Effective date: May 25, 2018
HOW WE COLLECT INFORMATION
TYPES OF INFORMATION WE COLLECT
HOW WE USE YOUR INFORMATION
HOW WE SHARE YOUR INFORMATION
OUR LEGITIMATE INTERESTS
YOUR RIGHTS AND CHOICES
ACCESS TO PERSONAL DATA
PORTABILITY OF PERSONAL DATA
DELETION OF PERSONAL DATA
COOKIES AND ADVERTISING
LINKS TO OTHER WEBSITES AND THIRD PARTY CONTENT
INTERNATIONAL DATA TRANSFERS
HOW WE PROTECT INFORMATION
The Solomon R. Guggenheim Foundation
Peggy Guggnheim Collection
Dorsoduro 701 – 30123 venezia
Data Protection Officer:
Adriano Doria – Sinergika Srl
We may collect personal data from various sources, including:
|Directly from you, at your direction or with your consent|
|Information and content you provide|
|From companies that organize events or programs at our museums|
|From our vendors and other third parties who join with the Guggenheim in initiatives and projects (such as advertisers, fellowship sponsors, etc.)|
|Automatically, from devices that you use to connect to our Sites|
From time to time, we may use or augment the personal information we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, we may use such third party information to confirm contact or billing information, to verify professional affiliations or to better understand your interests by associating demographic information with the information you have provided.
The types of personal data we may collect may include:
|Contact information, such as name, email address, postal address, and phone number|
|Demographic information, such as date of birth, gender, and zip code|
|Information to confirm an individual’s student status or affiliation with a research; institution|
|Information in connection with employment, fellowship, or internship applications|
|Content you make available through social media accounts (e.g., when you sign in using social media plug-ins)|
|Billing information, such as credit card details, billing address, and proof of identification|
|Membership information, such as your name and any information you submit in connection with your member profile|
We may use the information we collect to:
|Respond to requests, questions, and comments|
|Manage ticket sales and group reservations|
|Offer mission-related products and services that we believe may be of interest to visitors and the public|
|Fulfill, manage, and send you information about your orders|
|Offer and administer promotions, sweepstakes, auctions, or other contests|
|Conduct market research and administer surveys|
|Provide you with newsletters, articles, announcements, invitations, and other information about programs, exhibitions, other third parties, and events|
|Provide and manage memberships|
|Collect and process donations|
|Process requests to access the Guggenheim archives|
|Offer educational and public programs|
|Analyze and enhance our communications and strategies (including by identifying when emails have been received and read)|
|Tailor the content we display to Site users in our communications, and in connection with the use of our Sites|
|Generate anonymized data for further data analytics|
|Process employment, internship and fellowship applications, as further described in the “Employment, Internship and Fellowship Applications” section below|
|Comply with legal requirements, judicial process, and our policies (including to verify Site users’ identity in connection with access or correction requests)|
|Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our Sites), and claims and other liabilities, including by enforcing the terms and conditions that govern the use of the Sites|
We may also aggregate any personal data that we collect in connection with our Sites, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated information for our own legitimate business purposes without restriction.
We may share the information we collect with:
|Other third parties who join with the Guggenheim in initiatives and projects|
|Other members or donors in limited circumstances|
|Other cultural organizations in limited circumstances|
|Others within our organization|
Service providers that perform services on our behalf or others with whom we may collaborate, including:
We may also disclose personal data to comply with a legal or regulatory obligation, protect and defend the Guggenheim’s rights or property, protect the safety of our visitors and Site users or the public, or to protect against legal liability.
We process your information given our legitimate interests in providing the public with access to our exhibitions, programs and membership. We may also process your information given our legitimate interest in undertaking marketing activities and collecting donations to promote and fund activities and programs in furtherance of our mission.
Some features of the Sites allow you to post content on our websites or mobile apps, or social media pages, such as product reviews. Content that you provide may be shared publicly or with other users or third parties.
If you apply for employment or an internship or fellowship with the Guggenheim, we will use the information you provide to process your application, to monitor recruitment statistics, and to comply with government reporting requirements. The Guggenheim is headquartered in the United States and employee, intern, fellow, and recruitment data is held there and in other Guggenheim locations worldwide. If an applicant becomes a Guggenheim employee or intern, the Guggenheim will maintain a record relating to that person’s employment or internship participation (including information collected via the employment or internship application) and may provide additional information about our data practices in connection with employee and intern data to the extent required by law.
We do not knowingly collect personal data from children under age 13. If we learn that we have collected personal data from a child under the age of 13, we will delete that information.
Individuals in certain jurisdictions, such as in the European Union, may have certain rights and choices regarding the Guggenheim’s processing of their personal data. We reserve the right to verify your identity in connection with any requests regarding personal data to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.
If the Guggenheim relies on your consent for the processing of your personal data, we will obtain your consent at the time we collect your personal data. To the extent provided by applicable law, you may withdraw any consent previously provided to us, or object at any time on legitimate grounds, to the processing of your personal data. We will apply these preferences going forward. In some circumstances, withdrawing consent to our use or disclosure of your personal data will mean that the Guggenheim may no longer be able to provide you with services or information about programming or initiatives that may be of interest to you.
You may access the data we maintain about you by submitting a request to firstname.lastname@example.org for inquiries relating to the Solomon R. Guggenheim Museum, or email@example.com for inquiries relating to the Peggy Guggenheim Collection. If we grant your request, we will provide you with a copy of the personal data we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your personal data. We may reject your request to access or correct personal data, as permitted by applicable law. If we reject your request, we will notify you of the reason(s) for the rejection.
Under certain conditions, you may request that we transfer your personal data to another entity in the format in which we maintain it in the ordinary course of business. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reason(s) for the rejection.
You may request that we delete your personal data. We may reject your request, as permitted by applicable law. For example, the Guggenheim may be required by legal, tax or other reasons to retain your personal data in its business or donation records. If we reject your request, we will notify you of the reason(s) for the rejection.
We, our service providers, and other third parties may also collect certain information about the use of our Sites by automated means, such as cookies, web beacons and other technologies.
We, our service providers and other third parties may collect information about Site users’ online activities over time and across third-party websites and our Sites.
The information that may be collected by automated means includes:
|URLs that refer users to our Sites|
|Search terms used to reach our Sites|
|Details about the devices that are used to access our Sites (such as IP address, browser type, and operating system information)|
|Details about users’ interaction with our Sites (such as the date, time, frequency, and length of visits, specific content and pages accessed and buttons clicked during the visits, and information provided by you, including email addresses)|
Web browsers may offer users of our Sites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Sites may not function correctly. For more information on how to disable cookies, please visit your internet browser’s “help” menu or you can visit http://www.aboutcookies.org/how-to-control-cookies.
Some of the third parties that collect information about your activities on our Sites may be members of organizations or programs that provide you with choices regarding the use of your browsing behavior for purposes of targeted advertising. For example, you may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting your country, and then clicking “Choices” (or similarly-titled link). Mobile app users may opt out of receiving targeted advertising in mobile apps through members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting your choices. Please note that we may also work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please note that not all tracking will stop even if you delete cookies.
The Guggenheim maintains reasonable administrative, technical and physical safeguards designed to protect the personal data we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Despite these efforts, however, no organization, including the Guggenheim, can fully eliminate risks or guarantee the security of personal data. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of information about you at any time, and we bear no liability for uses or disclosures of personal data or other data arising in connection with theft of the information or other malicious actions.
We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. When we no longer need the personal information we collect, we either anonymize the information or securely destroy the information.
Customers who reside in California and have provided their personal data to us can request, once per calendar year, information about our sharing of certain categories of personal data to third parties, for their direct marketing purposes. Such requests should be submitted to us at firstname.lastname@example.org or:
The Solomon R. Guggenheim Foundation
1071 Fifth Avenue
New York, NY 10128-0173
The Solomon R. Guggenheim Foundation
1071 Fifth Avenue
New York, NY 10128-0173
Peggy Guggenheim Collection
Palazzo Venier dei Leoni
30123 Venezia, Italia
A. Doria – RPD FPG