Supplemental Website Privacy Notice

For CA, CO, VA, UT, and CT Customers

Last Revised: July 23, 2024

This Supplemental Website Privacy Notice (“Supplemental Notice”) applies only to information collected about California, Colorado, Virginia, Utah, and Connecticut consumers AND supplements the information contained in the Wendover Art Group Privacy Policy. It provides information required under the California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively, the “CPRA”), the Colorado Privacy Act of 2021 (the “CPA”), the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”), the Utah Consumer Privacy Act of 2022 (the “UCPA”), and the Connecticut Data Privacy Act of 2022 (“CDPA”).

This Supplemental Notice describes Wendover Art Group (“Wendover,” “we,” “our,” or “us”) practices regarding the collection, use, and disclosure of Personal Information and provides instructions for submitting data subject requests. Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, we have indicated that such language applies only to those consumers.

If you are unable to review or access this notice due to a disability, you may contact Wendover at privacy@wendoverart.com to access this notice in an alternative format.

I. Definitions Specific to this Supplemental Notice

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes “personal data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA. Personal Information also includes “Sensitive Personal Information,” as defined below, except where otherwise noted.
“Sensitive Personal Information” means Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying a consumer and Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Sensitive Personal Information also includes “sensitive data” as that term is defined in the CPA, VCDPA, UCPA, and CDPA.
“Third Party” has the meanings afforded to it in the CPRA, CPA, VCDPA, UCPA, and CDPA.
“Vendor” means a service provider, contractor, or processor as those terms are defined in the CPRA, CPA, VCDPA, UCPA, and CDPA.

To the extent other terms used in this Supplemental Notice are defined terms under the CPRA, CPA, VCDPA, UCPA, or CDPA, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein. As there are some variations between such definitions in each of the five statutes, the definitions applicable to you are those provided in the statute for the state in which you are a consumer. For example, if you are a Virginia consumer, terms used in this Supplemental Notice that are defined terms in the VCDPA shall have the meanings afforded to them in the VCDPA as this Supplemental Notice applies to you.

II. Collection and Processing of Personal Information and Sensitive Personal Information

We, and our Vendors, may have collected and processed the following categories of Personal Information about you in the preceding 12 months:

Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, or other similar identifiers;
Contact and financial information, including phone number, address, email address, bank account number, credit or debit card number, or other financial information;
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement;
Inferences drawn from any of the information listed above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (e.g., predications about an individual’s preferences or tendencies);
Individuals’ written signatures; and
Sensitive personal information, including:

Personal Information that reveals account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account.

III. Categories of Personal Information and Sensitive Personal Information We Disclose to Vendors and Third Parties

We may disclose the following categories of Personal Information to Vendors and Third Parties:

Identifiers, such a real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, or other similar identifiers;
Contact and financial information, including phone number, address, email address, bank account number, credit or debit card number, or other financial information;
Internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement;
Inferences drawn from any of the information listed above to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (e.g., predications about an individual’s preferences or tendencies);
Sensitive personal information, including:

Personal Information that reveals account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials for allowing access to an account.

IV. Purposes for Collecting and Processing Personal Information

We, and our Vendors, collect and process Personal Information (excluding Sensitive Personal Information) described in this Supplemental Notice to:

Register your online account and profile;
To send you relevant email communications;
To estimate sales tax and shipping costs on orders;
To process and fulfill your order;
To assign a salesperson and account manager to you;
To contact you regarding your account or orders;
To apply payments and appropriate tax amounts to your account;
To invoice your order and facilitate payment; and
To personalize, advertise, and market our products and services.
Comply with laws and regulations including, without limitation, applicable tax, health and safety, anti-discrimination, immigration, labor and employment, and social welfare laws;
Monitor, investigate, and enforce compliance with and potential breaches of Wendover’s policies and procedures and legal and regulatory requirements;
Comply with civil, criminal, judicial, or regulatory inquiries, investigations, subpoenas, or summonses; and
Exercise or defend the legal rights of Wendover and its employees, affiliates, customers, contractors, and agents.

V. Purpose(s) for Processing Sensitive Personal Information

We, and our Vendors, collect and process the Sensitive Personal Information described in this Supplemental Notice only for:

Performing the services or providing the goods reasonably expected by an average consumer who requests those goods or services;
Ensuring security and integrity to the extent the use of the consumer’s Personal Information is reasonably necessary and proportionate for these purposes;
Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with us; provided that we will not disclose the consumer’s Personal Information to a Third Party and/or build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business;
Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf; and
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

VI. Sources from which We Collect Consumer Personal Information

We collect Personal Information directly from consumers. We also collect Personal Information from joint marketing partners, public databases, providers of demographic data, social media platforms, Vendors, and Third Parties.

VII. Categories of Entities to Whom We Disclose Consumer Personal Information and Sensitive Personal Information

Affiliates & Vendors. We may disclose Personal Information to our affiliates and Vendors for the purposes described above in this Supplemental Notice. Our Vendors provide us with third-party payment processing services and website services, as well as other products and services, such as web hosting, data analysis, customer service, infrastructure services, technology services, email delivery services, legal services, and other similar services. We grant our Vendors access to Personal Information only to the extent needed for them to perform their functions.

Third Parties. We may disclose your Personal Information to the following categories of Third Parties:

At Your Direction. We may disclose your Personal Information to any Third Party with your consent or at your direction.
Business Transfers or Assignments. We may disclose your Personal Information to other entities as reasonably necessary to facilitate a merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Legal and Regulator We may disclose your Personal Information to government authorities, including regulatory agencies and courts, as reasonably necessary for our business operational purposes, to assert and defend legal claims, and otherwise as permitted or required by law.

We will not collect a category of Personal Information not listed above, or use any Personal Information collected in any of the above categories for a business purpose not listed above, without first providing you with notice.

VIII. Retention of Data

We intend to retain each category of Personal Information described above only for as long as necessary to fulfill the purpose for which it was collected, or a related and compatible purpose consistent with the average consumer’s expectation, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain Personal Information: why we collected the Personal Information; the nature of the Personal Information; the sensitivity of the Personal Information; our legal obligations related to the Personal Information; and risks associated with retaining the Personal Information.

IX. Your Rights to Your Personal Information

California, Colorado, Virginia, Utah, and Connecticut consumers have certain rights with respect to the collection and use of their Personal Information. Those rights vary by state. As required by the CPRA, we provide detailed information below regarding the data subject rights available to California consumers. Colorado, Virginia, Utah, and Connecticut consumers have similar rights and can find more detail by referencing the CPA, VCDPA, UCPA, or CDPA, as applicable.

Right to Receive Information on Privacy Practices. You have the right to receive the following information at or before the point of collection:

The specific pieces and categories of Personal Information we collected about you;
The categories of sources from which Personal Information was collected;
The business or commercial purpose for which Personal Information was collected, and if sold, the business purpose for such sale;
The categories of Personal Information we sold or disclosed; and
The categories of third parties with which we shared Personal Information.

Right to Delete. You have the right to request that we delete certain Personal Information that we have collected. Please note that there are circumstances in which we may not be able to comply with your deletion request. We will notify you if that is the case.

Right to Correct. You have a right to request that we correct any inaccurate Personal Information we may retain about you.

Right to Opt-Out of the Sale and Sharing of Your Personal Information.

You have the right to opt-out of the sale and sharing of your Personal Information and the right to opt out of the processing of Personal Information for targeted advertising purposes, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPRA, CPA, VCDPA, UCPA, and CDPA. We do not sell or share Personal Information or process Personal Information for targeted advertising purposes. Relatedly, we do not have actual knowledge that we sell or share Personal Information of California consumers under 16 years of age.

Do Not Sell or Share My Personal Information

Right to Limit the Use of Your Sensitive Personal Information. You have the right to instruct us to limit the use and disclosure of your sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by an average Consumer or for specific business purposes defined by applicable law. We do not use Sensitive Personal Information for purposes beyond those authorized by the CPRA. You have the right to limit the use of your Sensitive Personal Information to the purposes authorized by the CPRA. To submit a request to limit the use of your Sensitive Personal Information, please click [HERE]. We will process your request(s) in accordance with applicable law.

Right to Non-discrimination. You have a right to exercise the above rights and we will not discriminate against you for exercising these rights. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests, as permitted under law.

Instructions to Exercise your Rights. If you would like to make any of the data requests listed above, please click [HERE] or call 1-888-743-9232. The link will take you to an interactive webform that you can complete and submit to make a request for information that we will then verify. If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request, and the level of verification will depend on the request being submitted. You may also submit a request by emailing us at privacy@wendoverart.com.

You may designate an authorized agent to exercise your rights under the CPRA on your behalf. Such individual must be power of attorney, or another authorized agent registered with the California Secretary of State.

Please note that there are circumstances in which we may not be able to comply with your request, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if that is the case.

Right to Appeal.. If you choose to appeal a decision, your request would move from our operations team to our legal team. If you would like to appeal a decision regarding your data request, please contact us at privacy@wendoverart.com or call 1-888-743-9232. Please state that your request is an “Appeal,” and describe the date and nature of your original request. We will respond to your appeal in accordance with applicable law.

X. Verification Process

We may ask you to provide information that will enable us to verify your identity in order to comply with your data subject request. In particular, when a California consumer authorizes an agent to make a request on their behalf, we may require the agent to provide proof of signed permission from the consumer to submit the request, or we may require the consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.

XI. Additional Information

If you would like additional information regarding our Supplemental Notice or need assistance accessing the notice in an alternative format, please email privacy@wendoverart.com.

More information about our privacy practices can be found in our Wendover Art Group Privacy Policy. If you have any questions regarding this Supplemental Notice or Wendover’s Collection and use of your Personal Information, please contact us at privacy@wendoverart.com.

XII. Additional California Privacy Rights

Shine the Light Request. California Civil Code Section § 1798.83 permits users of our website who are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to privacy@wendoverart.com with the subject “Shine the Light Request.”

XIII. Changes to Our Supplemental Notice

Wendover reserves the right to amend this Supplemental Notice at our discretion and at any time. When we make changes to this Supplemental Notice, we will post an updated notice on our website with a new revised date.

XIV. Contacting Us

If you have any questions regarding this Supplemental Notice, please contact us via email at privacy@wendoverart.com, by phone at 1-888-743-9232, or at the following address:

Wendover Art Group

6465 126th Ave. N.

Largo, FL 33773