EDWARDSTEICHEN.COM
PRIVACY POLICY
Last Updated: December 20, 2019
EdwardSteichen.com, including all of its features and content and related websites that we own and control (“Website”), is a service made available by the Estate of Edward Steichen (the “Estate”).
How This Privacy Policy Applies
Your privacy is very important to us, and in order to best protect your information, we have adopted this privacy policy (“Privacy Policy”), which applies to any and all information you submit to us in connection with your access to and/or use of the Website. This Privacy Policy describes the information we collect from you through the Website, how we use that information, and our legal basis for doing so. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us.
By using the Website, you are accepting the practices described in this Privacy Policy (including new versions of this Privacy Policy when and as they go into effect), and our Terms and Conditions of Use, which governs this Privacy Policy and contains all disclaimers of warranties and limitation of liabilities. Capitalized words not defined in this Privacy Policy are defined in the Terms and Conditions of Use.
What Information We Collect and Receive
In order for you to use our Website, we need to collect and process certain information, which depending on how you use the Website, may include:
Information you provide by using the Website, such as your name and email address when completing forms the Website. We may ask for this information if you subscribe to our newsletter or contact us;
Details of any requests or transactions you make through the Website. We may from time to time offer products for sale through the Website and partner with certain third-party payment processors to facilitate the transaction, in which case the payment information you submit to us will be collected and used by the payment processor in accordance with its privacy policy. Note, however, that where the Website may enable you to purchase certain goods and services from third parties, the terms and conditions of use, guidelines, rules, privacy policies, and other practices of the third-party merchant, and not this Privacy Policy, will apply to your use of that third-party merchant’s website and purchase of such products.
Information that is not personally identifiable, but that relates to your usage of the Website or that is necessary for the proper functioning or improvement of the Website, including: (i) times and dates and the extent of your usage of the Website; (ii) time zone, language, screen resolution, and other usage preferences you select when using the Website; (iii) device keyboard settings; (iv) usage history such as areas and pages within the Website that you access or use and/or which buttons on the Website you click on; (v) the search terms you entered into a search engine that may have led you to the Website; (vi) the Internet service provider or mobile platform you use, and (vii) other device and Website access information such as your browser type, operating system, Internet Protocol (IP) address, referring/exit pages, and other unique device identifiers; and
Communications you send to us, such as when you request support, send us comments or questions, or report a problem to us.
You can opt out of being included in Google Analytics at https://tools.google.com/dlpage/gaoptout. For more information about our use of data analytics to protect and improve our Website, see Cookies and How We Utilize Them below.
For more information about our use of data analytics to protect and improve our Website, see Cookies and How We Utilize Them below.
We also collect and maintain aggregated, anonymized, or pseudonymized information to protect the safety and security of the Website, improve the Website, or comply with legal obligations.
You may decline to provide us with some or all of your information. However, this will limit your ability to use the Website.
Types of Cookies We Utilize
We use the following types of cookies and other technologies:
Security: We secure the Website with cookies that facilitate security features and allow us to detect activity that might violate our rules and Terms and Conditions of Use, such as unauthorized access or activity.
Localization: Some cookies help us provide localized experiences, such as displaying the Website in the local language.
Site Features and Services: Certain cookies provide greater functionality to the Website and help us deliver our products and services.
Performance: We use performance cookies to help us route traffic between servers and understand how the Website is performing so we can provide users with the best experience possible.
Analytics and Research: Cookies and other technologies also help us to understand, improve, and research features and content on the Website, such as by using Google Analytics, which you can opt out of at https://tools.google.com/dlpage/gaoptout.
Marketing and Online Behavioral Advertising: Cookies help us deliver targeted advertisements through web browsers and on social media platforms based on your activity on the Website and to track the performance of those ads. In some cases, our partners may use cookies to provide us with information about your interactions with their services. Those third-party cookies would be subject to such third-party service’s privacy policies. The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes. Visit http://optout.aboutads.info/ to opt out of having your online behavior collected for advertising purposes.
Limiting or Blocking Cookies and Our Do Not Track Policy
Your browser may give you the ability to control cookies, which may depend on the type of cookie, and browsers can be set to reject browser cookies. However, blocking or deleting cookies may prevent you from using most of the Website.
Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. If you block cookies, certain features on the Website may not work. If you block or reject cookies, not all of the tracking described here will stop.
Note that certain options you select are browser- and device-specific.
Web Beacons
The Website may contain electronic images known as web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how the Website is used.
We use third parties to gather information about how you and others use the Website. For example, we will know how many users access a specific page and what Website Content they clicked on. We use this aggregated information to understand and optimize how the Website is used.
Social Media Plug-ins
We may implement the use of certain social media plug-ins (e.g., Facebook, Twitter, YouTube) to allow you to communicate with such services and interact (e.g., “like” or “comment”) with various Website content. The social media plug-in, if and when implemented, will enable a direct communication between your end user device and the servers of the applicable social media provider, allowing the applicable social media provider to communicate with you and collect information about you browsing our Website. This processing is based on Article 6, Section 1(f) of the EU general data protection regulation 2016/679 (“GDPR”) and represents our legitimate interest to improve your Website user experience and to optimize those services and functionalities offered via the Website. If you decide to use a social media plug-in that we implement on the Website, we may transfer your personal data whether or not you have a registered user account with the applicable social media provider. Please note that we are not responsible for the content and the data collection on respective third-party websites or apps and that we neither control the extent of personally information collected by the respective plug-in provider nor do we know the processing’s purpose or the period your personally information will be retained. For further information as to how and for what purpose certain social network providers process your data, please see the relevant privacy policies of the three main social network providers, and their notification when you connect to the social network in question.
Facebook Inc., 1601 S. California Avenue, Palo Alto, CA 94304, USA
https://de-de.facebook.com/policy.php
Twitter Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA
YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA
https://policies.google.com/privacy?hl=en
How We Use the Information We Collect
We use the information we collect for the following purposes:
To protect our Website;
To enable us to provide you with our Website, and to improve and promote our Website and services;
To address inquiries and respond to customer service requests, questions, and comments;
To contact you with newsletters, offers, promotions, and other product specials or to customize your experience on the Website;
To track and analyze use of the Website and our services, such as to identify trends, conduct data analysis, and determine the effectiveness of our marketing and promotion and other service offerings, so that we can improve how the Estate is performing and provide our users with the best experience possible;
To maintain security and to enforce our Terms and Conditions of Use and applicable law; and
For other purposes that we believe are necessary to protect our rights and the rights of others, or as otherwise described to you at the time of collection.
California Users
Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for those third parties’ direct marketing purposes. As explained elsewhere in this Privacy Policy, we will not sell or transfer your Personal Information to any third-party companies for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this statute or who have questions more generally about our Privacy Policy and our privacy commitments to our customers and Website users should not hesitate to contact us at info@edwardsteichen.com.
European Union Users
European Union data protection law requires a “lawful basis” for collecting and retaining personal information from citizens or residents of the European Economic Area. Our lawful bases include:
Consent: In certain cases, you have affirmatively provided us with your consent to collect your personal data for a specific purpose, such as providing your email address when you sign up for our newsletter.
Contract: We may need your personal data to comply with our contractual obligation to deliver the Website, such as fulfilling subscriptions or transactions.
Legal Obligations: Sometimes the law requires us to collect and use your data, such as applicable tax laws may require us to retain records of payments made through the Website.
Legitimate Interests: This is a technical term that means we have a good and fair reason to use your data and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we use identity, device, and location information to prevent fraud and abuse and to keep the Website secure, may also send you promotional communications about our Website and services subject to your right to opt out, analyze how users interact with our Website so we can understand better what elements do or do not work well, which allows us to improve and develop the quality of the online experience we offer all our users.
How We Share the Information We Collect
Information We Never Share Publicly
The following personal information is never publicly displayed:
Your name;
Your email address, IP address, mailing address, or phone number;
The date you register for any services we provide through the Website, such as a newsletter/mailing list;
Any other identity verification information or documentation;
Any payment information you provide; and
Communications you send to us.
Information We Share with Trusted Third-Party Service Providers
We may share certain information pertaining to you with certain trusted third-party service providers to help us provide, improve, promote, or protect the Website, such as if and when we partner with payment processors or use services to help us manage our ads on other websites. When we share data with third-party services to help us deliver the Website and our services, we require that those service providers use your information only for the purposes we have authorized and protect your personal information at least to the same standards we do. We may also share information that is aggregated and anonymized in a way that it does not directly identify you.
Information We Share to Protect the Estate and Comply with the Law
We reserve the right to disclose information we collect from or about you when we believe that doing so is reasonably necessary to comply with the law or law enforcement, to prevent fraud or abuse, or to protect the legal rights, property, or safety of the Estate or others. You hereby authorize us, to share or disclose your personal information, including, without limitation, any content, records, or electronic communications of any kind, when we determine, in our sole discretion, that the disclosure of such information is necessary to identify, contact, or bring legal action against you if and to the extent:
You are or may be violating the Terms and Conditions of Use or this Privacy Policy;
You are interfering with the rights or property of the Estate or a third party;
You are violating any applicable law, rule, or regulation;
Necessary or required by any applicable law, rule, or regulation; and/or
Requested by governmental authorities in the event of any investigation, act of terrorism, or instance of local, regional, or national emergency.
In the event that the Estate sells all or substantially all of its assets, we reserve the right, in any of these circumstances, to transfer or assign the information and content we have collected from our users as part of such sale or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used.
Links to Other Websites and Services
Our Website may include links to other websites or services whose privacy practices may differ from the Estate’s privacy practices as described in this Privacy Policy. When you click or otherwise use a link to an external website or service, the privacy policy and data processing disclosures for that website or service govern.
Data Retention
We will retain the information we collect from or about you as long as necessary to provide you with the Website or our services, or as otherwise set forth in this Privacy Policy, and to the extent set out in this Privacy Policy and as necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and protect the Estate’s legal rights. Additionally, we may retain indefinitely any aggregated, anonymized, or pseudonymized information which we may collect and maintain, and may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format.
Cross-Border Data Transfers
The Estate is based in the United States so your information will be collected and processed in the United States, which has its own laws governing data protection and access to it, including by the government. If you reside outside of the United States, be advised that the rules that protect your personal information under United States federal, state, and local law may differ from those of your home country.
With respect to any personal information that may be originally collected and stored in the European Economic Area, if and when we transfer your personal information to countries outside the European Economic Area, we will do so under the Commission’s model contracts for the transfer of Personal Information to third countries (i.e., standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as appropriate). For a copy of these Standard Contractual Clauses, please contact us at info@edwardsteichen.com
Children’s Privacy
The privacy of children is of the utmost importance, and we are committed to complying with the federal Children’s Online Privacy Protection Act (COPPA). The Estate does not knowingly collect, use, or disclose personal information from children under the age of thirteen (13). If we ever discover that we have inadvertently collected personal information from children under the age of thirteen (13) on or through the Website, we will delete it from our records as soon as possible. If you are a parent or legal guardian of a child under the age of thirteen (13) and believe that we have collected personal information from your child, please email us at info@edwardsteichen.com, and we will take steps to delete such personal information from our records as soon as possible.
Accessing Your Information
Users residing in certain countries, including citizens or residents of the European Economic Area, are afforded certain rights regarding their personal information. Except where an exception or exemption applies, these rights include the ability to access, correct, and request deletion of such user’s personal information. Even after you request we delete your personal information, we may retain certain information as required by law or as necessary for our legitimate business purposes.
More specifically, these users have the following rights:
The right to require free of charge (i) confirmation of whether we process your personal information and (ii) access to a copy of the personal information retained;
The right to request proper rectification, removal or restriction of your personal information;
Where processing of your personal information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal information concerning you in a structured, commonly used and machine-readable format or to have your personal information transmitted directly to another company, where technically feasible (data portability);
Where the processing of your personal information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;
The right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and
The right to take legal actions in relation to any breach of your rights regarding the processing of the personal information, as well as to lodge complaints before the competent data protection regulators.
As far as we process your personal information on the basis of our legitimate interests, you can object to processing at any time. You can find a detailed description of our processing activities and the legal basis herein. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal information and decide whether to adjust the processing accordingly.
Email Notifications
We want to communicate with you only if you want to hear from us. You may elect to receive certain marketing email communications, in accordance with your preferences, and from which you may opt out at any time by adjusting your notification settings. We will also send you service-related announcements when and as necessary. We try to keep emails to a minimum and give you the ability to opt in to any marketing communications we send.
We maintain a strict no-spam policy. We will not use false or misleading subjects or email addresses, identify the message as an advertisement in a reasonable way, include the physical address of our business, monitor our third-party email marketing services for compliance, honor opt-out/unsubscribe requests quickly, and allow users to unsubscribe by using the link at the bottom of each email. If you are having problems unsubscribing please contact us at info@edwardsteichen.com by forwarding the email communication and including the word “Unsubscribe” in the subject line and we will use reasonable efforts to remove you within seven (7) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.
Security
We take security seriously, and the security of your personal data is important to us. We follow industry-standard practices to protect the data we collect and maintain, including using Secure Sockets Layer (SSL) to encrypt information as it travels over the Internet.
However, the Internet is, by nature, not a secure environment and the nature of security risks is constantly evolving as are the technical and organizational industry standards relating to management of those risks. While we strive to keep current our security technology and will review, refine, and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, the complete security of any information collected, stored or used by us cannot therefore be guaranteed. In the unlikely event that an unauthorized third-party compromises the Estate’s security measures, the Estate will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information.
Updates to this Privacy Policy
We may change the terms of this Privacy Policy at any time. Whenever we make a material change, we will post on the Website or send you an email. The effective date of the most recent version of this Privacy Policy will appear at the top of this page. New versions of this Privacy Policy will never apply retroactively.
Contact
Questions or comments about this Privacy Policy should be sent by email to info@edwardsteichen.com.