This website is brought to you by Fine Art Bourse Limited. We take the privacy of our website users very seriously. We ask that you read this Privacy Policy ('the Policy') carefully as it contains important information about how we will use your personal data. For the purposes of the Data Protection Act 1998, Fine Art Bourse Limited ('we' or 'us') is the 'data controller' (i.e. the company who is responsible for, and controls the processing of, your personal data). As a Hong Kong company, the relevant primary legislation can be found in the Personal Data (Privacy) Ordinance Cap 486 of the Laws of Hong Kong. As we are based outside the European Economic Area, we have nominated the following representative to handle privacy issues relating to EEA issues:

Name of representative: Philip Wood




We will obtain personal data about you (such as your name, email address, postal address, phone number, credit card information) whenever you visit our site, register on the site, place an order, subscribe to the newsletter, fill out a form, and in connection with other activities, services, features or resources we make available on our Site.

For example, we will obtain your personal data when you register on the site, place an order, subscribe to the newsletter, fill out a form, apply for a bidding paddle, bid on a Lot, enter any contract through your actions, Buy a Lot, contact us for any reason, sign up to a service, enter a competition, purchase goods or services etc..

We may also obtain sensitive personal data about you if you volunteer it during the completion of an online form. If you volunteer such information, you will be consenting to our processing it for the purpose of improving customer service, personalising user experience, improving our Site, processing payments, running promotions, contests, surveys or other Site features, and sending periodic emails.

We may collect non-personal identification information about you whenever you interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about your means of connection to our Site, such as the operating system and the Internet service providers utilised and other similar information.

We may monitor your use of this website through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, Page 2 Hong Kong | United Kingdom | Australia | India traffic data, location data and the originating domain name of a user's internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, note that some parts of the Site may not function properly.

Occasionally we may receive information about you from other sources (such as credit reference agencies and third parties conducting research or providing due diligence and Know Your Client services), which we will add to the information we already hold about you in order to help us comply with legal duties and contractual obligations with third parties. This will only apply in such instances where you have already consented to our dealing with third parties under our Conditions of Business and general Conditions of Sale .



We will use your personal data for the purposes described in the data protection notice that was given to you at the time your data were obtained. These purposes include - To improve customer service Information you provide helps us respond to your customer service requests and support needs more efficiently

• To personalize user experience We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site

• To improve our Site We may use feedback you provide to improve our products and services

• To process payments We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service

• To run a promotion, contest, survey or other Site feature To send Users information they agreed to receive about topics we think will be of interest to them

• To send periodic emails We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email

• In conjunction with our Conditions of Business and general Conditions of Sale. We may use your data in order to allow us, you and others to comply with terms by which we are respectively bound. This will include for instance, the use of an address you provide as a part of the Website Registration process as a delivery address. We Page 3 Hong Kong | United Kingdom | Australia | India will make it clear where we will use or rely on information you provide for a specific purpose, in the above example we may write “Delivery Address” next to the space in which you provide this information to make it clear to you that this is the address we will rely on to deliver items including any Lot which you successfully bid on.

In addition and more generally:

• To help us identify you and any accounts you hold with us;

• Administration;

• Research, statistical analysis and behavioural analysis;

• Marketing—see 'Marketing and opting out', below; • fraud prevention and detection;

• Billing and order fulfilment;

• Credit scoring and credit checking - see 'Credit checking', below;

• Customising this website and its content to your particular preferences;

• To notify you of any changes to this website or to our services that may affect you;

• Security vetting; and

• Improving our services.



If you have given permission, we may contact you by mail, telephone, SMS, text/picture/video message, fax or email about products, services, promotions, special offers, charitable causes that may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time.

See further 'Your rights', below. If you have given permission, we may share your personal data with organisations who are our business partners and we or they may contact you (unless you have asked us or them not to do so) by mail, telephone, SMS, text/picture/video message, fax, email, other about products, services, promotions, special offers, charitable causes that may be of interest to you.

If you prefer not to receive any further direct marketing communications from us or our business partners, you can opt out at any time. See further 'Your rights', below.



We may disclose your personal data to:

• Our business partners trusted affiliates;

• Our third party contractors and service partners who require such data in order to carry out functions we have agreed to for your benefit;

• Advertisers.



We will use technical and organisational measures to safeguard your personal data, for example: Page 4 Hong Kong | United Kingdom | Australia | India;

• Access to your account is controlled by a password and username that are unique to you;

• We store your personal data on secure servers Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.



When you signed up to register with Fine Art Bourse Limited and either applied for a Paddle or intended to sell artwork you agreed that we may transfer your personal data to countries outside the European Economic Area. In particular Hong Kong where all of our auction Sales take place. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your personal data.



You have the right, subject to the payment of a small fee (currently HKD100), to request access to personal data that we may process about you. If you wish to exercise this right, you should:

• Put your request in writing;

• Include proof of your identity and address (eg a copy of your driving licence or passport, and a recent utility or credit card bill);

• Attach a cheque in the amount of HKD100 made payable to Fine Art Bourse Limited; and

• Specify the personal data you want access to, including any account or reference numbers where applicable. You have the right to require us to correct any inaccuracies in your data free of charge. If you wish to exercise this right, you should:

• Put your request in writing;

• Provide us with enough information to identify you (eg account number, username, registration details); and

• Specify the information that is incorrect and what it should be replaced with. You also have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you should:

• Putting your request in writing in an email sent to FAB@FINEARTBOURSE.COM with a header that says 'Unsubscribe' is acceptable; Page 5 Hong Kong | United Kingdom | Australia | India

• Provide us with enough information to identify you (eg account number, username, registration details); and

• If your objection is not to direct marketing in general, but to direct marketing by a particular channel (eg email or telephone), please specify the channel you are objecting to. .



We welcome your feedback and questions. If you wish to contact us, please send an email to FAB@FINEARTBOURSE.COM or you can write to us.

Our registered office is Kinwick Centre, Suites 1601-1603, 32 Hollywood Road, Central, Hong Kong.

Fine Art Bourse has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page.

We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect.

You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications