December 2021
Sable Stone NFT Inc. (“Sable Stone,” “we” or “us”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Information (as defined below) we collect, why we collect it, and how we use and disclose it.
Your privacy matters to us, so please do take the time to get to know and familiarize yourself with our policies and practices. Please understand that we reserve the right to change any of our policies and practices at any time, but you can always find the latest version of this Privacy Policy here on this page.
As used herein, “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is capable of being associated with an identified or reasonably identifiable individual.
When you buy and sell in our auctions or by private sale or purchase other services or goods from us, the controller of your data will be the company or companies shown in your Seller’s Agreement, Conditions of Sale, invoice or agreement. When you take part in one of our events or attend a course or lecture in person, the saleroom or office running the course or event is the controller of your data.
The controller of data collected through App.kulchur.io, our other websites and apps, online courses and object data is Sable Stone.
As used herein, “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is capable of being associated with an identified or reasonably identifiable individual.
We may collect the following categories of Personal Information directly from you:
We may collect the following categories of Personal Information automatically through your use of our services:
Our automatic collection of Personal Information may involve the use of Cookies, described in greater detail below.
We may collect and/or verify the following categories of Personal Information about you from third parties, including service providers and our affiliates:
We take reasonable and practicable steps to ensure that your Personal Information held by us is (i) accurate with regard to the purposes for which it is to be used, and (ii) not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.
We collect Personal Information about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Information to:
We will not share your Personal Information with third parties, except as described below:
If we decide to modify the purpose for which your Personal Information is collected and used, we will amend this Privacy Policy.
When you access Sable Stone, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit Sable Stone. We use Cookies to help us recognize you as a customer, collect information about your use of Sable Stone to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities; (ii) assess and improve our services and advertising campaigns.
Please note that if you reject cookies, you will not be able to use some or all of Sable Stone. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use Sable Stone.
Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from or about you. You may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy to not provide your Personal Information for those third parties’ direct marketing purposes without your consent.
We will retain your personal data for as long as is necessary to provide the relevant services, maintain business records to satisfy tax, legal and other regulatory requirements, and protect and defend against potential legal claims.
In the context of our research and records on ownership of art objects to assist with checks on authenticity, provenance and title, we will keep this data for as long as the record is relevant to our legitimate business interests and the public interest.
We understand that your personal information is important and we are committed to treating it with the utmost care and security.
No security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect Sable Stone and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take include encryption of the Sable Stone website communications with TLS; optional two-factor authentication; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
We have multiple layers of security technologies and controls in our environment which safeguard your data, while at rest or in transit, from unauthorized access or disclosure. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. In addition, our colleagues receive data protection training, and we have in place detailed security and data protection policies which colleagues are required to follow when handling personal information.
In an ever-altering threat landscape, we are constantly assessing our security defenses to ensure your data continues to stay protected. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
While customers who are located in the European Union (“EU”), European Economic Area (“EEA”) or the Channel Islands, or other locations subject to EU data protection law (collectively, “Europe”) are customers of our US entity, we recognize and, to the extent applicable to us, adhere to relevant EU data protection laws. For purposes of this section, “personal data” has the meaning provided in the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
We process personal data subject to GDPR on one or more of the following legal bases:
European residents have the following rights under GDPR, subject to certain exceptions provided under the law, with respect to their personal data:
To submit a request to exercise these rights, please contact us using the methods described at the end of this Privacy Policy. When handling requests to exercise European privacy rights, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request.
Sable Stone operates with many of our systems based in the United States. As a result, we may transfer personal data from Europe to third countries outside of Europe, including the United States, under the following conditions:
Where transfers to a third country are based on your consent, you may withdraw your consent at any time. Please understand, however, that our services may not be available if we are unable to transfer personal data to third countries.
When we transfer personal data to third countries, we endeavor to ensure adequate safeguards are implemented, for example through the use of standard contractual clauses or Privacy Shield certification.
We may engage in automated decision-making for purposes of fraud detection and prevention.
You may ask us if you have questions about the data we hold on you. Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include:
The right of access: You may request a copy of the personal data that we hold about you (a “subject access request”). If you exercise this right and we process personal data about you by automated means or as part of a filing system, once we have verified your identity and, if relevant, the authority of any third-party requestor, we are required to provide you with a description and copy of that personal data and tell you why we are processing it.
Other rights As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing, or have its processing restricted. If you have provided us with data about yourself and the grounds for processing is Contract or Consent, you may have the right to be given the data in machine readable format for transmitting to another data controller.
If we are relying on Consent as the grounds for processing your data, you may withdraw consent at any time. This will not affect the lawfulness of Sable Stone’s processing of your data prior to your withdrawal.
Please contact us at info@sablestone.consulting if you would like to exercise any of your rights explained above in relation to your personal data.
If you have any queries in relation to Sable Stone’s processing of your personal data please contact us at info@sablestone.consulting. You can also call us at 716-830-9610.
You have the right to make a complaint at any time to the applicable data privacy regulator. We would, however, appreciate the chance to deal with your concerns before you do so please contact us in the first instance using the contract details above. You can also call us at 716-830-9610.
If you have questions or concerns regarding this policy or our processing of your Personal Information, please feel free contact us at:
Sable Stone NFT Inc.
The Green, Ste A,
Dover, Delaware 19901
Tel: 716-830-9610
info@sablestone.consulting