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PRIVACY POLICY

Privacy Policy
Effective Date: July 21, 2022


SCOPE
Welcome to the Jesie Mac group of companies (“Jesie Mac”, Jesie Mac LLC, Jessie Mac Gallery" or “we”).

From its beginnings, Jesie Mac has built its business on the trust of its customers, clients and visitors. We endeavor to understand their interests in art and design and, at the same time, protect their
privacy. Those values remain essential to us even as we have grown into a global network of
offices in approximately 40 countries. Jesie Mac publishes this Privacy Policy to let you know
how we collect, use, and disclose your personal information in the course of operating our
business. It also describes your rights in relation to this information. In some circumstances,
such as for certain events, we may provide additional information regarding our data practices.
This Privacy Policy applies to any Jesie Mac service, event, website, mobile application or other
digital or non- digital service, and any hard copy (paper) form which provides a link to or refers
to this Privacy Policy.


For those who reside in California, the United Kingdom or the European Economic Area, please
see the end of this Policy for additional information regarding our practices.


INFORMATION Jesie Mac COLLECTS ABOUT YOU
Personal information is information, or a combination of pieces of information, that could
reasonably allow you to be identified. As described in more detail below, we collect personal
information about you from a variety of sources, including information we collect from you
directly, information we collect about you from other sources, and information we collect
automatically from you.


Information We Collect Directly From You
We collect information that you submit to us. The types of information that we collect directly
from you include: personal details (e.g., name, date of birth, alias and/or avatar alias), contact
details (e.g., phone number, email address, postal address), transaction information (e.g.,
bidding or purchase records, shipping details, information about items you purchase or wish to
consign), details about your collection, limited financial information (e.g., tokenized payment
information in connection with your purchases, wire instructions, digital wallet details and
address), username and password, user ID, unique device ID, information on forms required for
certain transactions (e.g social security number), and identification information (e.g. photo ID).
We rely on the information you provide to us or that we collect or observe about your individual
interactions with us, for example, if you attend a live event, consign property, participate in one
of our auctions, become a client, register or bid online.


Information We Collect From Other Sources
We share information within the Jesie Mac group of companies. We may collect information
about you from external sources, including social media sites and data supplementation
services. 

-2- Types of information we collect about you from other sources include your public profile information, family relationships, and organizational affiliations. We may work to expand our
customer base by acquiring names, contact data, financial information, affiliations, and
demographic information from other sources such as private companies, public registers, and

social media sites, where permitted by law. We may also generate information such as
appraisals, profiles, and a history of our relationships with you based on the information you
have provided or that we have obtained from other sources, as permitted under applicable law.


Information We Collect Automatically
We may make video recordings of our exhibitions, gallery spaces, and certain live events.
We record calls made to our customer care line for quality assurance, compliance purposes,
and recordkeeping purposes.


We may use common data collection technologies as you visit our websites or apps or interact
with our emails. For example:
– Our logs gather date, time, information about your browser and system or device
configuration, information about how you interact with our digital properties, and an IP address
for all visitors to our sites.
– If you have registered with us online, we use data collection technologies to collect information
that indicates your individual interests in our websites, online platforms and apps, and your
response to our emails and marketing campaigns.
– The Cookies and similar technologies on our digital platforms can also read and collect data
about your browsers as you visit and interact with those platforms: please read our Cookie
Policy for more detailed information about what cookies are, what kinds are used on our sites,
and what choices you have. As described further in our Cookie Policy, we use these
technologies to enable you to use our digital platforms, learn how you and others interact with
our digital platforms, personalize the content on our digital platforms, and to deliver advertising
based on your interests, including those inferred from your activities over time and across digital
platforms operated by us and others.
– In general, our app will communicate data you provide about yourself, for example,
registration, purchase, or bidding data, to our databases and systems. An app may, however,
rely on other data collection technologies to recognize the device you use for viewing and to
personalize your experience. If our app relies on additional data collection technologies that
collect or use data about individual users, we will include additional notice either within the app
or in a policy that accompanies it.
– We also use and allow certain other companies to use technologies that are similar to cookies
(for example pixels and gifs) when we send you emails.


HOW JESIE MAC USES INFORMATION ABOUT YOU
Jesie Mac uses data about you for the following purposes, as permitted by applicable law: – To
manage and assure the integrity of our auctions.


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– To fulfill your orders and purchases, facilitate consignments, provide the services,
publications, catalogs, and information you request, and manage your account, enquiries and
requests and to manage your relationship with us.
– To send you information about upcoming events and content that you may be interested in. –
To improve and personalize based on your inferred interests from our website and services.
– To match online ads to your interests, arrange for Jesie Mac and other companies’ ads to
reach you after you have left our sites, and help advertisers show you ads that are more
relevant to your interests.

– To expand our online audiences.
– To provide, maintain, and protect our digital offerings.
– To check your identity and to protect against the risk of fraud and to detect money laundering
or other financial crime.
– To carry out anti money laundering checks, risk screening, crypto wallet and transaction
screening and monitoring and blockchain analytics.
– To provide you (where required) with a digital wallet to enable you to receive an NFT that you
have purchased.
– To protect and defend our rights and property, you, or third parties.
– To comply with legal obligations and regulations to which we are subject and cooperate with
regulators and law enforcement bodies.
– To develop, improve and test certain of our products and services.
– For other purposes that we tell you about specifically when you register or provide data about
yourself to us.
HOW Jesie Mac DISCLOSES INFORMATION ABOUT YOU
We share information within the Jesie Mac group of companies. Jesie Mac may disclose
personal information to other companies or entities as follows:
– To business partners and vendors that work on our behalf to provide services such as item
shipments, mailings, customer account and technology support, secure payment processing,
fraud prevention, digital marketing management, and data storage.
– To our auction partners in association with auctions.
– To consigners, sellers and others as needed to facilitate a consignment or purchase, including
to arrange the delivery of property to you.
– To organizations we partner with to host events.
– To digital wallet and cryptocurrency providers as required to complete your sale or purchase.
Please see their privacy policies for details of how they use your personal information. One such
provider is Circle Internet Financial, LLC ("Circle") that provides payment processing services on
Sotheby's Metaverse. Note that as part of the process of minting NFTs, your digital wallet details
will be made available on the public blockchain to enable the NFT to be made available to you
and will be a permanent record of the transaction, along with the details of the NFT’s you
purchase.
– To law enforcement or other entities that present valid legal process or in our discretion,
unless otherwise prohibited by law, to protect human safety, our rights, or the rights of others.


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– To meet certain legal compliance requirements, for example under anti-money laundering
laws or customs laws and regulations.
– To US, UK and overseas regulators, law enforcement agencies and authorities in connection
with their duties, such as preventing or detecting crime.
– As part of a sale, merger, liquidation, or transfer of our business assets.
– We may disclose information about you to Jesie Mac International Realty, a company outside
of the Jesie Mac corporate group and a business partners that we coordinate our activities with
from time to time.

– We may share information with digital advertising and analytics firms so that they may
recognize your devices and deliver interest-based content and advertisements to you. The
information we share may include your name, postal address, email, device ID, or other
identifier. These firms may collect additional information from you, such as your IP address and
information about your browser or operating system; may combine information about you with
information from other companies in data sharing cooperatives in which we participate; and may
place or recognize their own unique cookie on your browser. To learn about certain choices you
may have with regard to such sharing, please see our Cookie Policy or click here.


• YOUR CHOICES
You have a choice about and control over:
– Receiving marketing messages from us. We may contact you by email, text, or SMS
messaging.
• – We encourage you to visit Jesie Mac Preference Pages to let us know your preferences in
relation to email marketing.
• – You may also stop email marketing by using the “opt out,” or “unsubscribe” mechanism at the
bottom of our email marketing messages. In most cases, we will give you a choice about
stopping just one kind of email or opting out of all email marketing from us.
– Whether cookies can be set or read on your browser. You can learn more about controlling
cookies placed on your device as you visit our sites in our Cookie Policy.
– Whether your account is up to date. You may review and edit the personal information that is
stored in your user account on our website (e.g., your passwords and other contact information)
by visiting the “Profile” area of your account on our website or by contacting Jesie Mac via the
email address at the end of this Policy. We will endeavor to respond to your request as soon as
practicable. Before we are able to provide you with any information, correct any inaccuracies, or
delete any information, however, we may ask you to verify your identity and to provide other
details to help us to respond to your request.
–Your public profile on Jesie Mac Metaverse and Metaverse notifications. Details of your bidding
activity, your collection (i.e. any lots you have won) and your saved items (i.e. saved lots) will be
displayed in your public profile on Jesie Mac Metaverse if you are a Metaverse user. These
details will be publicly available unless you change your settings. You will also receive
notifications regarding saved items and items you have bid on. You can go to your Settings on
Metaverse to change your settings in respect of the information that will be displayed as part of
your public profile and the notifications you receive in relation to the Metaverse at any time.


INFORMATION SECURITY AND STORAGE
We will
– Maintain business records for analysis and/or audit purposes.
– Comply with record retention requirements under the law or other relevant legal or regulatory
requirements.
– Defend or bring any existing or potential legal claims.
– Deal with any complaints regarding the services.

– Preserve historical records of transactions and property.
delete your personal information when it is no longer required for these purposes.


CHILDREN’S DATA
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Jesie Mac is a global company. We receive data collected locally by members of the Jesie Mac
group and collect data online directly from individuals in countries around the world. We may
process that data on servers globally. We have put recognized protections in place for the
transfer of data from members of the Jesie Mac group in the EU to our servers in the United
States (“US”).
We protect your information using physical, technical, and administrative security measures to
reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Please be
aware, though, that no security measures are perfect or impenetrable. You remain responsible
for protecting your username and password and for the security of information you transmit to
us over the Internet.
We will keep your personal information for as long as we have a relationship with you. Once our
relationship with you has come to an end, we will retain your personal information for a period of
time that enables us to:
Our websites are directed to adults. We do not accept children as clients or knowingly collect
data about them.


• THIRD PARTY WEBSITES
Our websites may contain links to other websites not owned or controlled by Jesie Mac. Those
websites may collect information about you. Jesie Mac is not responsible for their practices or
content.
Additionally, we may work with auction partners so that you can bid on Jesie Mac items from
other sites or platforms. If you participate in an online auction on another company’s site or
platform, please note that those companies may transfer data about you to us to fulfill
successful bids and that we may use that data in a manner consistent with this Policy. Please
note that if you use another company’s auction site, you should review the posted privacy policy
applicable to that site.
• HOW TO CONTACT US
For questions about this Privacy Policy please email us at privacycompliance@sothebys.com or
contact:
Jesie Mac
Attn: Legal and Compliance Department

324 S Beverly Drive

Suite 977

Beverly Hills, CA 90212


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• ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

We may collect the following
categories of personal information from and about you:
• Identifiers: Such as your name, email address, phone number, IP address, device identifier,
online identifier, and government-issued identification numbers you provide.
• Internet activity: Such as browsing history, search history, content or items viewed, account
logins, and interactions with emails, digital ads, and other communications.

• Transactions: Such as bidding and purchase records, items considered for purchase or
bidding, items offered for consignment, shipping details, and events attended.
• Payment information: Such as tokenized payment information or wire instructions.
• Demographics: Such as information about your gender or age.
• Location information: Such as the addresses you provide or your general location as
inferred from your IP address or other network information.
• Professional and employment information: Such as information provided on valuation
or credit documents.
• Video and audio: Such as recordings of auctions or client service calls.
• Inferences: Such as our assessment of the types of art, furniture, objects or jewelry in
which you may have an interest.
We share your information for the following business purposes:
• To obtain services such as item shipments, mailings, customer account and technology
support, secure payment processing, fraud prevention, digital marketing management, and data
storage;
• To coordinate auctions with business partners;
• To coordinate events;
• For legal and compliance purposes;
• To cooperate with law enforcement or other reasonable requests for information;
• To support potential sales, mergers, liquidations, or transfers of our business assets.
We disclose all of the categories of personal information noted above with service providers that
process personal information on our behalf (e.g., data storage providers, email services,
Internet service providers, and research firms), business partners (e.g., event coordinators,
professional advisors and consultants), government and law enforcement entities, advertising
and marketing companies, and our affiliates.
We also disclose certain personal information in exchange for services, insights, or other
valuable consideration. California law treats such disclosures as “sales” even if no money is
exchanged. We may disclose or sell the following categories of information to the third parties
listed below:
Categories of personal information disclosed in exchange for valuable consideration
Identifiers Internet activity
Transactions Payment information
Categories of third parties to whom this information is or was disclosed in the past 12 months
Digital advertising and analytics companies, marketing partners, social media platforms, auction
partners and event co-hosts.
Digital advertising and analytics companies, social media platforms, and marketing partners.
Digital advertising and analytics companies, auction partners and event co-hosts, and marketing
partners.
N/A
Categories of personal information disclosed in exchange for valuable consideration
Demographics
Location information
Professional and employment information Video and audio information

Inferences
Categories of third parties to whom this information is or was disclosed in the past 12 months
Digital advertising and analytics companies, marketing partners, social media platforms, auction
partners and event co-hosts.
Digital advertising and analytics companies, auction partners and event co-hosts.
Marketing partners, auction partners, and event co- hosts.
Auction partners and event co-hosts.
Digital advertising and analytics companies, marketing partners, social media platforms, auction
partners and event co-hosts.


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Residents of California have the following rights:
• Right to know. You may request that we provide you with information about the
categories of your personal information that we collect, the specific pieces of personal
information that we hold about you, the categories of sources from which we collected the
information, our reasons for collecting and sharing the information, and the types of third parties
with which we share the information.
• Right to deletion. You may ask us to delete your personal information, subject to certain
exceptions.
• Right to opt out of sales. You have the right to opt out of certain disclosures of your personal
information for valuable consideration. You can exercise this right through the “Do Not Sell My
Personal Information” link.
• Right to be free from discrimination. You have the right to not be discriminated against for
exercising any of the above-listed rights. We may, however, provide a different level of service
or charge a different rate reasonably relating to the value of your personal information.
If you are a California resident and would like to exercise any of the above rights, please submit
your request at privacycompliance@sothebys.com.
Please note that we may request specific information from you in order to verify your identity,
and there may be circumstances where we will not be able to honor your request. For example,
if you request deletion, we may need to retain certain personal information to comply with our
legal obligations or other permitted purposes. We will only use personal information provided in
a verifiable consumer request to verify your identity or authority to make the request. If you are
submitting a request through an authorized agent, the authorized agent must provide us with
your signed written permission stating that the agent is authorized to make the request on your
behalf. We may also request that any authorized agents verify their identity and may reach out
to you directly to confirm that you have provided the agent with your permission to submit the
request on your behalf.


ADDITIONAL INFORMATION FOR EEA, UK, AND SWITZERLAND CUSTOMERS & VISITORS
TO JESIE MAC SITES AND APPS


Who is responsible for your data?
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If you transact in an auction or private sale in a Jesie Mac office in the EEA, UK, or Switzerland,
then the Jesie Mac entity running the auction will be the data controller for that data. The name

and contact details for this entity will be set out in your consignment agreement, private sale
agreement, invoice, or Conditions of Business for the auction.
If you visit Sothebys.com, another Jesie Mac website (such as Jesie Mac Metaverse) or use a
Jesie Mac app, then the data controller will be Jesie Mac, a US entity, and this Policy contains
our contact details. Jesie Mac main establishment in the EU is Jesie Mac France. Jesie Mac in
London is the Jesie Mac UK-based establishment.
What is the legal basis on which Jesie Mac relies to process your data?
On some occasions, Jesie Mac processes your data with your consent (e.g., when you agree
that we may place cookies, or if you ask Jesie Mac to send you information about upcoming
events).


On other occasions, Jesie Mac processes your data when we need to do this to fulfill a contract
with you (e.g., for billing purposes) or where we are required to do this by law (e.g., where we
have to fulfill anti-money laundering requirements). If it is mandatory for you to provide data for
these purposes, we will make this clear at the time and will also explain what will happen if you
do not provide the data (e.g., that we will not be able to process a bid at auction).
Jesie Mac also processes your data when it is our legitimate interests to do this and when these
interests are not overridden by your data protection rights. For example, Jesie Mac has a
legitimate interest in ensuring the security and integrity of our auctions, in learning about the
interests and preferences of our current and prospective clients, in developing new business
opportunities, in maintaining accurate business and provenance records, and in ensuring that
our websites and apps operate effectively. When we process personal information to meet our
legitimate interests, we put in place robust safeguards to ensure that your privacy is protected
and to ensure that our legitimate interests are not overridden by your interests or fundamental
rights and freedoms.


Data transfers
Jesie Mac may transfer personal information to countries outside the EEA and the UK, including
to countries which have different data protection standards to those which apply in the EEA and
the UK. Jesie Mac has put in place European Commission approved standard contractual
clauses to protect this data. For more information on the appropriate safeguards in place,
please contact us at the details above.


Automatic Decision-Making
The way we analyse personal information for advertising and marketing purposes and for client
development, risk assessment, or fraud prevention may involve profiling, which means that we
may process your personal information using software that is able to evaluate your personal
aspects and predict risks or outcomes. For example, we may use the information we collect
(e.g., bidding and purchase information, browsing history, and consignment history) to infer your
interests. And we may use those inferences to support automated decisions about the content,
recommendations, and offers we present to you on our digital properties. We may use
automated tools to flag for further review suspicious activities associated with our services (e.g.,
multiple logins from different locations within a short period of time or activities associated with
suspicious IP addresses). These automated activities will not, in themselves, have legal or
similar effects for you.


Your rights

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You may ask Jesie Mac for a copy of your personal information, to correct it, erase it, restrict our
use of it, or to transfer it to other organizations at your request subject to local law. You also
have rights to object to some processing and, where we have asked for your consent to process
your data, to withdraw this consent. In particular, you have rights to object to direct marketing at
any time.


Where we process your data because we have a legitimate interest in doing so (as explained
above), you also have a right to object to this. These rights may be limited in some situations –
for example, where we can demonstrate that we have a legal requirement to process your data.
If you would like to discuss or exercise such rights, please contact us at the details below. We
encourage you to contact us to update or correct your information if it changes or if the personal
information we hold about you is inaccurate. We will contact you if we need additional
information from you in order to honor your requests.


We hope that we can satisfy queries you may have about the way we process your data. We
are committed to working with you to obtain a fair resolution of any complaint or concern about
privacy. However, if you have unresolved concerns and believe that we have not been able to
assist with your complaint or concern, you also have the right to complain to data protection
authorities.


For questions about this Privacy Policy please email us at info@jesiemac.com or
contact:
Jesie Mac
Attn: Legal and Compliance Department

324 S Beverly Dr

Suite 977
Beverly Hills, 90212


• CHANGES TO THIS POLICY
You may request a copy of this Policy from us using the contact details set out above. We may
modify or update this Policy from time to time. If we change this Policy, we will notify you of the
changes by updating this Policy on our website. Where changes to this Policy notice will have a
fundamental impact on the nature of the processing or otherwise have a substantial impact on
you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights.

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