- National Gallery of Fine Art

1. SCOPE AND APPLICATION

National Gallery of Fine Art, as a joint data controller understands the importance of our customers’ privacy. This Privacy Policy describes the treatment of information we collect from and about you when you visit our websites or use our apps and other services that contain a link to this Privacy Policy or otherwise refer to or provide the URL to this Privacy Policy (collectively, the “Services”). Our Privacy Policy also describes other sources we use to obtain information about you; tells you how we use, share and protect your information; and what choices you have about how your information is used and shared. By using the Services, you agree to the terms and conditions of this Privacy Policy and consent to our collection, use and disclosure of your personal information in the manner set out below.

We do not knowingly permit children under age 13 (in the United States) or age 16 (in the EEA) to register for any content, product or Service. We do not knowingly collect, use or disclose personal information about users under age 13 (in the United States) or age 16 (in the EEA), except as permitted by law. In recognition of the need to provide additional privacy protections for children, we have a separate privacy policy that applies to those sites and apps that are directed to them.

For purposes of this Privacy Policy, “personal information” means information that identifies a specific person or that is about an individual who can be identified, such as full name, email address, newsletter choices, magazine or product purchases, consumer product preferences.

2. COLLECTION OF INFORMATION

Information You Provide Directly to National Gallery of Fine Art

If you are interested in obtaining information, products or services from National Gallery of Fine Art, or participating in certain activities through the Services, you may need to provide us or our service providers with information about yourself. For example:

· If you register for a Service to become a member, receive a newsletter, or get information about National Gallery of Fine Art’s promotions or events, you may be asked for your name, email address, mailing address, phone number and other information.

· If you order a product from us or one of our business partners, you may be asked for your name, postal address, email address, telephone number and your credit card number.

· If you participate in an activity such as a survey or sweepstakes, you may be asked for your name, email address and birth date, and also to provide other types of information such as gender and personal interests, which may be associated with other personal information that has been obtained from or about you.
Sensitive Information. We ask that you not send us, and you not disclose, any sensitive personal information (such information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Services or otherwise.

Information We May Collect Automatically

In addition to information you choose to provide to us, National Gallery of Fine Art and our service providers also use standard technologies to automatically collect certain additional information. For example:

· IP Address and Other Identifiers. When you access and interact with our Services, National Gallery of Fine Art and our service providers may collect information about your visits in order to permit you to connect to and obtain the Services and to understand the frequency with which specific visitors visit various parts of our Services. For example, we may collect your Internet Protocol (“IP”) address, which identifies the computer or service provider that you use to access the Services, or information about your browser type, authentication identifiers, and other software and hardware information. If you access the Services through a mobile or other device we may collect your mobile device identifier, geolocation data (including your precise location), or other transactional information for that device. We may combine this information with other information that we have collected to make our Services and our communications to you more targeted to your interests.

· Social Media Information and Content. If you access or log into a Service through a social media service or connect a Service to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access the Services through social media services or when you connect a Service to social media services, you are authorizing National Gallery of Fine Art to collect, store, and use such information and content in accordance with this Privacy Policy.

· Cookies and Other Tracking Technologies. Our Services may also use cookies. Cookies are small text files that are stored on a user’s computer and allow websites to remember information about users. We and our service providers use cookies for a variety of purposes in order to enhance the quality of our sites. We use transient (also called “session ID”) cookies to provide continuity from page to page. A session ID cookie expires when you close your browser. We also use persistent cookies. Persistent cookies allow our online store and certain other parts of our site to recognize your browser when you return after your first visit to that part of our site. Cookies allow us to personalize your return visits to our site and to save you time during certain activities, such as checking out from our online store. You have the choice to set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) You can manage the use of Flash technologies, with the Flash management tools available at Adobe’s website, see http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. It is up to you whether to allow us to send you cookies. Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the Services.

· Web beacons and other tracking technologies. The Services may use other tracking tools, including so-called “pixel tags,” “web beacons,” “web bugs,” “clear GIFs,”etc. (collectively “Web Beacons”) to collect user activity information about your activities on the Services. These are small electronic images embedded in web content (including online ads) and email messages and are ordinarily not visible to users. Like Cookies, Web Beacons enable us to track pages and content (including ads) accessed and viewed by users. Also, when we send HTML-formatted (as opposed to plain text) emails to you, Web Beacons may be embedded in such emails to allow us to monitor readership levels so that we can identify aggregate trends and individual usage to provide our audiences with more relevant content or offers. Web Beacons in emails may recognize activities such as when an email was opened, how many times an email was forwarded, which links in the email were clicked on, etc. Web Beacons cannot be declined when delivered via a regular web page. However, Web Beacons can be refused when delivered via email. If you do not wish to receive Web Beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.

· Third Party Tracking. Third parties that support the Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate the Services usage statistics, may also use these technologies to collect similar information when you use the Services (such as websites and emails). These third parties may also use these technologies, along with activity information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer. National Gallery of Fine Art does not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, see www.aboutads.info/consumers, and to opt-out of such ad networks’ and services’ advertising practices, go to www.aboutads.info/choices.

· Please visit our Cookie Policy for more information on the Cookies and other tracking technologies present on our Services.

· Information Contained in User Content

· Some parts of our Services may allow users to post or transmit messages, comments, screen names, computer files and other materials. You should be careful about what personal information you choose to make public through these Services.

· Information from Other Sources

· To the extent permitted by law, National Gallery of Fine Art and our service providers may supplement the information we collect from and about you with information from other sources, such as publicly available information about your online and offline activity from social media services, commercially available sources and information from National Gallery of Fine Art Affiliates or business partners.

3. USE AND DISCLOSURE

National Gallery of Fine Art and our service providers may use information that we collect from and about you for a variety of business purposes, including:

· to maintain and manage your account, deliver content and services that you request, improve the Services and enhance your experience on our Services;

· to process and track your product or service orders and provide the Services and content you request;

· to communicate with you about the content and Services or other products, content or services in which you may be interested, or to respond to your inquiries or comments;

· to contact you. National Gallery of Fine Art may periodically send notifications related to the Services such as notifications of changes to the Services or policies;

· to offer you branded, co-branded or other services, products, or features, such as travel services and products. By virtue of such relationships, we may share the information you submit in connection with the service with the third party (provided that you have consented to this). The third party’s use of your information will be governed by the third party’s privacy policy;

· to deliver relevant advertising and marketing. National Gallery of Fine Art and our service providers may use the information we collect from and about you as described in this Privacy Policy to deliver relevant ads to you when you use the Services (on any of your devices) or another service (on any of your devices). As noted above, third-party advertising networks and advertisers may use cookies and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and information about the different devices you use and your activity on such devices, to assist them in delivering advertising that is more relevant to your interests. The information may also be used to deliver more relevant advertising to you across marketing channels, including email. If you would like to opt-out of such ad networks’ and services’ advertising practices on the device on which you are accessing this policy, go to http://optout.aboutads.info/ to opt-out in desktop and mobile web browsers. You may download the AppChoices app at www.aboutads.info/appchoices to opt-out in mobile apps. If you want to stop receiving National Gallery of Fine Art promotional materials, you can follow the unsubscribe instructions in our communications;

· to allow social sharing functionality. If you log in with or connect a social media service account with the Services, we may share your user name, picture, and likes, as well as your activities and comments with other National Gallery of Fine Art Services users and with your friends associated with your social media service. We may also share the same information with the social media service provider. By logging in with or connecting your Services account with a social media service, you are providing your consent to us to share information we collect from and about you with the social media service provider, other users and your friends and you understand that the social media service’s use of the shared information will be governed by the social media service’s privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with your account and do not participate in social sharing on Services;

· to perform business analyses or for other purposes to improve the quality of our business, the Services, and the products and services we offer;

· To protect the rights of Company and others. There may be instances when Company may use or disclose your information, including situations where Company has a good faith belief that such use or disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Company, our Company Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the Company Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities;

· to complete a merger or sale of assets. If National Gallery of Fine Art sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), National Gallery of Fine Art may transfer your information to the party or parties involved in the transaction as part of that transaction; or in accordance with your consent.

· In order to make our content, Services and advertising more interesting and relevant to you, we may use the information we collect from and about you to make inferences and predictions about your potential areas of interest. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.
National Gallery of Fine Art will disclose your personal information as described in this Privacy Policy, including:

· with entities that help us to manage and provide the Services, including development of our websites and applications, maintenance and support, personalization, payment processing, email distribution, measurement and improvement, sweepstakes/contest administration, booking, fulfilment, and operation of travel services and products, and promotions management, only to the extent that these entities need the information to perform their services or as required by law;

· with our National Gallery of Fine Art Affiliates. You agree and consent that National Gallery of Fine Art may share your information with National Gallery of Fine Art Affiliates for the purposes described in this Privacy Policy. This may include transferring information to other countries (including countries other than where you are based) that have a different data protection regime than is found in the country where you are based which may include countries outside of the EEA including the United States. Users who visit National Gallery of Fine Art Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy;

· with identified entities whose products or services you specifically use or request to receive while you use the Services;

· with our business partners, such as travel operators. Their use of your personal information will be governed by their own privacy policies;

· with third parties in in the ordinary course of business in order to process your requests and fulfil your orders for video content offered through the Services;

· with your consent, with other selected third parties so that they may send you promotional materials about goods and services that they offer;

· in response to legal process and when we believe that doing so is required by law (including laws applicable to our Affiliates and service providers), may be necessary to protect any person’s property, rights, or safety, or to investigate a potential violation of law, will help to enforce any terms of use or other legal agreement, or in the event of a corporate transaction, such as a divestiture, merger, consolidation, bankruptcy or asset sale;

· in accordance with your consent.

National Gallery of Fine Art, and its Affiliates, service providers, business partners and other individuals described above, may be located outside of your country of residence, including, among others, in the United States (Canada and EEA). These countries may have different data protection regimes than is found in the country where you are based.

When information we collect is aggregated, anonymized or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

4. INFORMATION SECURITY

We take a number of commercially reasonable administrative, technical, personnel and physical measures designed to safeguard information in our possession from loss, theft and unauthorized use, disclosure or modification. However, no one can guarantee the complete safety of your information.

5. USER ACCESS AND CONTROL

If you would like to access, review, correct, update, suppress, delete or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us using the mechanisms provided below. We will try to comply with your request as soon as reasonably practicable.

You may opt out of having your personal information used or disclosed for certain purposes.
· If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these emails be clicking “Unsubscribe” or “Update my Preferences” at the bottom of any marketing email you receive.

· If you continue to receive our communications in error after expressing an opt-out preference, please let us know so that we can investigate the situation.

· If you are under 18 and a registered user of the Services, you may request removal of content or information that you have publicly posted to the Services. To make such a request, please go email [email protected]. Please identify “privacy” in the description of your request and select “User Content Removal” as the option that best describes your type of inquiry. Please also provide your name, email address, and a detailed description of your content removal request in the designated spaces. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user. There may also be circumstances where the law does not allow removal of your content even if requested.

6. OTHER IMPORTANT INFORMATION

Changes in this Privacy Policy. We may amend this Privacy Policy at any time by posting the most recent version of the Policy on the Services, along with an indication of the date on which the Policy was amended most recently. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. If we make any material changes to this Privacy Policy in the way we collect, use, and/or share personal information through the Services in a manner that expand our rights to use the personal information we have already collected from you, we will notify you and provide you with a choice about our future use of that information.

Location of Data. The Services are hosted in and managed from the United States. If you are a user located outside the United States, you understand and consent to having any personal information (which may include information collected through the use of cookies and other technologies, as described above) processed in the United States or in any other country in which we have facilities or in which we engage service providers. United States and other countries’ data protection laws may not be the same as those in your jurisdiction. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States may be entitled to access your personal information.

Data Retention. We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

Remember that even after you cancel your account, or if you ask us to delete your personal information, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services. Because of the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, for fraud detection or to comply with applicable law or our internal security or record-keeping policies. It may not always be possible to completely remove or delete all of your information due to technical constraints or, contractual, financial or legal requirements.

Third-Party Sites. If you click on or interact with a hyperlink or advertisement that you find on the Services, you may leave our Services or send information to a different website or application. Our Privacy Policy does not apply to your interactions with third-party websites or mobile apps, even if you find a link to them on or access them through our Services, and so you should read the privacy policy of the third-party provider to see how your personal information will be treated on its site. We have no control over such third-parties, their Internet sites, or their products or services.

Collection of Personal Financial Information by a Payment Service. In some cases, we may use an unaffiliated payment service to enable you to purchase a product or make payments on a third-party payment service provider website (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a page operated by that Payment Service. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.

7. THE GDPR AND ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (“EEA”)

If you are a resident of the European Economic Area (“EEA”) and the Services are targeted to you, please note:
· The EU General Data Protection Regulation (GDPR) is a new comprehensive data protection law that updates existing EU laws to strengthen the protection of “personal data” (any information relating to an identified or identifiable natural person, so called “data subjects”) in light of rapid technological developments, the increasingly global nature of business and more complex international flows of personal data. The GDPR replaces the current patchwork of national data protection laws with a single set of rules, directly enforceable in each EU member state. The GDPR takes effect on May 25, 2018. We may need to collect and process the types of Personal Information listed above in order to provide the Services to you or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide you with the Services. We may use the Personal Information for our legitimate business interests, including those listed above.

· We do not knowingly permit children in the EEA under age 16 to register for any content, product or Service. We do not knowingly collect, use or disclose personal information about users under age 16, except as permitted by law. In recognition of the need to provide additional privacy protections for children, we have a separate privacy policy that applies to those sites and apps that are directed to them.

· If you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company, you may contact us at [email protected].

· Regarding the section entitled “Location of Data” in Section 6, above: Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. The full list of these countries is available at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting [email protected] and providing your contact information, selecting “Other” from the drop-down menu and providing a brief description in the text box available.

· Regarding the section entitled “Data Retention” in Section 6, above: We keep your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you and provide the Services to you; (ii) as required by a legal obligation to which we are subject; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

· You may contact us at [email protected] with any questions about this Privacy Policy.

· You may lodge a complaint with a supervisory authority competent for your country or region.

8. CONTACT US

If you have additional questions regarding this privacy policy, please contact us at:
Email: [email protected]
Or
National Gallery of Fine Art
Attn: Business and Legal Affairs – Privacy
12930 Worldgate Drive, Suite 300
Herndon, VA 20170