Privacy Policy

The following is the privacy policy (the "Privacy Policy") under which you (the "User") may use the Russian Paintings Gallery's (the "Company") web site (the "Web Site" - https://paintinggallery.pro). Please read this page carefully. By accessing and using the Web Site, you accept and agree to be bound, without modification, limitation or qualification, by the Privacy Policy.

YOUR USE OF THE WEB SITE CONSTITUTES YOUR AGREEMENT TO ALL TERMS, CONDITIONS, AND NOTICES CONTAINED HEREIN. IF YOU DO NOT ACCEPT ANY OF THE PROVISIONS OF THE PRIVACY POLICY, DO NOT USE THE WEB SITE.

Section 1. Types of data collected

Complete details on each type of personal data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed prior to the data collection.

Among the types of personal data that this Web Site collects there are: cookies, usage data, email address, data communicated while using the service. Personal data may be freely provided by the User, or, in case of usage data, collected automatically when using this Web Site.

Unless specified otherwise, all data requested by this Web Site is mandatory and failure to provide this data may make it impossible for this Web Site to provide its services. In cases where this Web Site specifically states that some data is not mandatory, the User is free not to communicate this data without consequences to the availability or the functioning of the service.

The User who is uncertain about which personal data is mandatory is welcome to contact the Company. Any use of cookies – or of other tracking tools – by this Web Site serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document.

The User is responsible for any third-party personal data obtained, published or shared through this Web Site and confirm that he has the third party's consent to provide the data to the Company.

Section 2. Methods of processing the data

The Company takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data.

The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Company, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of this Web Site (administration, sales, legal, system administration) or external parties (third-party email carriers and hosting providers) appointed, if necessary, as data processors by the Company. The updated list of these parties may be requested from the Company at any time through the contact details provided in the contact section of the Web Site.

Section 3. Legal basis of processing the data

The Company may process personal data relating to the User if one of the following applies:

• - the User has given his consent for one or more specific purposes. Note: under some legislations the Company may be allowed to process personal data until the User objects to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of personal data is subject to European data protection law;
• - provision of data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• - processing is necessary for compliance with a legal obligation to which the Company is subject;
• - processing is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Section 4. Place of processing the data

The data is processed at the Company's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's data to a country other than his own.

If any such transfer takes place, the User can inquire with the Company using the information provided in the contact section of the Web Site.

Section 5. Retention time

Personal data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• - Personal data collected for purposes related to the performance of a contract between the Company and the User shall be retained until such contract has been fully performed.
• - Personal data collected for the purposes of the Company's legitimate interests shall be retained as long as needed to fulfill such purposes. The User may find specific information regarding the legitimate interests pursued by the Company within the relevant sections of this document or by contacting the Company using the information provided in the contact section of the Web Site.

Once the retention period expires, personal data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Section 6. The purposes of processing the data

The data concerning the User is collected to allow the Company to provide its service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of the User), detect any malicious or fraudulent activity, as well as the following: analytics, advertising, handling payments, interaction with external social networks and platforms, SPAM and DDoS protections, interaction with live chat platforms, content commenting, contacting the User.

For specific information about the personal data used for each purpose, the User may refer to the section 'Detailed information on the processing of personal data'.

Section 7. Detailed information on the processing of personal data

Analytics. The Company uses its own web software to monitor and analyze web traffic and to keep track of the User behavior. No third-party web analysis services are used.

Advertising. This type of service allows User data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Web Site, possibly based on User interests. This does not mean that all personal data are used for this purpose. No third-party advertising services are used.

Handling payments. Unless otherwise specified, the Company processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, the User is requested to provide his payment details and personal information directly to such payment service providers. The Company isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Interaction with external social networks and platforms. This type of service allows interaction with social networks or other external platforms directly from the pages of this Web Site. The interaction and information obtained through this Web Site are always subject to the User's privacy settings for each social network.

SPAM and DDoS protections. This type of services analyze the traffic of this Web Site, potentially containing Users' personal data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM and/or DDoS. Google reCAPTCHA and other similar third-party services are not used. SPAM protection is provided by Google's Gmail services. DDoS protection is provided by Cloudflare's services.

Interaction with live chat platforms. This type of service allows the User to interact with third-party live chat platforms directly for contacting and being contacted by this Web Site support service. If one of these services is installed, it may log live chat conversations. No User data is transferred deliberately by the Company to third parties who own this live chat platforms.

Content commenting. Content commenting services allow the User to make and publish his comments on the contents of the Web Site. The User may not leave anonymous comments. An email address among the personal data provided by the User may be used to send notifications of comments on the same content. The User is responsible for the content of his own comments. No third-party commenting services are used.

Contacting the User. The User may be contacted personally by email or by third-party live chat platforms for purposes related to the performance of a contract between the Company and the User. No built in or third-party bulk email services are used.

Section 8. The rights of the User

The User may exercise certain rights regarding his data processed by the Company by contacting the Company at any time through the contact details provided in the contact section of the Web Site.

In particular, the User has the right to do the following:

• - Withdraw his consent at any time. The User has the right to withdraw consent where he has previously given his consent to the processing of his personal data.
• - Object to processing of his data. The User has the right to object to the processing of his data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• - Access his data. The User has the right to learn if data is being processed by the Company, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
• - Verify and seek rectification. The User has the right to verify the accuracy of his data and ask for it to be updated or corrected.
• - Restrict the processing of his data. The User has the right, under certain circumstances, to restrict the processing of his data. In this case, the Company will not process the data for any purpose other than storing it.
• - Has his personal data deleted or otherwise removed. The User has the right, under certain circumstances, to obtain the erasure of his data from the Company.
• - Receive his data. The User has the right to receive his data in a structured, commonly used and machine readable format.
• - Lodge a complaint. The User has the right to bring a claim before his competent data protection authority.

Section 9. Details about the right to object to processing

Where personal data is processed for a public interest, in the exercise of an official authority vested in the Company or for the purposes of the legitimate interests pursued by the Company, the User may object to such processing by providing a ground related to his particular situation to justify the objection.

Section 10. How to exercise these rights

Any requests to exercise the User rights can be directed to the Company through the contact details provided in the contact section of the Web Site. These requests can be exercised free of charge and will be addressed by the Company as early as possible and always within one month.

Section 11. Cookie policy

This Web Site uses so-called 'technical' cookies to enable basic interactions and functionalities, allowing the User to access selected features of the Web Site and facilitating the User's communication with the Company. No third-party cookies are used.

Section 12. Additional information about data collection and processing

Legal action

The User's personal data may be used for legal purposes by the Company in court or in the stages leading to possible legal action arising from improper use of this Web Site or the related services.

The User declares to be aware that the Company may be required to reveal personal data upon request of public authorities.

Additional information about User's personal data

In addition to the information contained in this Privacy Policy, this Web Site may provide the User with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

System logs and maintenance

For operation and maintenance purposes, the server of the Web Site may collect files (system logs) that record interaction with this Web Site such as the IP address, date and time, visited pages of the Web Site.

Information not contained in this policy

More details concerning the collection or processing of personal data may be requested from the Company at any time through the contact details provided in the contact section of the Web Site.

How "do not track" requests are handled

This Web Site does not support "do not track" requests.

Changes to this Privacy Policy

The Company may, at its sole discretion, modify or revise the Privacy Policy at any time by updating the text of this page. The User is bound by any such modification or revision and should therefore visit this page periodically to review the Privacy Policy. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Last modified: 10 December 2021.