personal data, which will be processed for the purpose for which they are requested. l. The personal data of our employees will be used to comply with the corresponding labor and contractual obligations. m. The purpose of the processing of your personal included in your CV or others you share with us during your participation in our staff recruitment process, is to carry on that process, and we inform you that: If it does not fit the profiles required by the Company and in compliance with data protection regulations, it will be immediately erased, and we will not keep a copy. If we consider that your profile may fit our needs, but there are currently no vacancies, we will keep it for a maximum of 1 year in case any vacancy arises during this period. After this period, it will be erased if no vacancy arises or if it does not fit in any of the processes we start. We will not keep any copies, although if it were of interest to us, we could ask you for an updated version. If your profile fits a position that is currently vacant, we will contact you shortly to initiate a selection process. In accordance with the current electronic commerce regulations, we inform you that Gorgeov’s does not perform SPAM practices, therefore, it does not send commercial emails by e-mail if it does not have the necessary legitimacy. In any case, you will always have the possibility to withdraw your consent to receive our communications. We shall not process your personal data for any other purpose than those described except by legal obligation or judicial requirement.

Your personal data will not be subject to decisions based on automated processing that produce effects on you.

Although Gorgeov’s carries out its activities worldwide, your personal data will be processed within the EU and there will be no international transfers of data outside the EU. However, if you are the buyer or seller of an item sold through Gorgeov's, we may need to provide your personal data for collection or delivery to an international transport agency based outside the EU. In such cases Gorgeov's will ensure that such transfer will be secure, and that the agency complies with current EU data protection regulations and has signed EU-approved standard contractual clauses.

3-WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA?

The legal basis for the processing of your personal data is: Performance of a contract: this is when the processing of your personal information is necessary to perform our obligations under a contract. E.g processing of the personal data of our clients, suppliers or employees. Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency, or in relation to the systems for prevention of money-laundering. Legitimate interests: we shall process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests. Your express consent: When you decide to share with us your CV or other personal data in a recruitment process or, in some cases, we would ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting Gorgeov’s at privacy@gorgeovs.com

The legal basis for the processing of the personal data of the suppliers is based on the contractual relationship that is generated when we contract with them. The legal basis for the processing of the data of our employees is based on the employment relationship.

Curriculum Vitae (CV) We inform you that in accordance with the provisions of the personal data protection regulations in case you send your CV to Gorgeov’s, it will be stored and processed in order to participate in the Staff selection processes carried out by us. The legal basis that legitimizes our processing is your expressed consent by voluntarily sending us your CV.

Likewise, we inform you that your CV shall be erased, and we shall not keep any copies, in case your profile does not match any of the positions offered by the Company. If your profile could potentially be interesting for the Company, your CV will be retained for a maximum period of two years for future Staff selection processes. During this period, you have the right to update your CV at any time. After this period has elapsed without being selected for any process, they shall be erased, and we shall not keep a copy or keep any of your personal data.

4. DATA RETENTION. ¿How long shall we keep your personal data?

We will retain your Personal Data for as long as is necessary to provide our services, to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. The personal data you provide us shall be kept for the time necessary to manage the information you request, or as long as there are contractual obligations deriving from services or content requested by users and subsequently until the expiration of legal, contractual or professional responsibilities that require its retention. The criteria used to determine our retention periods include: The time we have an ongoing relationship with you and provide the services to you (for example, for as long as you have an account with us or keep using our Services) Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them) Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations)

Once the data has met the needs for which it was collected, we will delete it permanently. However, we will keep your data longer, if necessary, to comply with legal obligations. Likewise, it may be necessary to keep them for the time necessary until the prescription of the legal responsibilities that are generated.

If we have your e mail in our database for the sending of commercial information, it will be kept if the necessary legal basis that legitimizes its conservation and use is maintained. You have the right to obtain from us the erasure of personal data concerning to your data at any time in order not to receive commercial information.

5. DATA RECIPIENTS

Your Personal Data will be processed by duly authorized personnel, and, if necessary or practical to fulfill the purposes indicated above, they may be processed, in certain cases, by third parties.

The categories of recipients to whom your Personal Data may be communicated are the following:

a. Data processors, such as IT providers, consultants and consultants and other companies. b. Public entities and Authorities, exclusively for the purpose of complying with legal and regulatory obligations, as well as the requirements of the police authorities if is requested. c. Other suppliers to whom, where appropriate, your personal data may be transferred, when is necessary for our normal operation, as financial institutions, insurers, among others. d. Gorgeov’s Shareholders.

Is your personal data transferred out of EEA? Gorgeov’s shall not, in the normal course of its business, transfer your personal data internationally (out of EEA) to countries which have not been approved by them as providing essentially equivalent data protection standards.

6. RIGHTS ¿what are your rights when you provide us with your data?

If you wish to exercise the rights that the data protection regulations grant you, please send us an e-mail to the following address privacy@gorgeovs.com putting in the subject the right you want to exercise and attaching a copy of your national identity document or passport or by sending the same content by postal mail to Gorgeov’s Fine Art, SL, C/ Pau Alcover 60 bajos 08017- Barcelona (Spain)

The Rights that the current regulations recognize and that, where appropriate, may be exercised are:

Right of access to data:

You have the right to be informed by the Data Controller if your personal data is being processed or not, and if the process is confirmed, you shall be able to access it by providing the following information: -The purposes of processing. -The categories of data. -The term or criteria for data retention.

Right to rectification:

You will have the right to order the Data Controller to rectify your data when they are inaccurate or incomplete by means of an additional rectifying statement.

Right to Erasure:

The data subject shall have the right to Data Controller erasing their data, when:  -The processing is illegal. -The data subject has withdrawn their consent. -They are no longer necessary in relation to the purposes for which they were collected or processed. -The data subject has exercised the right of opposition and other legitimate reasons for the processing do not prevail. -The data must be erased to fulfill a legal obligation of the Data Controller.

The data subject shall not have the right for the Data Controller to erase their data when the processing is necessary:   -To exercise the right to freedom of expression and information. -To fulfill a legal obligation of the Data Controller. -For the preparation, exercise or defense of claims. -For public interest based on current legislation for public health reasons or for historical, statistical or scientific research purposes.

Right to data portability:

You have the right for the Data Controller to transfer your data to another Data Controller or to the same data subject, through a structured format of habitual use and mechanical reading, when the processing is carried out by automated means and is based on: -The consent of the data subject for specific purposes. -The execution of a contract or pre-contract with the data subject.

The right to data portability will not apply when: -The transmission is technically impossible. -It can negatively affect the rights and freedoms of third parties. -The processing has a public interest mission based on current legislation.

Right to restriction of processing:

1.The data subject shall have the right to obtain from the Data Controller restriction of processing where one of the following applies: -the accuracy of the personal data is contested by the data subject, for a period enabling the Data Controller to verify the accuracy of the personal data; -the processing is unlawful, and the data subject opposes the erase of the personal data and requests the restriction of their use instead; -the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims; -the data subject has objected to processing, pending the verification whether the legitimate grounds of the controller override those of the data subject.

2.   Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

3.   A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

Right of opposition:

The data subject shall have the right to object to processing of personal data, on grounds relating to his or her situation, at any time. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Right not to be subject to profiling:

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, mainly when is referred to the following personal aspects:

-Professional performance. -Economic situation. -Health. -Preferences or personal interests. -Reliability. -Behavior. -Location or movements of the person.

When profiling is based solely on automated processing:   -The data subject will have the right to be informed if the decision that can be taken could have legal effects that significantly affect him. -The data subject will have the right to obtain human intervention from the Responsible, to express their point of view and to challenge the decision, if the processing has been authorized by: -The explicit consent of the data subject. -A contract between the Responsible and the data subject.

This right shall not apply if the decision:

-is necessary for entering, or performance of, a contract between the data subject and a data controller; -is authorized by European Union or Member State law to which the controller is subject, and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or -is based on the data subject's explicit consent.  

7- COMPLAINTS. SUPERVISORY AUTHORITY:

If you consider that Gorgeov’s has violated any of your rights protected by the personal data protection regulations or that it has violated any obligation regarding the protection of Personal Data, you have the right to submit a claim to the competent Supervisory Authority which in Spain is the Spanish Agency for Data Protection located at Calle Jorge Juan, 6. 28001 - Madrid. Tel. 901 100 099 - 912 663 517

You can also submit an electronic claim through the electronic address that is available on their website https://www.aepd.es

8. GOVERNING LAW AND JURISDICTION

This privacy policy is governed in each and every one of its extremes by Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons in regard to the processing of personal data and the free circulation of this data.

It is also governed by Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights. Likewise, our website is governed by Law 34/2002, of July 11, on Information Society and Electronic Commerce Services.

Any dispute arising from matters relating to the Site shall be exclusively subjected to the jurisdiction of the courts of the city of Barcelona.

9. ADDITIONAL INFORMATION

SECURITY MEASURES:

We understand that your personal data and your privacy is very important, and we are committed to treating it with maximum care and security.

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us.

The data you provide will be processed confidentially. Gorgeov’s has adopted all the technical and organizational measures and all the necessary levels of protection to guarantee the security in the treatment of the data and avoid its alteration, loss, theft, process, or unauthorized access, according to the state of technology and nature of the stored data. Likewise, it is also guaranteed that the processing and registration in files, programs, systems or equipment, premises and centers comply with the requirements and conditions of integrity and security established in current regulations.

SSL CERTIFICATE (SECURE SOCKETS LAYER)

We use reasonable safeguards to protect personal information against loss and theft, including encryption technology, restricted access, “firewalls,” and Secure Socket Layers (SSL). The SSL CERTIFICATE provides authentication, privacy and information security between Gorgeov’s and the user. Gorgeov’s has a security certificate that is used to make secure connections and is established using preset keys, encrypting, and decrypting all data sent until the connection is closed.

However, security over the internet cannot be guaranteed. Our Company does not assume any responsibility for any harm, loss, or damage you may experience or incur by the sending of personal or confidential information over the internet, and you should take your own measures to protect your sensitive information. If you have any questions about the security of our Site, contact us through privacy@gorgeovs.com

LANGUAGE

The language applicable to this Privacy Policy is English. Therefore, in case there is any contradiction in any of the versions we could provide in other languages, the English version will prevail.

GLOSSARY

Compliance with a legal obligation - processing is necessary to ensure we comply with our legal and regulatory obligations. Consent – you have given specific consent to the processing of your personal data. Data Controller – the person who determines the purposes and means of processing personal data. EEA – the European Economic Area which comprises countries that are members of the European Union and Norway, Iceland and Liechtenstein. Legitimate Interests - processing is necessary for our or a third party’s legitimate interests in carrying on, managing and administering our respective businesses effectively and properly (except where our or the third party’s interests are overridden by your own interests, rights and freedoms). Performance of a contract – processing is necessary to carry out our contractual duties, exercise our contractual rights or otherwise perform our contract with you, or to take steps at your request to enter a contract. Personal Data - any data relating to an identified or identifiable natural person. This can include names, user ID, location data, email addresses, photographs, job applications, purchase history, user account information, opinions, and correspondence to and from an individual. Processing - any operation performed on personal data, such as collection, recording, storage, retrieval, use, combining it with other data, transmission, disclosure or deletion. Public Interest – processing is necessary for the performance of a task carried out in the public interest. Special category data - details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health and genetic and biometric data.

10. UPDATE

This Privacy Policy was last updated in November 2023 but may be updated at any time. We recommend that you check it every time you access our page in case you have suffered alterations.