Privacy Policy Effective Date: January 28, 2025Welcome to Pace Gallery’s privacy policy. We are committed to the protection of any personal information we obtain from you by any means, whether at one of our galleries, through this website or otherwise in communication with you or in connection with the operation of our business.This privacy policy describes the types of information we collect about you, how we use it, how you can manage the information we have about you, and how you can contact us. Our privacy policy applies to “personal data” (which is defined in applicable data privacy law as information which can identify living people). Where we refer to personal data below, we use the term “personal information”.The contents of our privacy policy may change from time to time. Please check it now and again for any updates. This privacy policy was last updated on the date at the beginning of this privacy policy.It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.Some regions, such as California, provide additional rights by law, as described below. Read More A. Who we are and how to contact usThe Pace Gallery operates internationally and represents clients and artists in the contemporary art space. Our international group of galleries seeks to provide a seamless service to all Pace clients and artists located anywhere in the world. This privacy policy relates to all companies within our international group of Pace Galleries and all affiliated and related companies from time to time – the “Pace Group”, so when we mention the “Pace Group”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Pace Group responsible for processing your personal information. We will let you know which entity will be the controller for your personal information when you purchase a product or service with us. The Pace Gallery LLC is the controller and responsible for this website.Each of the companies within the Pace Group may collect and process your personal information in particular circumstances, however personal information is only shared between the companies in the Pace Group where we have a lawful justification for doing so.Here is a list of the companies in our Pace Group:New York Gallery and Los Angeles Gallery, USAThe Pace Gallery LLCLondon Gallery, UKThe Pace Gallery Limited (Registered with the UK Information Commissioner, number ZA650597)Hong Kong GalleryPace Art HK LimitedSeoul Gallery, South KoreaPace Art Korea LtdGeneva Gallery, SwitzerlandThe Pace Gallery SARLBeijing Office, ChinaPaceart (Beijing Commercial Company Limited)Tokyo Gallery, JapanPace Gallery Japan GKOur Joint venture company, New York, USAAGP Ventures LLPTribeca gallery, New York, USA125 Newbury LLCIf you have any questions or comments about this privacy policy, please contact us via:Telephone: +1 (212) 421 3292 or +44 (0)20 3206 7600Email: privacy@pacegallery.com Read More B. How do we collect your personal information?Collecting information from you directly:We collect your personal information directly from you by email, telephone, face to face when you visit one of our galleries or events, in paper form and via our website, including when you:visit our website;attend any of our galleries or events;express an interest in our business or interact with us as a client or prospective client;wish to make an acquisition or sale of an artwork;are represented by us as an artist;ask to receive our marketing or newsletters; orgive us feedback or contact us.Collecting your personal information from other sources:We may be required to collect personal information about you to comply with our obligations to “know our clients” or to check credit ratings or otherwise.We may also obtain information about you where it is in the public domain, such as director information available on company registers or information that you post on social media accounts such as Twitter, Facebook and Instagram.Collecting certain personal information automatically:When you interact with our website, we may automatically collect data about your browsing activities. We use cookies to collect and log analytical information such as your internet protocol (IP) address. We use pixels (also known as web beacons) in combination with cookies to track activity by a particular browser on a particular device.When you visit our galleries and sale and exhibition venues, we may automatically record your image through our CCTV operations which we have in place for security purposes. Read More C. What personal information do we collect and why?We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so.Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your personal information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below. We have included more information about the lawful basis beneath the following table.FOR CLIENTS AND PROSPECTIVE CLIENTSIdentity Data: First name, surname, titleTo provide our services to you, including responding to enquiries, offering artworks for sale, processing purchases, making shipping arrangements and keeping track of contractual arrangementsOur lawful basis is: Performance of a contract with youProof of Identity Data: Copy of photo ID and a recent utility billTo comply with our legal obligation to “know our client” and be able to prove your identity prior to completing any transaction=Our lawful basis is: Compliance with a legal obligationContact Data: Your home or business address, billing address, email address and telephone numbersTo provide our services to you, including responding to enquiries, offering artworks for sale, processing purchases, making shipping arrangements and keeping track of contractual arrangementsOur lawful basis is: Performance of a contract with youProfile Data: Collecting interests, purchasing and consignment history, event attendanceTo understand which artworks might be of interest to you and to tailor our services to you accordinglyOur lawful basis is: Legitimate interests (to develop our business and to inform our marketing strategy); Your consent to processingFinancial Data: Bank account details, credit history, payment card details, taxpayer identification number (such as a W-9 form)To process payments for artwork that you acquire or sellOur lawful basis is: Performance of a contract with youMarketing Data: Your preferences in receiving marketing from us and our third parties or event invitations and your communication preferencesTo send you marketing or event invitations where you have consented to receive these by email or otherwise where we have legitimate interests to contact youOur lawful basis is: Your consent; Legitimate interests (to develop our business and promote our products/services)Correspondence and Transaction Data: Records of our interactions with you, including details about payments to and from you and other details of products and services you have purchased from usTo provide our services to youOur lawful basis is: Performance of a contract with you; Legitimate interests (to keep our records updated and to record how our customers use our products/services)FOR ARTISTSIdentity Data: First name, surname and titleTo provide our services to you, including responding to enquiries, offering artworks for sale, processing purchases, making shipping arrangements and keeping track of contractual arrangementsOur lawful basis is: Performance of a contract with youProof of Identity Data: Copy of photo ID and a recent utility billTo comply with our legal obligation to “know our client” and be able to prove your identity prior to completing any transactionOur lawful basis is: Compliance with a legal obligationContact Data: Your home or business address, billing address, email address and telephone numbersTo provide our services to you, including responding to enquiries, offering artworks for sale, processing purchases, making shipping arrangements and keeping track of contractual arrangementsOur lawful basis is: Performance of a contract with youProfile Data: Resume, exhibition history, Pace sales recordTo understand demand for your artworks and tailor our services to you accordinglyOur lawful basis is: Performance of a contract with you; Legitimate interests (to develop our business and to inform our marketing strategy)Financial Data: Bank account, payment card details and taxpayer identification number (such as a W-9 form)To process payments for artwork that we sell on your behalfOur lawful basis is: Performance of a contract with youCorrespondence Data: Records of our interactions with youTo provide our services to youOur lawful basis is: Performance of a contract with you; Legitimate interests (to keep our records updated and to record how our customers use our products/services)FOR VISITORS TO OUR WEBSITE AND GALLERIESIdentity Data: First name, surname and titleIf you choose to provide it to us because you wish to make an enquiry or learn more about our businessOur lawful basis is: Legitimate interests (to offer and promote our products/services to you); Your consentContact Data: Your home address, billing address, email address and telephone numbersIf you choose to provide it to us because you wish to make an enquiry or learn more about our businessOur lawful basis is: Legitimate interests (to offer and promote our products/services to you); Your consentGallery Data: CCTV footage at our galleriesFor security purposesOur lawful basis is: Legitimate interests (for operation and protection of our business and maintaining our security on premises); Public interest taskTechnical Data: The IP address of the computer you use; the internet browser from which you visit our website; the pages you visit on our website and how long you viewed them forWhere we have your consent or it is otherwise in our legitimate interests to collect this information, we do so in order to improve our website provisionOur lawful basis is: Your consent; Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)FOR SUPPLIERSIdentity Data: First name, surname and titleTo engage with you to procure goods/services from youOur lawful basis is: Legitimate interests (to consider your offer of goods/services to us); Performance of a contract with youProof of Identity Data: Copy of photo ID and a recent utility billTo comply with our legal obligation to “know our client” and be able to prove your identity prior to completing any transactionOur lawful basis is: Compliance with a legal obligationContact Data: Your supplier address, billing address, email address and telephone numbersTo engage with you to procure goods/services from youOur lawful basis is: Legitimate interests (to consider your offer of goods/services to us); Performance of a contract with youFinancial Data: Bank account details, payment card details and taxpayer identification number (such as a W-9 form)To process payments for goods/services provided by youOur lawful basis is: Performance of a contract with youCorrespondence and Transaction Data: Records of our interactions with you, including details about payments to and from you and other details of products and services you have provided to usTo receive our services from youOur lawful basis is: Performance of a contract with you; Legitimate interests (to keep our records updated and to record how our customers use our products/services)The terms in the tables above that explain our “lawful basis” have the following meanings:Performance of a contract with you: We may process your personal information because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.Legitimate interests: We may process your personal information because it is necessary for our or a third party's legitimate interests. Our "legitimate interests" include our commercial interests in operating the business of the Pace Group in accordance with applicable legal and regulatory requirements, provided that, objectively, there is no unjustified impact on your privacy rights.Compliance with a legal obligation: We may process your personal information to comply with our legal obligations, including our “know our client” obligations, anti-money laundering checks and tax reporting.Your consent: We may process your personal information where you have freely given your specific consent for us to do so for a particular purpose. You are free to withdraw your consent at any time. For example, if you consent to us sending you marketing emails, you are free to withdraw this consent at any point, by clicking the “unsubscribe” option contained in those emails.Public interest task: We may process your personal information where it is necessary for the performance of a task carried out in the public interest.We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your personal information about your visits to our website to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.We do not collect any “Special Categories” of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Read More D. How long do we keep your personal information?We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.In some circumstances you can ask us to delete your personal information: see “managing your personal information section” below for further information. Read More E. Security of your personal informationWe are committed to taking all appropriate technical and organisational measures to ensure the integrity and security of any personal information processed and maintained by the Pace Group.We seek to prevent unauthorised access or disclosure of personal information under our control and we have put in place appropriate physical, electronic and managerial procedures to protect your personal information against unauthorised access or disclosure and any loss, destruction or damage. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business reason to access your personal information. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.We endeavour to take reasonable steps to protect your personal information from external threats, however, please be aware that, no security system can prevent all potential security breaches. Read More F. Third party linksThis website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.We have partnered with a third party to offer sales of non-fungible tokens (NFTs) on behalf of certain artists. This service is subject to the Mojito, Inc. Privacy Policy (located at (opens in a new window) https://verso.pacegallery.com/privacy). Read More G. Sharing your personal informationWhere we have lawful grounds for sharing your personal information with others, we may do so as set out below. We require all parties with whom we share your personal information, to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.As an international business we operate globally through affiliates in the Pace Group worldwide. Your personal information may be transferred and processed outside of the UK and the European Economic Area ('EEA'), including to the United States of America, where our headquarters are located. Whenever we transfer your personal information outside the country it is collected, we shall ensure that it is protected to a similar degree as it would be if kept within the country it is collected by making sure that at least one of the following mechanisms is implemented:We may transfer your personal information to countries that have been deemed to provide an adequate level of protection for Personal Data.We may transfer your personal information to countries that have not been deemed to provide an adequate level of protection for personal information– provided that, in these cases:we will use specific appropriate safeguards approved by the relevant government or supervisory authority which are designed to give personal information the same protection it has in the country from which the data originates (for example, requiring the recipient of personal information to enter into the so-called ‘International Data Transfer Agreement’ or ‘Standard Contractual Clauses’); orin very limited circumstances, we will rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.You can obtain more details of the protection given to your personal information when it is transferred outside the UK and/or EEA by contacting us.We may share your personal information within the Pace Group and with external third parties as follows:Within the Pace GroupWe may share personal information with any of the companies in the Pace Group acting as joint controllers or processors in order that we can provide a global connected service to our clients and artists.For example:If you are an artist in New York, you will be represented by the Pace Group and although the New York entity may collect your personal information, all entities within the Pace Group will have access to that in order to promote your work internationally because we consider that this is in accordance with our legitimate interests and within your expectations of how we treat your personal information;If you are a client of the Pace Gallery in London, our London entity will collect your personal information and if they consider that you might be interested in attending an event in Hong Kong or buying an artwork in Hong Kong, they might pass your contact details to the Hong Kong Gallery in order that they can contact you about that because we consider that this is in accordance with our legitimate interests and within your expectations of how we treat your personal information;If you access our website, this is operated by our New York entity, The Pace Gallery LLC, and any of the contact or technical data that is collected through the website might be shared with the Pace Group. We do this because we consider that this is in accordance with our legitimate interests and within your expectations of how we treat your personal information.External third parties – in support of our businessWe may share your personal information with our chosen providers and suppliers for a number of reasons, for example:So that we can provide our service under the contract between you and us; we have third parties that provide us with services including: IT and infrastructure, payment processing, art photographers, art conservators, art framing companies, art shipping companies.Where we have a legitimate interest or your consent to invite you to our events and exhibitions, we use third party email and distribution companies to assist us with that.External third parties – for other reasonsIn addition, we may be required to disclose your information:To the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies, fraud prevention agencies, credit reference agencies, tax authorities or regulatory bodies);In connection with any legal proceedings or prospective legal proceedings;In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention); andTo third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy. Read More H. Managing your personal informationYou have the right as an individual to manage the personal information we hold about you and make amendments if this is necessary to keep your personal information accurate. You are also able to withdraw any consent you might have given us to receive marketing communications, such as newsletters or invitations from the Pace Group. You can ask us to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you, or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions. You may also object to the Pace Group using your personal information even if we rely on our legitimate interests to make use of it.You have several rights in relation to your personal information under data protection law. In relation to most of these, if you exercise them we may ask for information from you to confirm your identity and, where applicable, to help us find your personal information. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to assist us in our response.If your request relates to UK or EU data protection laws, we are required to respond to you within thirty days after we have received a valid request, by which we mean a request that is backed up with any identification documents that we have requested. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.You have the following rights:to request a copy or summary of the personal information that we hold about youto correct and update your personal informationto withdraw your consent (where we rely on it) from certain types of data processing (for example to receive email marketing messages)to object to certain kinds of processing of your personal information such as automated processing and profilingto erase your personal information or restrict its use where we can do so under the relevant lawto complain to the appropriate supervisory authority regulating data privacy matters.If you want to exercise any of the rights described above, please contact us using the contact details shown in the “Who we are and how to contact us” section above. Read More I. CookiesYou can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the Cookies policy on our website. Read More J. CaliforniaThese additional rights and disclosures apply only to California residents. Terms have the meaning ascribed to them in the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CPRA”), unless otherwise stated.Notice of CollectionAt or before the time of collection of your personal information, you have the right to receive notice of our data practices. Our data practices are as follows:For the categories of personal information we have collected in the past 12 months, see the What personal information do we collect and why? section above, which we have further set out below using California-specific terms:Contact Identifiers, including your name, email address, postal address, and phone number.Commercial or transactions information, including records of products or services you purchased, obtained, or considered.Device identifiers, including your device’s IP address.Device information, including your device’s operating software and browser (e.g., type, version, and configuration), internet service provider, and regional and language settings.Internet activity, including information about your browsing history and interactions, such as the features you use, pages you visit, content you view, purchases you make or consider, time of day you browse, and referring and exiting pages.Non-precise location data, such as location derived from an IP address or data that indicates a city or postal code level.Payment information, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.User-generated content, including content within any messages you send to us (such as feedback or questions).For the categories of sources from which personal information is collected, see the What personal information do we collect and why? section above.For the specific business and commercial purposes for collecting and using personal information, see the What personal information do we collect and why? section above.For the categories of third parties to whom information is disclosed, see the Sharing your personal information section above.For the criteria used to determine the period of time information will be retained, see the How long do we keep your personal information? section above.We do not “sell” or “share” your personal information as those terms are defined by the CPRA. We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.Some of the personal information we collect may be considered sensitive personal information. For example, your photo ID. We collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CPRA or without the purpose of inferring characteristics about consumers. We do not sell or share sensitive personal information.Rights to Know, Correct, and DeleteYou have the following rights under the CPRA:The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which personal information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.The right to correct inaccurate personal information that we maintain about you.The right to delete personal information we have collected from you.To access, correct, delete, or exercise similar rights available to you in your region with respect to your information, please submit a request by emailing inquire@pacegallery.com or calling +1 212 421 3292. Please note these rights are subject to exceptions. We will confirm receipt of your request within 10 business days and respond to your request within 45 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.Authorized AgentYou can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. Except for opt-out requests, we will require written proof of the agent’s permission to do so and may verify your identity directly.Right to Non-DiscriminationYou have the right not to receive discriminatory treatment by us for the exercise of any your rights.Shine the LightUnder California’s Shine the Light law, customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make a request, please write us at the email or postal address set out in the Who we are and how to contact us section above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. Read More K. Issues and complaintsIf you have an issue regarding how we handle personal information, please do not hesitate to contact us. We will do everything we can to try to resolve your issue.If, however, you wish to make a complaint about the handling of your personal data you can complain to the data protection supervisory authority in the relevant country:If you wish to complain about the processing of your personal data under UK data protection laws, you can contact the UK Information Commissioner’s Office: (opens in a new window) https://ico.org.uk/.If you wish to complain about the processing of your personal data under EU or German data protection laws, you can contact the Berlin Commissioner for Data Protection and Freedom of Information: (opens in a new window) https://www.datenschutz-berlin.de/ Read More