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GABELLINI  SHEPPARD
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Gabellini Sheppard

PriVACY POLICY

Welcome to www.gabellinisheppard.com (the “Site”). This policy (“Privacy Policy”) describes how the Site collects and uses the information of its users. Please read this Privacy Policy carefully, as it applies each time a user accesses the Site and uses its services. By using and accessing the Site, you accept the terms of this Privacy Policy and the General Terms and Conditions of Use.

The Site is operated by Gabellini Sheppard Associates, LLP, 665 Broadway, Suite 706 New York, NY 10012 (“Gabellini” or “we”). Gabellini is the data controller. The words “user”, “you” and “your” in this Privacy Policy refer to a user of the Site.‍

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TYPES OF INFORMATION WE COLLECT FROM USERS AND HOW WE COLLECT IT:

When you use the Site, we may collect your (i) personal information (data that personally identifies you), or (ii) aggregate information, concerning your use of the Site and your account activity (e.g., number and times of log-ins, most frequently visited pages, IP address, etc.), which does not personally identify you.

The types of information we collect include:

  • Information you provide to us. Information provided by registering on the Site, making a purchase on the Site, subscribing to our newsletter, contacting us through the Site or via email, including your name, address, shipping address, credit/debit card information, email address, and phone number.
  • Automatically collected information. When you access our Site, some information not associated with specific users, such as device type, location information, IP address, webpage traffic, and access time is automatically collected in order to ensure the Site’s functionality. Automatic means of data collection include cookies and web beacons.
  • Third party sources. We may collect information from third parties to whom you have provided your information, and consented to the sale, rental or transfer thereof (for example, through social media).

Please be aware that if you do not allow us to collect certain personal information from you, we may not be able to deliver certain products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to provide your information.

Generally, we process personal information provided by visitors through our Site on the basis of consent or to perform a contract with you. We may also process personal information on other bases permitted by applicable law, such as when the processing is necessary for us to comply with our legal obligations or our legitimate interests in the effective delivery of information and services to you and in the effective and lawful operation of our businesses (provided these do not interfere with your rights).

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HOW WE USE YOUR INFORMATION:

Your information is processed using primarily electronic means and is used, without limitation, for the following services:

  • Marketing communications;
  • Customization of content;
  • Responding to customer service requests and similar communications from you; and
  • Technical assistance.

We may use automated decision making in processing your personal information for some services and products. You can request a manual review of the accuracy of an automated decision if you are unhappy with it.

In addition, we currently use Google Analytics to track traffic to, from and around our website, and we use the data gathered through this service (such as what time the current visit occurred, whether the visitor has been to the website before, and what website referred the visitor to the web page) for various purposes, including to improve the Site and our users' experience with it. To find out more about how information about your visits to the Site may be collected and analyzed through the Google Analytics tools, visit http://www.google.com/intl/en/analytics/privacyoverview.html.

Depending on the type of web browser you have, you may be able to opt-out of having certain of your web usage information sent to Google Analytics by visiting http://tools.google.com/dlpage/gaoptout?hl=en.

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HOW WE PROTECT YOUR INFORMATION:

The Site uses Secure Socket Layer (SSL) software and similar encrypting systems to protect your information when you purchase products on the Site. Only employees, contractors and agents of the Site operator may access user information on a need to know basis and only for the purposes set forth in this Privacy Policy.

While we make reasonable efforts to ensure your information is processed and stored in a secure manner, we cannot guarantee the security of data transferred over the Internet and you assume the risk of any such transfer.

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WHERE WE STORE YOUR INFORMATION:

Your information will be collected and stored in the United States. If you visit us from the European Union, you shall be advised that, according to the Court of Justice of the European Union and to European Data Protection Authorities, the United States do not offer a level of protection to personal data which is equivalent to the one granted by EU law. Personal data flowing to the US may be accessed and processed by local law enforcement authorities in accordance with US laws. Please keep this in mind when you interact with the Site.

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FOR HOW LONG WE KEEP YOUR INFORMATION:

We will process your data for the time strictly necessary to achieve the purpose in question. Thereafter, we will keep your information duly stored and protected for the time during which liability may arise for its processing as long as required by applicable law, in compliance with legislation in force from time to time.

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SHARING YOUR INFORMATION:

We will not sell or otherwise disclose your information, except as described in this section and other relevant sections of this Privacy Policy.

  • We may share your information with companies affiliated with Gabellini, including licensees and joint venture partners, who may be located outside the United States. These parties may only use your information in compliance with this Privacy Policy.
  • We may retain third party service providers in order to process your data in connection with the services provided on the Site (e.g., order fulfillment, IT support, customer service or marketing communications). Third parties who perform these operations are only permitted to use the information provided to them to perform their function and for no other purpose. Please contact us at pr@gabellinisheppard.com to receive a full list of third party providers who may receive your information.
  • In the event there is a change in the corporate structure of Gabellini including, without limitation, by merger, consolidation, sale, liquidation, or transfer of substantial assets, we may, in our sole discretion, transfer, sell or assign users’ information collected on and through the Site to one or more affiliated or unaffiliated third parties or successor in interest.
  • We may disclose a user’s information when required to do so to comply with applicable law or legal process or to respond to a request from law enforcement authorities. We may also provide your information where necessary for the defense of legal claims or for fraud prevention purposes.

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LINKS TO THIRD PARTY SITES:

The Site contains links to third party websites, which we do not operate, control, monitor, endorse or guarantee. This Privacy Policy does not apply to the collection and use of information by such third party websites. We suggest that you carefully read the privacy policy and other policies of all third party websites.

We provide hyperlinks to third party websites only for the convenience of our users and it is not a recommendation that users access such third party websites. We do not guarantee the services or goods provided and sold by such third party websites to Internet users. YOU AGREE THAT YOUR USE OF ANY THIRD PARTY WEBSITE IS AT YOUR SOLE RISK AND WITHOUT WARRANTIES OF ANY KIND BY GABELLINI, EXPRESS, IMPLIED OR OTHERWISE, INCLUDING, BUT NOT LIMITED TO, WARRANTIES OF TITLE, FITNESS FOR A PARTICULAR PURPOSE, MERCHANTABILITY OR NONINFRINGEMENT. UNDER NO CIRCUMSTANCES SHALL GABELLINI BE LIABLE FOR DAMAGES ARISING FROM ANY TRANSACTION BETWEEN YOU AND ANY THIRD PARTY WEBSITE OR FOR ANY INFORMATION APPEARING ON THIRD PARTY WEBSITES.

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INFORMATION COLLECTED FROM AND/OR SHARED WITH SOCIAL MEDIA SITES:

When accessing the Site through a third party social media site and/or application, we may access some of your information from your social media account, such as name, email address, profile picture, location, friend list, posts and/or likes. Please note that some aggregate information, that does not personally identify you, such as content viewed on the social media site/application, may also be collected by us if you access the Site through a third party social media site.

Some of the Site’s services are integrated with social sharing features, e.g., liking or sharing a service on a social media platform. Depending on your settings on your social media accounts, these activities may show up on your profile and be visible to your friends/followers and/or the public. Please note that this Privacy Policy does not apply to third party social media sites, and you should always refer to the privacy policies of the relevant social media sites for information concerning their collection and processing of information.

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CHANGING, UPDATING OR REMOVING YOUR INFORMATION:

You may update, correct or remove your personal information at any time and free of charge by contacting us at pr@gabellinisheppard.com. We may ask that you identify yourself and the information you wish to access, change or delete for security purposes, and we will comply with your request as soon as reasonably practicable. By removing some of your information, you may not be able to access some of the Site’s features. We may keep some of your personal information if required by law and/or for recordkeeping purposes.

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OPT-OUTING OF OUR NEWSLETTER AND EMAIL COMMUNICATIONS:

You may unsubscribe from any marketing communications by clicking on the “Unsubscribe” button included in all of our marketing communications or by contacting us at pr@gabellinisheppard.com.

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RIGHTS OF CALIFORNIA RESIDENTS:

Pursuant to California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with the California Department of Consumer Affairs, 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834; or by telephone at (800) 952-5210; or by email to dca@dca.ca.gov. For more information about protecting your privacy, you may wish to visit: www.ftc.gov.

Our Site does not recognize Do Not Track signals. Some third parties may collect aggregate information about the users’ online activities over time and across websites when they use the Site. While this information does not include personally identifiable information, certain processing activities that combine aggregate information with other information in possession of such third parties could result in the identification of users.

If you are a resident of California, you may request that we not share your information with certain affiliates or third party providers for marketing purposes, and/or you may inquire as to how we have shared your information with third parties providers for marketing purposes. In connection with such request, we will identify the types of information shared and provide you with the names and addresses of the third parties with whom the information was shared. If you would like to receive any such information, please contact us at pr@gabellinisheppard.com.

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RIGHTS OF EU DATA SUBJECTS:

If you are a data subject located in the European Union, you have the following rights:

  • Right of Access: This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it, and that it is accurate, complete and current.
  • Right of Rectification: This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Right of Erasure: This enables you to ask us to delete or remove personal information where one of the following grounds applies:
  • ~Your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • ~You withdraw consent on which the processing is based and there is no other legal ground for the processing.
  • ~You have exercised your right to objection to the processing and there is no overriding legitimate grounds for keeping processing your data.
  • ~Your personal data have been unlawfully processed.
  • ~Your personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • Right to Objection: Where we are relying on a legitimate interest or public interest as justification, or where it is used for direct marketing purposes, you have the right to object to the processing of your personal information.
  • Right of Restriction: You have the right to request that we restrict the processing of your personal data in certain situations:
  • ~If you contest the accuracy of your personal data, you may request that its processing is restricted while we verify its accuracy.
  • ~If the processing of your personal data is considered unlawful, and you request restriction of processing instead of the deletion of your personal data.
  • ~If we no longer need the data for the purposes of its processing, but you need it for the establishment, exercise or defense of legal claims.
  • ~If you object to our processing of your data based on our legitimate interests, or where the processing is based on public interest.
  • Right of Data Portability: When the processing takes place on the basis of your consent or contract, and is carried out by automated means, you have the right to request that we provide your personal data to you in a machine-readable format.
  • Right to Withdraw Consent: If your personal data is processed on the basis of your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
  • Right to Lodge a Complaint: You have the right to complain to your local data protection authority at any time.

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CHILDREN’S RIGHTS:

We do not sell products or services for purchase by children. If you are under 18 years old, you may use the Site only under the supervision of a parent or guardian. In accordance with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), we do not knowingly collect, solicit or use personal information of children under the age of 13 provided without parental consent. Should we become aware that a user under the age of 13 has registered without verifiable parental consent, any such information will be deleted.

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UPDATES TO OUR PRIVACY POLICY:

Gabellini may amend or update all or any portion of this Privacy Policy, at any time, without notice, in its sole discretion. Please access this section regularly to verify if any changes were made to our Privacy Policy and to review the updated Privacy Policy.

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EFFECTIVE DATE:

This Privacy Policy is effective as of September 26, 2023.

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