Data Protection & Privacy Notice
In general, Art Again will collect and use your Personal Data in order for us to run our business in a meaningful way. This includes making our online marketplace available to you, keeping it up to date and ensuring that our online marketplace can function, that artworks are listed for sale, and that users are able to inquire and eventually buy these artworks. We use some of your Personal Data for analytics, for example to understand trends in the respective categories, as well as for marketing purposes. Furthermore, we use Personal Data to meet our legal obligations, for example for reporting to the tax and other supervisory authorities.
Processing your Personal Data
The Personal Data we collect on our online marketplace and from our users reveal how people find and use Art Again, what they may be interested in and where our visitors are coming from. This helps us to further improve our product and services. We also collect statistics on the number of visitors on a daily and monthly basis, which explains to us how our business grows.
Until you list an artwork with us as a seller or inquire about an artwork, we only collect technical information. This includes your IP address, information about the device you use, access times, etc. Once you have provided us with your permission, also known as “consent”, we also collect electronic identification data from your browser or device by making use of cookies (small text files your computer sends each time you visit our online marketplace) and similar technologies on our online marketplace. This data will include a cookie ID, your browsing behaviour on our online marketplace, and which artwork(s) you like. These data elements also allow us to test new functionalities.
It is in Art Again’s legitimate interest to collect the main technical data when you visit and use our online marketplace, for the reasons explained above. However, when it comes to cookies and similar data that is used for analytical and advertising purposes, we rely on your consent.
Visiting our online marketplace
Based on your contract with us
When you buy or sell an artwork with us, you need to agree to our Terms of Use. Because of this, a legally binding agreement is in place between you and us, giving us the legal basis to process the Personal Data for the following reasons:
Sometimes it is helpful if we can contact you. To do so, we use your email address and sometimes, phone number. Both are also used to facilitate the shipping of items you have bought or sold via our online marketplace.
We are happy to see our users become sellers on Art Again. If you want to sell an artwork, you will need to provide additional information to verify your identity, including at least your full name, your address and contact information.
Your contact details and buyer/seller information may be used to provide customer support, in case of questions or difficulties with a buy or a sale via our online marketplace.
How we further process your Personal Data
Our Legitimate Interest
There are situations where Art Again needs to process the Personal Data we have about you for other reasons than those directly related to the contract you have with us. We consider we have a good reason to do so, legally called a legitimate interest, in any case in all the situations listed below. There could also be others. If you disagree, feel free to contact us, so we can see if we need to revisit our approach for your specific situation. For email communications, you can write to us at admin@artagain.co to opt-out. Please use the subject heading: “Request to opt-out of email communications”.
We want to help you use our online marketplace, so we may send you email messages. We may also send you a text message on your mobile phone number, to verify the number is real.
We want to make sure you can find the perfect artwork, so we will send you email messages as part of our marketing communications, for example a newsletter or surveys, as long as you are an active user of the Art Again platform.
We want to make sure you do not miss out on new artwork listings, special curations and events hosted by Art Again, so we send you email messages, for example to alert you about any price drops.
Our sales team wants to make sure you have the best experience when you start selling. They may send you email messages or call you, for example to provide assistance with onboarding, to invite you to participate in specific themed curations or partnerships, or to support you as you sell art on Art Again.
Our data team helps us to understand how you use our online marketplace, including purchases and artworks sold by our users, as well as what pages and categories you visit. This allows us to make improvements to our online marketplace and give you the best possible user experience. We also use data for market analysis and to improve our sales process.
We want to make sure you get the best possible customer service. To do so, we need to train our teams. Our customer experience team may therefore listen to recent interactions with users, or colleagues may listen in live to calls to provide immediate feedback.
To make sure Art Again is a secure, trusted platform for both buyers and sellers, by spotting and combating fraud, money laundering, and other non-compliant use of our online marketplace. For example, we use Personal Data to look into users who don’t comply with our Terms of Use to block these users from using our online marketplace. We also process your Personal Data for system integrity purposes (for example, to prevent hacking or credential stuffing attacks), to register, mediate, and resolve possible disputes or irregularities or to enforce our Terms of Use and other policies. If a contract has been entered into between you and another user (the “Contract of Sale”) and there is an issue or dispute, we might provide certain information to help you resolve the issue directly with that user.
We want to make sure our website is reliable for you to use. Therefore, we review, scan, or analyse all activity on our website as well as your messages with other users, for fraud prevention, risk assessment, investigation, or support purposes.
Finally, all Personal Data can be used to implement and operate company policies and procedures, to respond to any claims against us and to protect the rights, property, or personal safety of Art Again, our users, or the public. We can also use these data to make corporate transactions, such as any merger, sale, reorganisation, acquisition, bankruptcy or similar event and for other legitimate business purposes permitted by applicable law.
From time to time, we may initiate new data processing activities that rely upon legitimate interest. These will be included in this Data Protection & Privacy Notice when it is next updated.
Under a Legal Obligation
We are under a legal obligation to process certain types of Personal Data. This includes the processing of Personal Data for the following reasons:
To ensure all users are who they say they are, your contact details and, where appropriate, a copy of your government issued ID and other additional information, are used for identity verification in light of applicable laws, including for anti-money laundering. We may use a third-party service provider to support us in this process.
To ensure all transactions are recorded to the tax authorities and can be audited in a proper manner, we retain records of transaction and payment data.
Consent
Finally, we may process your Personal Data with your consent. We try not to bother you too much with consent requests, unless we are under a legal obligation to do so or if there is no other option. We use your information with your consent for the following reason:
We like to ensure that if we show you advertisements outside of our online marketplace, they are relevant to you. To do so, we may use the data from cookies and other trackers on your device. The same data can be used to make sure email communications and in-app or on device notifications you receive from us are relevant to you.
We may always collect some basic statistics, but we like to have more detail to really understand how you use our online marketplace. For these detailed statistics, we need your permission.
To get your feedback on your experience when buying or selling on Art Again. In these cases, we will only process Personal Data (such as your email address or user ID) for our internal analytics, which help to enhance our services. We may also process the opinions, experiences, preferences and interests and reviews that you provide to us, with other users or share with us online or through social media.
To use photos of your artwork captured in your private space or home for marketing campaigns.
Please note that you may withdraw your consent at all times. The section on Your Rights below provides more detail.
Sharing of Personal Data with users
Sometimes, it is necessary that Art Again shares your Personal Data with another user of our online marketplace. There is a number of possible scenarios, each of them related to the preparation and execution of the Contract of Sale which include:
If you buy an artwork from another user, the item may need to be shipped to you upon reception of payment. We will share your address and contact information (including phone number and email address) with the seller so they can arrange shipping.
If there is an issue between you and another user, we may share the address and contact information between the users to help you resolve the issue directly with that user.
If a Contract of Sale is cancelled by either the buyer or the seller, there can be limited situations where Art Again will still have to share your contact details with the seller in order for them to initiate legal proceedings.
If you receive another user’s Personal Data, you guarantee that you will only process these to perform your obligations, or to remedy any issues under, or arising from, the Contract of Sale. You shall always process Personal Data in accordance with applicable (data protection) laws and regulations. Without consent from the user in question, you may not use any Personal Data for (other) commercial purposes, for instance to send marketing messages, other unsolicited communications or otherwise approach the user for such purposes.
In addition to the contractual reasons above, we may share your Personal Data if you have given us consent to do so. This can for instance include the following situation:
If a user wants to inspect an artwork on site before making a bid and entering into a Contract of Sale, we can share the contact details of the seller with the buyer in order to arrange the viewing.
Should there be a need for a refund, we may ask you for your consent to share your banking information with another user, so this can be arranged directly between the users.
Sharing Information with Third Parties
Companies processing Personal Data on behalf of Art Again
Art Again uses multiple Third Party Service Providers to help us process your Personal Data. These include companies that host our website, run our databases, run our advertisements, or are involved in other ways in the processing of Personal Data. Just to be clear: your Personal Data will at all times be processed by our Third Party Service Providers under our instructions. Contracts are in place to ensure your expectations and our obligations regarding data protection and data security are met. Where relevant, we conduct a risk assessment before a contract is concluded.
The following categories of Third Party Service Providers may process your Personal Data as part of our operations:
Customer relationship management software providers
Email and messaging services
Web hosting services
Office software providers
Payment service providers (including identity verification)
Online advertisers and advertising networks
Data analytics service providers
Social media networks
Organisations processing your Personal Data for their own reasons
Sometimes, Art Again will need to share your Personal Data with organisations that will process the data for their own reasons. This is often the case when there is a legal obligation to process your data. If indeed your Personal Data is processed by an organisation for one of the reasons mentioned below, you need to be aware they (also) do so under their own responsibility.
Payment service providers (including identity verification)
Government authorities (including tax and law enforcement authorities)
Auditors
Debt Collectors
In addition, your Personal Data may be disclosed to one or more other organisations as part of any merger, (partial) sale or (partial) transfer of our assets. Should that ever happen, we will try to inform you in a timely manner.
Use of Social Media
Art Again is or will be active on social media platforms, including Facebook, Instagram, TikTok and LinkedIn, where you would be able to interact with us. Please note that in all situations, the terms of use and privacy policy of the respective social mediums would apply.
If you interact with Art Again on social media, we will in any case process your username and any additional information you share with us.
The Art Again sales teams also use social media and public websites to identify prospective sellers for our platform. You have the option to tell us you do not want us to contact you again.
Personal Data you entrust to Art Again will primarily be processed in Singapore. However, our Third Party Service Providers are not all located in Singapore, which means your Personal Data is likely to end up in other countries. We respect the rules set out by Singapore data protection rules and applicable guidance from supervisory authorities, also when your Personal Data is processed in other countries.
The main country outside Singapore where your Personal Data will be processed, is the United States. This is because many of our Third Party Service Providers have their headquarters there, and also make use (in part) of American hosting servers. Without going into all the technical details, we can tell you that we strive to encrypt all our Personal Data, both in transit and at rest, and try to agree with our Third Party Service Providers that they will not share your Personal Data with anyone else, without telling us to do so. There can be exceptions, for example when there is a warrant or subpoena in place that requires handing over your data.
Cross-border data transfers
The security, integrity, and confidentiality of your Personal Data are extremely important to us. We have implemented technical, contractual, organisational, and physical security measures that are designed to protect our user's Personal Data from unauthorised access, disclosure, use, and modification. We regularly review our security procedures and practices to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.
When we no longer need your Personal Data, we also do not want to keep it. In general, that means that Art Again will process your Personal Data for as long as you are an active user, or as long as required under our legal obligations in the respective countries we operate. Where we process Personal Data that is not directly related to you or our legal obligations, we will set specific retention periods based on the purpose for which we have collected that Personal Data in the first place.
Data Security & Retention
From time to time, this Data Protection & Privacy Notice will be updated, in order to ensure it reflects the current status of how and why we process your Personal Data. At the top of this page, you will see when the notice was last reviewed and updated. If we make any important changes to the way Art Again processes your Personal Data and how you use our online marketplace, we may also directly inform you via email, if we have your email address.
Changes to Data Protection & Privacy Notice
Contact
If you have any questions about this Data Protection & Privacy Notice, please reach out to us via email at admin@artagain.co. You can also reach out to us via our social media channels.