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Privacy Policy

PRIVACY POLICY

This Web Site ("Web Site") is published and maintained by Zola Group and its subsidiaries and affiliates (collectively referred to in this PrivacyPolicy as "Zola Group," "we," "us,""our," or other similar pronouns, or "The Zola Group Group").

This Privacy Policy governs your use of the Zola Group Web Sites on which it is posted.  By visiting this Web Site, and/or using the services offered on or through this Web Site (the "Services"), you agree to the terms of this Privacy Policy as they may be amended from time to time. As we update and expand our services, this Privacy Policy may change, so check back to this page from time to time. This Privacy Policy is incorporated into, and part of, the Zola Group Web Site Terms and Conditions of Use, which governs your use of this Web Site in general.

You may opt in or opt out of our sharing of your Personal Information with third parties for their marketing purposes by following the directions in the “Marketing Preferences” section below.

Purpose

Your privacy is a serious matter to us. In order to make your visits to our Web Site and use of the services available through our Web Site as worthwhile as possible, we may ask you for Personal Information and we may collect certaininformation about you and your interaction with the Web Site from you and yourcomputer each time you visit us. "Personal Information" includes, for example, your name; title; home and/or business address; e-mail address;home and/or business telephone, wireless and/or fax number; credit card andother payment information; demographic information; your location; art interests or preferences, art purchases, auction activity and bidding history, paddle numbers, bidding amounts, payment history; and/or other information thatmay identify you as an individual or allow online or offline contact with you as an individual. “Personal Information” includes “Personal Data” as that termis defined in Article 2 of the European Union Data Protection Directive. This Privacy Policy explains, in general, what Personal Information and otherinformation is collected on our Web Site, how the information is used, and with whom we may share such information. Please take a few minutes to read our Privacy Policy so that you understand how Zola Group treats your information.

Marketing Preferences

You have the right to "opt in" and "opt out" of certain ofour uses of your Personal Information and may change your preferences regarding such uses at any time. For example, at the time you are requested to provide Personal Information on this Web Site, you may have the opportunity to elect whetheror not to: (1) receive commercial correspondence from us (either on our behalfor on behalf of a third party), or (2) have your Personal Information shared with other entities (outside of The Zola Group Group) for their marketingpurposes. You may also make this request by visiting our marketing preferences Web page.You may also opt-out of Zola Group promotional e-mails by clicking on the opt-out link within the e-mail you receive, or of Zola Group postal mailings byfollowing the directions in such mailings.  Please be aware that it may take up to 10 business day(s)for Zola Group to update your preferences. During that time, you may continue to receive messages from us.

Please understand that if you opt-out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us (including,for example and without limitation, alerts, tracked lots, wishlists and condition reports, in connection with your use of Zola Group (as definedabove)). You may control how you receive such non-promotional correspondence from us by updating your account preferences. Also, a request to have us stopsharing your Personal Information with other entities for marketing purposes will only apply as of the date on which we receive your request, and we will not be responsible for any communications that you may receive from entities that received your Personal Information prior to such request. In these cases, please contact that entity directly.

WHAT INFORMATION IS COLLECTED ON THIS WEB SITE?

User-Provided Information

We collect Personal Information from users of our Web Site, for example,through such users' activities, transactions and completion of online forms on our Web Site. Such information is collected, for example, when users register or subscribe for accounts or features on our Web Site (for example, when you register to look at certain items of property up for auction or auction results, or when you use Zola Group (as defined above)), make online purchases(such as catalogue purchases), complete surveys, submit a comment or question to us using a "contact us" or similar feature on our Web Site, send us an e-mail, or in any other way submit Personal Information to us via our Web Site.

You may be able to send information about our products and services to your friends and family members through our Web Site by clicking ona "Share" or similar button on our Web Site or in an e-mail that we have sent you. In some of these cases (unless you simply forward our e-mail onyour own), you may provide the e-mail address of your friend or family member to us.

Web Site Usage Information

Cookies

If you have permitted your computer to accept “cookies,” we may use “cookies” to keep, and sometimes track, information about you. Cookies are small data files that are sent to your browser or related software from a Web server and stored on your computer's hard drive. Cookies track where you travel on our Web Site and what you look at, transact and purchase. They may store the information in your shopping cart, and/or your username and/or password, and wemay use them to deliver specific messages to you (for example, to announce anew feature that was added since the last time you visited the Web Site). A cookie may enable us to relate your use of our Web Site to other information about you, including your Personal Information. All of these purposes serve to improve and personalize your experience on our Web Site.

Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, if you have a Flash player installed on your computer, your Flash player can be set to reject or delete Flash cookies. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Web Site or certain areas or features of the Web Site.

Clear GIFs

We may use "clear GIFs" (aka "Web beacons" or "pixeltags") or similar technologies, in the Web Site and/or in our communications with you, to enable us to evaluate Web Site Usage Information about visitors to the Web Site, target campaigns, upgrade visitor information,and know whether you have visited a Web page or received a message. A clear GIFis typically a one-pixel transparent image (although it can be a visible imageas well), located on a Web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet thus enabling the verification of an individual's viewing or receipt of a Web page or message. A clear gif may enable us to relate your viewing or receipt of a Web page or message to other information about you, including your Personal Information.

IP Address and Clickstream Data

Our server automatically collects data about your server's Internet address when you visit us. This information, known as an Internet Protocol address, orIP Address, is a number that's automatically assigned to your computer by your Internet service provider whenever you're on the Internet. When you request pages from our Web Site, our servers may log your IP Address and sometimes yourdomain name. Your IP Address is used to help identify you and to gather demographic information about our customers as a whole. Our server may also record the referring page that linked you to us (e.g., another Web site or a search engine); the pages you visit on this Web Site; the Web site you visit after this Web Site; the ads you see and/or click on; other information about the type of Web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Web Site or a referral site;and other Web usage activity and data logged by our Web servers. We use this information for internal system administration, to help diagnose problems withour server, to administer our Web Site, and to customize your user experience. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider. We may link this information with your Personal Information.

Any or all of these activities with regard to Web Site Usage Information may be performed on our behalf by our services providers, including, for example, our analytics vendor(s) and our e-mail management partner(s).

How is your Personal Information used?

We will use the Personal Information you provide to our Web Site, for example,to respond to your requests and to provide you with our product and service offerings. For example, we will process and fulfill your orders (e.g., for catalogues), respond to your requests and inquiries and provide you with the services and features offered on or through our Web Site. We may also use your Personal Information to maintain our internal record keeping. We may also report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report. We may match information collected from you through different means or at different times, including both Personal Information and Web Site Usage Information, and use such information along with information obtained from other sources, including third parties. We also may compare your contact information to data in our worldwide databases in order to improve our Web Site and marketing. Also, advertisements and other content displayed to you on the Web Site may be customized to your interests and preferences, based on your Personal Information and Web Site Usage Information, including, for example, non-Personal Information, which we may obtain from you or from other sources.

In addition, we may use your Personal Information to send you notices about, or invitations to upcoming events in the collecting area inwhich you've made a purchase (for example, in the form of e-mails, mailings,and the like), and to otherwise correspond with you, about products, services, companies and events, sponsored by us and others, that we think might interest you. In order to alert you to the widest possible number of items and events of interest to you from our sales and events worldwide, we may share thisinformation among our affiliates in The Zola Group Group. For example, if you've expressed interest in Jewellery, Zola Group may share your name with Zola Group Institute in London so that they can alert you to upcoming lectures and events in connection with Jewellery. You may change your preferences regarding communications from us by following the instructions in the Marketing Preferences section above.

We also may provide visitors to our Web Site an opportunity to receive offers from other entities (outside of The Zola Group Group) who have services, products and offers that we think might be of interest to you. For example, if you have elected to receive notices about our jewellery sales, we might include a link to Zola Group International Realty or Zola Group Diamonds in the e-mails we send to you. (Please note that Zola GroupInternational Realty is not a member of The Zola Group Group and that Zola GroupDiamonds is a partnership between Zola Group and Steinmetz. Information collected on these and any other sites is subject to those sites' privacy policies.) However, we will not transfer your contact information to any unaffiliated third party for the third party's marketing purposes unless you expressly direct us to do so. If you change your mind and no longer want to receive third party promotions, follow the instructions to opt out in the Marketing Preferences section above.

We may analyze user behavior as a measure of interest in, anduse of, our Web Site and e-mails, both on an individual basis and in the aggregate.

Do we share Personal Information and Web Site Usage Information with others?

Zola Group does not sell, lease or give your Personal Information to any other company, unless otherwise stated herein.

Call Center

Certain Personal Information is only available to certain Zola Group employees and to Zola Group third party call center and other service providers, as set forth below. The third party call center is required to keep all sensitive information about you and your use of our Web Site confidential. The call center is required to use your information solely in order to help you with registration or sign-in problems and other services.

Service Providers

We may use third party partners to help operate our Web Site and deliver our products and Services, and may, when necessary to do so, share your informationwith our affiliates, service providers and other third parties that provide products or Services for or through this Web Site or for our business purposes (such as Web site or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies, and other similar service providers that use suchinformation on our behalf). These third party partners are obligated to protect the security and confidentiality of your information.

Artnet (Past Sales Results)

For certain sales, we have incorporated a link on our catalogue pages to a third party web site, artnet.com. Users of this service may be required toprovide us with certain Personal Information such as an e-mail address. Then we may use a cookie to remember you as a registered user and to track what youbrowse. We use this information to refine our Web Site, notify you of properties and invite you to events that may be of interest to you. You may request that we do not send any such notices or invitations to you by following the instructions in the Marketing Preferences section above.

Subject to your consent, we have agreed to share names and e-mail addresses provided to us for use of the Artnet feature with Artnet. Artnet is obligated to protect your confidential information and to only usethis information to invite you, no more than twice, to use Artnet's otherservices. Click here to see Artnet's privacy policy. You mayrequest that we do not share your name and e-mail address with Artnet byfollowing the instructions in the Marketing Preferences section above.

Aggregate Statistics

We may disclose aggregate statistics regarding user behavior as a measure ofinterest in, and use of, our Web Site and e-mails to third parties in the formof aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user.

Legally Compelled Disclosures

We may disclose user information to government authorities or other third parties when we believe such disclosure is required by law.  We may also disclose user informationas necessary to enforce the Zola Group Web Site Terms and Conditions, inconnection with investigations, or when we believe disclosure is necessarily incident to the provision of Zola Group services or to the protection of therights, property or safety of Zola Group or others.

Business Transfer

Zola Group regards its databases of customer information (which will include your Personal Information) as a valuable asset. In the event that Zola Group,any entity of The Zola Group Group, or substantially all of its or their assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, such databases containing Personal Information may be one of the transferred assets. In addition, such a transfer may mean that your Personal Information istransferred to countries outside the European Economic Area ("EEA"). In using the Services you consent to such transfer of your Personal Information.

Wireless Addresses

If the email address you provide to us is a wireless email address, and you have elected to receive promotional messages from Zola Group, you agree to receive messages at such address from us, unless and until you have elected not to receive such messages by following the instructions in the Marketing Preferences section above. You understand that your wireless carrier's standard rates apply to these messages, and that you may change your mind at any time by following the instructions in the Marketing Preferences section above. You represent that you are the owner or authorised user of the wireless device on which messages will be received, and that youare authorised to approve the applicable charges.

Your Access Rights

You may review and edit the Personal Information that is stored in your useraccount on our Web Site (e.g., your passwords and other contact information) by visiting the “Profile” area of your account on our Web Site or by contacting Zola Group via the email address at the end of this policy.  We will endeavor to respond to your request as soon as practicable. Before we are able to provide you with anyinformation, correct any inaccuracies or delete any information, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. In addition, you have the right to request access tothe Personal Information that we hold about you at any time.

Security

Zola Group will take reasonable steps to protect the security and integrity ofall Personal Information provided to this Web Site, including making your Personal Information available to our employees and agents on a need-to-know basis. However, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our system or otherwise inour care, will be absolutely safe from intrusion by others, such as hackers.

If you contact us by e-mail or a "contact us" or similar feature on our Web Site, you should be aware that your transmission might not be secure. A third party could view information you send by these methods in transit.

You may be able to create an account on our Web Site with a username and password. Passwords are encrypted and Zola Group policies do not permit any employee or service provider access to your password. If you do create a username and password, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any access to or use of the Web Site by you or any person or entity using yourpassword, whether or not such access or use has been authorised by or on behalfof you, and whether or not such person or entity is your employee or agent. You agree to (a) immediately notify Zola Group of any unauthorised use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session, especially where you are accessing the Web Site on a public computer. It is your sole responsibility to control the dissemination and use of your password, control access to and useof your account, and notify Zola Group when you desire to cancel your account onthis Web Site. We will not be responsible or liable for any loss or damagearising from your failure to comply with this provision.

We will have no liability for disclosure of your information dueto errors or unauthorised acts of third parties.

In the unlikely event that we believe that the security of yourPersonal Information in our possession or control may have been compromised, wemay seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification.

Phishing

With identity theft a continuing problem, it has become increasingly common for unauthorised individuals to send e-mail messages to consumers, purporting to represent a legitimate company such as a bank or on-line merchant, requestingthat the consumer provide personal, often sensitive information. Sometimes, thedomain name of the e-mail address from which the e-mail appears to have beensent, and the domain name of the web site requesting such information, appears to be the domain name of a legitimate, trusted company. In reality, such sensitive information is received by an unauthorised individual to be used forpurposes of identity theft. This illegal activity has come to be known as"phishing."

Zola Group will never request your password or social security number via e-mail. If you receive an e-mail or other correspondence requesting that you provide any sensitive information (including your Web Site password or credit card information) via e-mail or to a web site that does not seem to beaffiliated with our Web Site, or that otherwise seems suspicious to you, please do not provide such information, and report such request to us.

Consent to Worldwide Transfer and Processing of Personal Data

Zola Group is a global enterprise, with affiliates worldwide. When you give your Personal Information to Zola Group, it may be processed by Zola Group in all countries in which Zola Group has affiliates. Each of these countries has different privacy laws that afford varying levels of protection for your PersonalInformation. Regardless of the laws in place in these countries, Zola Group willtreat the privacy of your information in accordance with this Privacy Policy. By providing your Personal Information to Zola Group, you consent to Zola Group transmission to, and processing of your information in, any jurisdiction, inaccordance with this Privacy Policy.

Third Party "Linked-To" Web Sites

When you are on our Web Site you may have the opportunity to visit, or link to, other sites not operated by Zola Group, including other Web sites operated by other members of The Zola Group Group or by unaffiliated third parties. Examples of such third party sites are artnet.com, Zola Group International Realty, Zola Group Institute of Art, and Zola Group Diamonds. These sites may collect Personal Information about you. Zola Group does not control sites that areoperated by these entities and is not responsible for the information practices of these sites. This Privacy Policy does not address the information practicesof those other Web sites. The Privacy Policies of Web sites operated by other members of The Zola Group Group and other affiliated entities are located onthose sites.

Changes to this Privacy Policy

Zola Group reserves the right to change or update this Privacy Policy, or any other of our policies or practices, at any time, and will notify users of this Web Site by posting such changed or updated Privacy Policy on this page. Any changes or updates will be effective immediately upon posting to this Web Site. Under certain circumstances, we may also elect to notify you of changes or updates to our Privacy Policy by additional means, such as posting a notice on the front page of our Web Site to sending you an e-mail.

If you have any questions or comments regarding our privacy practices or wish to verify or change the information in our files, you may contact us.