Privacy Policy

Last Update: January 2022

This privacy policy applies if you reside outside Canada and the US, such as if you are resident in the EEA (being the Member States of the EU and Norway, Iceland and Lichtenstein).

If you reside elsewhere, please review this other version instead.

Peggy Inc. (“Peggy”) brings together Galleries, Artists, Collectors and other stakeholders in the art ecosystem (collectively, our “Users”) to make living with and investing in art accessible to all.

Peggy is the controller of your personal information. Personal information is information that can identify you, such as your name, email address or home address, or information that could reasonably be linked back to you.

Peggy values and respects your privacy. We have prepared this privacy policy to explain the manner in which we collect, use and disclose personal information through our website located at Peggy.com (the “Website”), through any mobile device software provided by us to you (the “App”), and in our other interactions with you (collectively, the “Service”), and the ways that you can manage how your personal information is used, including the right to object to certain types of processing. See below for more information on your rights as a data subject.     

TABLE OF CONTENTS  

• Collection and Use of Personal Information
• Sharing of Personal Information
• Information About our Website
• Safeguards and Retention
• Access to Information
• Updates to the Privacy Policy
• Contact Us

 

COLLECTION AND USE OF PERSONAL INFORMATION 

We collect and use your personal information when you:

Apply to become a User (for Gallerists and Artists): Prior to becoming a Gallerist or Artist User, you must first apply for a User account. When you apply for an account, we collect your first and last name and an email address. We also collect certain additional information about you depending on whether you are a Gallerist or Artist:

• If you are a Gallerist, we collect the business contact information (such as name, phone number and email address) of one or multiple representatives of the Gallery, and any information that may be contained on the Gallery’s public websites or social media accounts.
• If you are an Artist, we collect the business contact information (such as name, phone number and email address) of one or multiple representatives of the Artist, information contained in your portfolio or CV (by asking you to send a link to your online portfolio or social media), and information about your medium of art. 

As outlined above, Gallerists and Artists are asked to provide Peggy with certain personal information relating to their representatives. If you decide to share such information with Peggy, it is your responsibility to inform such individuals of their rights and to obtain their authority to this sharing of personal information. These representatives should also be provided with a copy of this privacy policy so they know how Peggy will handle their personal information. 

If your application to become a Gallerist or Artist User is approved, we will invite you to create a public username. 

We use the above-noted information to process, evaluate, and respond to your application to become a Gallerist or Artist User, and to create and administer your online account. When you create or log-in to a User account, we will send a one time code to your email address, and ask you to verify that code in the App. Do not disclose your one-time code to anyone. We will never ask you for your one-time code in any communication from us (such as phone calls, text messages or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.

Create a User Account (for Collectors and other Users): When you create a Collector or other User account, we collect your first and last name, an email address, your city, optional information about your engagement with and interest in art and a public username. We use this information to create and administer your online account. When you create or log-in to a User account, we will send a one time code to your email address, and ask you to verify that code in the App. Do not disclose your one time code to anyone. We will never ask you for your one time code in any communication from us (such as phone calls, text messages or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.

Where we provide you with the option of applying for, signing up for, or logging in to an account with your Google account, we will collect your name, Google account email address, and account information for the purpose of authenticating you and administering your account. 

Join the User Waitlist

Prior to creating a User account, you could be invited to join a waitlist by providing your first and last name and your email address. We will contact you using the email address provided when we invite you to create an account.

Create and Share your Public User Profile: We offer Users the opportunity to create public User profiles through which they can create, curate, and share their art collections and artistic interests with other Users. 

When creating a profile, we will invite you to write a short bio that will be publicly viewable on your profile page, and upload a profile photo. The information you upload to your profile is public and viewable by other Users. Accordingly, you should be aware that any information you provide in these areas will be publicly viewable. Please see our Terms of Use for rules and restrictions regarding User Submissions (as defined therein).

We collect additional information from you to create your public User profile:

• Information about your Gallery: If you are a Gallerist, we invite you to add details to your profile about your Gallery, including an address and contact information for your Gallery, as well as photos or videos of your Gallery and links to your Gallery’s website or social media accounts. We also invite you to share information about Artists who are represented by your Gallery, as well as artworks exhibited and past or future exhibitions taking place at your Gallery. To the extent you share any information about Artists you represent,      it is your responsibility to inform such individuals of their rights and to obtain their authority to the sharing of personal information.
• Information about you as an Artist: If you are an Artist, we invite you to add details to your profile about you as an Artist, including an address and contact information for your Artist practice, as well as photos or videos of your Artist studio or artworks and links to your Artist website or social media accounts. We also invite you to share information about Galleries on the Service that represent you as an Artist. We invite you to share details about your work, including information about your process and interests, or your background, training, future or past exhibitions, publications or recent press, grants and awards, or your experiences as a student or teacher.      

As an Artist, you will also be required to provide certain information about yourself to be displayed on your User profile, including your date of birth (though only year of birth will be displayed publicly), place of birth, and current city.  

• Information about you as a Collector or other User: As a Collector or other User of the Service, we invite you to share information about yourself, including your occupation and education, your perspectives about art, the Artists you are interested in and follow through the Service, and the artwork in your collection.      

Use Pegboards: We invite Users to “pegboard” artwork to Pegboards that other Users can view and follow. Pegboards allow Users to curate and share artwork they find interesting. We use information about the market value of the artworks in User Pegboards to track the demand for and value of certain art pieces over time, allowing Users to understand the market for the artworks they have added to Pegboards. We also use Pegboards to personalise the User’s experience, features and content on the App. 

Connect with other Users: Connection is a key element of the Service. We allow our Users to invite, follow and be followed by other Users on the Service, and to view the profiles, Pegboards, and collections of other Users. Accordingly, please remember that any information you upload to your profile is publicly viewable and may be read, collected, and used by other Users. Please see our Terms of Use for rules and restrictions regarding User Submissions (as defined therein).

Buy and sell artwork: We collect and use certain personal information to facilitate the buying and selling of art by our Users, as described below:

     Buying artwork 

• When you offer to purchase artwork, we display information about the offer, including the amount and timestamp of the offer and your username. 
• When an offer is created, we will either ask you to provide your shipping address or, with your express consent, collect real-time information about the location of your device in order to help us determine your shipping address and estimated shipping costs.
• When you receive artwork you purchased using our Service, we will ask you to verify yourself as the new owner by scanning a fingerprint of the artwork using your smartphone. We will capture and store the fingerprint image(s) and associated metadata on our servers. 

Selling artwork

• When you add an artwork to our Service, we will ask the Artist or an authorized representative of the Artist to create a fingerprint of the artwork using their smartphone. We will capture and store the fingerprint image(s) and associated metadata on our servers.      
• If you wish to sell artwork using our Service and the artwork is not already captured from a previous sale, we will ask you to upload and display information about the artwork, including the asking price for the work, as well as photos of the work and information about its medium and size dimensions. You may also provide unique written or visual perspectives on the artwork, and can choose to indicate which Gallery, if any, represents the artwork. This information is public and viewable by other Users. 
• Any time you set an asking price for your artwork, we will either ask you to provide the location of the artwork or, with your express consent, collect real-time information about the location of your device in order to help us determine estimated shipping costs, shipping information and provide shipment tracking details to the buyer. We may ask you to confirm that the authentic artwork is in your physical proximity, by scanning a fingerprint of the artwork using your smartphone. We will capture and store the fingerprint image(s) and associated metadata on our servers. 

When you add or remove artwork (or asking prices for such artwork) to or from your collection            or when offers are added or removed for such artworks, we display to you and other Users insights and up-to-date information about the market value for artwork in your collection, including information about the total value of the collection, any realized gains and losses, the supply of and affordability of your collected works in relation to demand. In addition, we display purchase history for each piece of artwork, including asking, offer and purchase price information and the number of views it has received. 

Make or Receive Payments:                

If you are an Artist, Gallery or Collector selling an artwork, you can earn proceeds from the sale or resale of such artwork.  If you are an Artist or Gallery, you can earn royalties from the resale of your artwork.           

When you buy or sell artwork, or for the purposes of royalties, we collect your direct deposit/ card information (including payment method, card number, expiry date, the name on the card, and CVV code) or wire transfer information (including where applicable: a reference code, the name on the account, your phone number, the sending bank’s phone number, the sending bank’s address, account number, branch number, institution number, and SWIFT code) in order to process the payment. In the case of processing payouts for royalties, we also collect information about your nationality in order to determine the royalty rate applicable in your country. We do not store payment information entered through our Service; rather, we use a third-party payment processor who is Payment Card Industry Data Security Standard (PCI DSS) compliant to facilitate secure payment processing. We only use this information to process and deposit artwork sale payments, artwork resale payments, or royalty payments.

Verify your identity:  Before you upload artwork for sale, bid on artwork or transfer ownership of artwork, you will be required to verify your identity by providing a photo of your government-issued identification (driver’s license, passport, or government-issued photo identification card) and a real-time selfie photo. We verify your identity in order to track the provenance of the artwork that is sold from Users on our platform. We use a third-party service provider who matches the photo on your identification card to the selfie you upload and validates the authenticity of the selfie and identification card provided. Our third-party service provider is not authorized to use or retain this information for any other purpose.

Visit the Website and use the App: You do not have to register to visit or use our Website. However, when using the App, you are required to log-in using your User account. We collect some personal information when you visit our Website or use the App. Please see the "Information about our Website and App" section below for detailed information regarding the personal information we collect when you visit our Website or use the App, and the choices you have with regards to that collection and use. 

Sign-up to receive marketing communications: If you sign-up to receive email marketing communications such as newsletters, we collect your email address as well as other information on an optional basis to help us tailor our communications to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email or in the Settings section of the App. Please note that you may continue to receive transactional and account-related communications from us.

Custom Audience: We      use services provided by third-party platforms (such as social media and other websites) to serve targeted advertisements on such platforms to you or others, and we provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your information for such purposes, please send a request using any of the methods set forth in the Contact Us section below.

Connect with us on social media: We offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you can allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your social media account, we use this information to personalize your experience on the Website or App.

Create a Pegcast: When you agree to create a Pegcast (i.e., a podcast-like audio or video recording) with us, we will record, produce and edit audio, video or written content based on our interview(s) with you, and may post the Pegcast or other content to our Website and on our App. Pegcasts are publicly accessible by any User of the Service or visitor to our Website. You are responsible for obtaining the consent of any other identifiable individual for their appearance or their work’s appearance, or reference to them or their work in our interview with you.

Send or Receive Referrals: Our Website and App permit you to tell others about Peggy. We do this by providing you with a referral link or code, which you can then provide to a friend or family member for their use in accessing our App and applying to create an account. Any account that is created using your referral code will auto-follow your account.

When you create an account using a referral code, your account will auto-follow the account that is connected to the referral code you used. You can unfollow the account (or any other account) at any time. 

Participate in a contest or promotion: When you enter a contest or participate in a promotion, we will collect your name, address, email address, phone number, and any additional information or content required for the contest or promotion, including to deliver a prize to you, or that you otherwise provide, including your social media handle, profile picture and public posts or comments you make about our contest on social media networks. We use this information to administer the contest or promotion. As part of a contest or promotion, we can      also share or otherwise publish the content you submit.

Participate in a survey: From time to time, we can offer you the opportunity to participate in one of our surveys. The information obtained through our surveys is used in an aggregated, de-identified form. We use this information to help us understand our Users and to enhance our Website and App.

Contact Us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you for verification purposes, such as your name, mailing address, email address, or telephone number, along with additional information we need to help us promptly answer your question or respond to your comment.  We retain this information to assist you in the future and to improve our customer service and service offerings

HOW WE USE YOUR PERSONAL INFORMATION

We process your personal information including, but not limited to, the following types of personal data:

Information Category	Description	Purpose and relevant personal information	Applicable Legal Bases (under GDPR)
Gallerists, Artists and Collectors
Personal details and contact information	Your first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name.	We process this personal data to manage all aspects of our contractual relationship with you, including, but not limited to, providing the Service and other general administrative processes (including for User account applications and creation, joining the User waitlist, creating and sharing your public User profile).	We rely on contractual necessity to process your personal data where it is required for us to manage the contractual relationship with you in providing the Service.
Customer records	Your name, address, last 4 digits of credit card number, bank institution number, bank transit number, SWIFT code, bank account number, and telephone number	We process this data to manage all aspects of our contractual relationship with you, including but not limited to accepting offers in an auction, accepting asking prices in an auction, other auction actions, accepting payments from you to a Seller, and paying out payments to you from a      Buyer.	We rely on contractual necessity to process your personal data where it is required for us to manage the contractual relationship with you in providing the Service.
Business contact information	Name, phone number and email address of you or one or multiple representatives of your account.	We process this personal data to manage all aspects of our contractual relationship with you, including, but not limited to, providing the Service, providing customer support, and other general administrative processes.	We rely on contractual necessity to process your personal data where it is required for us to manage the contractual relationship with you in providing the Service.
Commercial Information	Products or services purchased, obtained, considered or sold, or other purchasing or consuming and selling histories or tendencies.	We process this personal data to recommend artworks you may be interested in buying or Pegboarding, recommend artworks you are selling to other buyers or Pegboarders, suggest Pegcasts that you may wish to watch or listen to, and suggest users that may be relevant for you to follow within the App.	We rely on contractual necessity to process your personal data where it is required for us to manage the contractual relationship with you in providing the Service.
Internet or other similar network activity information	History or browsing within our Website or App, history of searches conducted within our Website or app.	We process this information to provide convenience features to you to resume searches or browsing in order to make your experience within the Website and App more efficient, and to recommend artworks you may be interested in buying or Pegboarding, recommend artworks you are selling to other buyers or Pegboarders, suggest Pegcasts that you may wish to watch or listen to, and suggest users that may be relevant for you to follow within the App.	We rely on contractual necessity to process your personal data where it is required for us to manage the contractual relationship with you in providing the Service.
Professional background information	If your account is that of a Gallery: Personal information that may be contained on the Gallery’s public websites or social media account If your account is that of an Artist: Information contained in your profile bio, portfolio or CV, artist perspectives on artworks If your account is that of a Collector: Information contained in your profile bio, portfolio or CV, collector perspectives	We process this information to showcase it publicly on your profile to other users in order to help you sell art or buy art, since users’ buying and selling decision process may factor in such background information.	We rely on contractual necessity to process your personal data where it is required for us to manage the contractual relationship with you in providing the Service.
Pegboard information	We invite Users to “pegboard” artwork to Pegboards that other Users can view and follow. Pegboards allow Users to curate and share artwork they find interesting.	We use information about the market value of the artworks in User Pegboards to track the demand for and value of certain art pieces over time, allowing Users to understand the market for the artworks they have added to Pegboards. We also use Pegboards to personalise the User’s experience, features and content on the App, by providing convenience features to User’s to resume searches or browsing, recommending artworks that they may be interested in buying or Pegboarding, recommending artworks they are selling to other buyers or Pegboarders, suggesting Pegcasts that they may wish to watch or listen to, and suggesting other Users that may be relevant for the User to follow within the App.	We rely on contractual necessity to process your personal data where it is required for us to manage the contractual relationship with you in providing the Service.
Profile information	Any information you upload to your profile is publicly viewable and may be read, collected, and used by other Users. Please see our Terms of Use for rules and restrictions regarding User Submissions (as defined therein).	Connection is a key element of the Service. We allow our Users to invite, follow and be followed by other Users on the Service, and to view the profiles, Pegboards, and collections of other Users.	We rely on contractual necessity to process your personal data where it is required for us to manage the contractual relationship with you in providing the Service.
Photo of your government-issued identification (driver’s license, passport, or government-issued photo identification card) and a real-time selfie photo	Before you upload artwork for sale, bid on artwork or transfer ownership of artwork, you will be required to verify your identity by providing this information.	We verify your identity in order to track the provenance of the artwork that is sold from Users on our platform. We use a third-party service provider who matches the photo on your identification card to the selfie you upload and validates the authenticity of the selfie and identification card provided. Our third-party service provider is not authorized to use or retain this information for any other purpose.	We rely on contractual necessity to process your personal data where it is required for us to manage the contractual relationship with you in providing the Service.
IP addresses of visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website	You do not have to register to visit or use our Website. However, when using the App, you are required to log-in using your User account.	We use this information to help us understand our Website activity and to monitor and improve our Website.	Our legitimate interests in improving our Service
Email address, first name and last name	If you sign-up to receive email marketing communications such as newsletters, we collect your email address as well as other information on an optional basis.	We use this information to help us tailor our communications to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email or in the Settings section of the App. Please note that you may continue to receive transactional and account-related communications from us.	We rely on your consent to send you emails that you have signed up to. We also have a legitimate interest in promoting our Service
Hashed version of your email address	We use services provided by third-party platforms (such as social media and other websites) to serve targeted advertisements on such platforms to you or others, and we provide a hashed version of your email address or other information to the platform provider for such purposes.	To serve targeted advertisements on such platforms to you or others. To opt-out of the use of your information for such purposes, please send a request using any of the methods set forth in the Contact Us section below.	We have a legitimate interest in promoting our Service
Certain information associated with your social media account (e.g., name, username, email address, profile picture, gender)	We offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content in this manner, you can allow us to have access to certain information to deliver the content or as part of the operation of the website, plug-in or application.	We use this information for the purpose of personalising your experience on the Website or App.	We have a legitimate interest in promoting our Service.
Audio and visual recordings	When you agree to create a Pegcast (i.e., a podcast-like audio or video recording) with us, we will record, produce and edit audio, video or written content based on our interview(s) with you, and may post the Pegcast or other content to our Website and on our App.	For the purpose of creating Pegcasts, to be posted on the Website or App. Pegcasts are publicly accessible by any User of the Service or visitor to our Website. You are responsible for obtaining the consent of any other identifiable individual for their appearance or their work’s appearance, or reference to them or their work in our interview with you.	We have a legitimate interest in promoting our Service, including through Pegcasts
Referral code information	Our Website and App permit you to tell others about Peggy. We do this by providing you with a referral link or code, which you can then provide to a friend or family member for their use in accessing our App and applying to create an account.	This is for the purposes of referrals as any account that is created using your referral code will auto-follow your account. When you create an account using a referral code, your accounts will auto-follow the account that is connected to the referral code you used. You can unfollow the account (or any other account) at any time.	We have a legitimate interest in promoting our Service, including through referral links.
Contact information, and any additional information or content required for the contest or promotion or that you otherwise provide including your social media handle, profile picture and public posts or comments you make about our contest on social media networks	When you enter a contest or participate in a promotion, we will collect certain information.	We use this information to administer the contest or promotion, and to deliver a prize to you. As part of a contest or promotion, we can also share or otherwise publish the content you submit.	We have a legitimate interest in promoting our Service, including through running contents or promotions.
Survey response information	If we offer you the opportunity to participate in one of our surveys, we will request certain information. The information obtained through our surveys is used in an aggregated, de-identified form.	We use this information to help us understand our Users and to enhance our Website and App.	We have a legitimate interest in improving our Service.
Name, mailing address, email address, or telephone number, along with additional  relevant information	When you contact us with a comment, question or complaint, you may be asked for information that identifies you for verification purposes.	We use this information to help us promptly answer your question or respond to your comment.  We retain this information to assist you in the future and to improve our customer service and service offerings	We have a legitimate interest in providing and improving our customer service.

     

SHARING OF PERSONAL INFORMATION

We do not disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.

Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as hosting the Website and App, cloud storage, payment processing, shipping, insurance, customer support and issue-tracking capabilities, and providing advertising, analytics, and marketing services. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the U.S., Canada or other jurisdictions outside of the EEA.

Legal and Compliance: We and our service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable law or legal process, which may include lawful access by applicable courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Peggy Inc. or as part of a corporate reorganization or other change in corporate control.

INFORMATION ABOUT OUR WEBSITE AND APP

Visiting our Website: In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.

Push Notifications: If you provide your consent to receive push notifications, we may send push notifications to your mobile device to provide you with relevant information, such as: news about Peggy, including product updates and features; news about the community and other third-party services; suggestions for recommended artworks, artists and galleries; notifications when an Artist or Gallery you follow adds a new artwork, someone you follow creates a new Pegboard, someone adds an artwork to a Pegboard you follow, someone you follow adds a new Pegcast, someone Pegboards one of your artworks, someone places an offer on one of your artworks, your offer is outbid, your offer is the highest and won the auction, an asking price for an artwork you follow or have offered upon was reduced, one of your artworks sells; updates on royalties; new followers of your profile or Pegboard; and shipping notifications. If you wish to stop receiving push notifications from us, you can turn off push notifications for the App either within the App preferences page or in the settings of your mobile device.

Cookies:  Our Website uses a technology called "cookies". A cookie is a tiny element of data that our Website and App sends to a User’s browser, which may then be stored on the User’s hard drive so that we can recognize the User’s computer or device when they return. You can learn more about how we use cookies and similar technologies in our Cookies Policy.

Analytics: We use third parties such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the User experience and the Website. These third parties use cookies and other tracking technologies. 

For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

•  https://policies.google.com/technologies/partner-sites and
• https://support.google.com/analytics/topic/2919631

App Usage Information and Analytics: As with many applications, certain limited data is required for the App to function on your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the App accesses our servers. We use this information to help us understand the activity on our App, to monitor and improve our App, to verify that you are complying with our geographic restrictions in accordance with our Terms of Use, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-App experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our Users.

Third Party Links:  Our Website may contain links to other websites that Peggy does not own or operate. We provide links to third party websites as a convenience to the User. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

INTEREST-BASED ADVERTISING

We work with third parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website and App in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website, App and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns. If you do not want us or third parties to use data about your interests to serve you targeted ads, you may change your settings as described below and in the above section on cookies. To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.

You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.

SAFEGUARDS, ACCOUNT DELETION AND RETENTION

You can delete your User account at any time by contacting us at support@peggy.com. If you delete your account, information about the artwork you have purchased or sold will continue to be publicly viewable on the Service. However, any attribution of such information to you will be removed. Further, we may retain certain information to meet our legal or regulatory obligations.

We will retain your personal information only for as long as is necessary for the purposes set out in this privacy policy, including for the payment of royalties. Peggy will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your personal data to comply with applicable law), to resolve disputes and to enforce our agreements. Please note that on the termination of your contractual relationship with Peggy, Peggy may continue to retain your personal information for these purposes. Once specific retention timelines have passed and we have no further specific reason to retain that personal information, the relevant personal information will be erased. 

DATA TRANSFERS

In some cases, we may need to transfer your information to recipients outside the EEA for the purposes described in this privacy policy. If you are based in the EEA, Switzerland or the UK, and your personal data is transferred to a third country, some of these countries may not offer the same level of data protection as in your home country. 

Peggy relies on the European Commission’s adequacy decisions on certain countries to transfer your information from the EEA, namely Canada. Please find a list of the European Commission’s adequacy decisions here. In certain limited circumstances, we may use derogations, such as the contractual necessity derogation, where appropriate to process personal information, when there are no other data transfer mechanisms applicable. In all other situations where we transfer your information to outside the EEA, Switzerland or the UK, we do so in accordance with EU data protection law.

YOUR RIGHTS AND ACCESS TO YOUR PERSONAL INFORMATION

You have several rights in relation to your personal information, subject to applicable law. While some of these rights apply generally, certain rights apply only in limited cases.

Right of access - You have a right to request access to your personal information and to be provided with a copy of certain information including the categories of your personal information we collect and disclose.  

Right of rectification - You have the right to request that we rectify inaccurate personal information about you.

Right of erasure - You have the right, in certain cases, to request that we delete your personal information, provided there are valid grounds for doing so and subject to applicable law. 

Right to data portability - You may have the right to receive certain of your information in a structured, commonly used and machine-readable format and to transmit such information to another controller.     

Right to object (marketing) - You have the right to object to processing for direct marketing purposes at any time.

Right to object (legitimate interest) - Where we process your personal information based on legitimate interests, you can object to this processing in certain circumstances. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.

Right to restrict processing - You have the right, in certain cases, to temporarily restrict the processing of your information by us, provided there are valid grounds for doing so.

Right to withdraw your consent- Where we have sought your consent for certain processing activities, you have the right to withdraw that consent at any time. Please note that the lawfulness of any processing undertaken prior to your withdrawal of consent shall not be affected by the withdrawal.

Right to complain- You also have the right to lodge a complaint with your local supervisory authority for data protection. Click here to find your local supervisory authority.

However, these rights may not be exercised in certain circumstances, such as when the processing of your data is necessary to comply with a legal obligation or for the exercise or defence of legal claims. 

UPDATES TO THE PRIVACY POLICY

We may amend or update this privacy policy from time to time. The updated privacy policy will be made available through our Service and if we make any material changes to this privacy policy, we will contact Users directly by email for notification purposes. We will indicate at the top of this privacy policy when it was most recently updated.

CONTACT US

If you are resident in the EEA, Switzerland or the UK, Peggy Inc. is your data controller. 

If you have any questions or comments about this privacy policy or the manner in which we or our service providers process your personal information, or you wish to avail of any of your rights set out herein, please contact us at:

Privacy Officer

privacy@peggy.com

Exchange Tower, 130 King Street West, Suite 1800, Toronto, ON M5X 1E3, Canada     

                    

If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights, you have the right to lodge a complaint with your local supervisory authority for data protection. Click here to find your local supervisory authority.      For example, if you are based in the UK, you can make a complaint to the Information Commissioner’s Office (“ICO”). See the ICO’s page in relation to data protection complaints here.