Privacy Policy

Information on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR)

This Privacy Policy is valid as of May 20, 2026.

Introduction

This Privacy Policy is provided by Art-Rite S.r.l. with a sole shareholder – Kruso Kapital S.p.A. – a company belonging to the Banca CF+ Group, with registered office at Largo Augusto 1/A, corner of via Verziere 13, 20122 Milan (MI), share capital Euro 250,000.00 f.p., Milan Business Register: 09626240965, REA: MI-2103302, Tax Code and VAT No.: 09626240965, in its capacity as Data Controller (“Kruso Art”).

The Privacy Policy also applies to the website https://www.krusoart.com/ (“Site”), owned by Kruso Art.

We invite you to review this Privacy Policy before providing your personal data, in order to understand the data protection principles applied by Kruso Art.

In compliance with the GDPR, we hereby inform you that Kruso Art will process your personal data under the following conditions.

Art. 1. Purposes and legal basis of the processing. Mandatory or optional provision. Consequences of refusal to process.

The processing of personal data is aimed at achieving the following purposes:

• For functional requirements related to the performance of its obligations, including auction management. For this purpose, the provision of data is optional; however, failure to provide it will make it impossible to execute the sales contract. The legal basis for processing for these purposes is the need for Kruso Art to perform the purchase contract.
• For the management of the relationship with sellers and buyers (such as, for example, administration of sales proceeds, invoices, shipping). The provision of data is optional. However, any refusal will make it impossible for you to take part in the auction and/or to purchase the lot by means of private treaty. The legal basis for processing for this purpose is the obligation to perform pre-contractual and/or contractual measures and/or the legitimate interest of Kruso Art. This legitimate interest is equivalent to your interest in wanting to participate in the auction and/or private treaty.
• For checks and evaluations regarding the auction sale relationship and the risks associated with it. The provision of data is optional. However, any refusal will make it impossible to execute the sales contract. The legal basis for processing for these purposes is the need for Kruso Art to perform the purchase contract.
• To withhold an amount as a guarantee for the payment of the total amount due for the auction award and/or for the purchase of the lot through private treaty. The provision of data is optional. However, any refusal will make it impossible for you to take part in the auction and/or to purchase the lot by means of private treaty. The legal basis for processing for this purpose is the obligation to perform pre-contractual and/or contractual measures.
• For the fulfillment of tax, accounting, and legal obligations or provisions of public bodies or to ensure the regulatory compliance necessary for the performance of Kruso Art’s activities. The provision of data is optional. However, any refusal will make it impossible for Kruso Art to comply with legal obligations, which therefore will not be able to execute the purchase contract. The legal basis for processing for this purpose is the fulfillment of a legal obligation by Kruso Art.
• The information and personal data requested during registration on the Site will be used to allow you access to the reserved area of the Site and to allow you to use the online services provided by Kruso Art to registered users. These services include, among other things, the possibility of making bids for lots for sale at auction and/or by means of private treaty and of being awarded the same through the Site. The legal basis for processing data for this purpose lies in the need for Kruso Art to perform pre-contractual measures adopted at the request of the data subject. The provision of data is optional; however, failure to provide it will make it impossible to register on the Site and, consequently, to access the reserved services.
• Subject to your consent, for sending newsletters, advertising, and information material by Kruso Art by means of automated systems, such as e-mail, SMS, MMS, or WhatsApp (marketing purposes). Consent to the processing of data for marketing purposes is optional. However, failure to provide consent will make it impossible to receive advertising and information material from Kruso Art, as well as to send you newsletters, by means of automated systems, such as e-mail, SMS, MMS, or WhatsApp. The legal basis for processing is your consent.
• Subject to your consent, for the analysis of your consumption choices and purchasing habits by Kruso Art, through the detection of the type and frequency of participation in auctions and/or purchases by means of private treaty, for the purpose of sending information and/or advertising material of specific interest to the user, by means of automated systems, such as e-mail, SMS, MMS, or WhatsApp (profiling purposes). Consent to the processing of data for profiling purposes is optional. However, failure to provide consent will make it impossible for Kruso Art to carry out the analysis of consumption choices and purchasing habits, through the detection of the type and frequency of participation in auctions and/or purchases by means of private treaty for the purpose of sending information and/or advertising material of specific interest to the user. The legal basis for processing is your consent.
• To respond to your requests for information, or to address your complaints, reports, and disputes. The provision of data for this purpose is optional. However, any refusal will make it impossible for Kruso Art to respond to your requests. The legal basis for processing is represented by the legitimate interest of Kruso Art in managing and resolving such requests. This legitimate interest is equivalent to your interest in wanting to obtain answers to the requests made to Kruso Art.
• For the establishment, exercise, or defense of a legal claim in relation to the execution of the sales contract. The provision of data is optional. However, any refusal will make it impossible for Kruso Art to defend its rights and therefore the impossibility for Kruso Art to follow up on the sales agreement. The legal basis for processing is the legitimate interest of Kruso Art in defending its rights.

Notwithstanding the foregoing, it is understood that Kruso Art may still use your personal data solely for the purpose of correctly fulfilling the obligations provided for by current laws and the obligations arising from the contractual relationships in place between you and Kruso Art.

We remind you that you may object to the processing of your personal data also through the specific link at the bottom of any promotional email sent by Kruso Art.

The Data Controller does not process special categories of data or judicial data.

Art. 2. Processing methods

The processing of your personal data will be carried out primarily with the aid of electronic or automated means, according to the methods and with the tools suitable to guarantee its security and confidentiality in accordance with the GDPR.

The information acquired and the processing methods will be relevant and not excessive with respect to the type of services rendered. The data will also be managed and protected in environments where access is under constant control.

Art. 3. Communication and dissemination of data

Your data may be communicated to:

• to employees and/or collaborators of Kruso Art as persons authorized to process data under the direct authority of Kruso Art or the manager appointed by it;
• all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative provisions;
• banking institutions and companies that manage national or international payment circuits through which online payments are made for the purchase of lots at auction and/or by means of a private treaty;
• post offices, couriers or shippers in charge of delivering the lots;
• companies, consultants or professionals possibly in charge of the installation, maintenance, updating and, in general, the management of Kruso Art’s hardware and software or which Kruso Art uses to provide its services;
• companies or Internet providers in charge of sending documentation and/or information or advertising material;
• companies in charge of processing and/or sending advertising and information material on behalf of Kruso Art;
• to all those public and/or private entities, natural and/or legal persons (legal, administrative, and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Labor Offices, etc.), if the communication is necessary or functional for the correct fulfillment of the contractual obligations assumed by Kruso Art, as well as the obligations deriving from the law;
• to Kruso Kapital S.p.A. and Banca CF+ S.p.A. as part of management and coordination activities, in order to allow the fulfillment of reporting obligations to the Board of Directors and the Bank of Italy.

Your data will not be disseminated, except in anonymous and aggregated form, for statistical or research purposes.

Art. 4. Kruso Art; Data Controller

The Data Controller is Kruso Art, who can be contacted at the following addresses:

• E-mail by writing to the address
  info@krusoart.com;
• By ordinary mail by writing to the address:
  Art-Rite S.r.l. a socio unico
  Largo Augusto 1/A, ang. via Verziere 13, 20122 Milano (MI)

Art. 5. Retention of personal data

Personal data will be stored according to the following logic:

• to execute the sales contract, data will be stored for ten years from the date the purchase contract is concluded;
• as provided for by Article 2220 of the Civil Code, invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration;
• for the purpose of complying with regulations, for the time necessary for this purpose;
• the personal data provided by you at the time of registration on the Site will be stored and processed until you unsubscribe from the Site;
• for marketing and profiling purposes, until any withdrawal of consent. The personal data you may have provided for marketing and profiling purposes will be stored for two years from the last opening of the email sent for these purposes, of which there is evidence, unless you previously withdraw your consent;
• to respond to complaints, reports, or disputes, the data will be deleted once the assistance service is completed;
• your personal data will be stored only for the time necessary to ensure the correct provision of the services offered by Kruso Art. Kruso Art reserves the right to record telephone bids received;
• for the purpose of legal defense, for the time necessary to defend its rights and, in any case, until the judgment becomes final.

Art. 6. Transfer of personal data to third countries

Kruso Art is based within the European Union. Therefore, the processing of your data is legally secure as it is governed by the GDPR.

If the transfer of your personal data takes place to a non-EU country for which the European Commission has issued an adequacy decision, the transfer is considered legally secure in any case.

Kruso Art, for the proper functioning of the Site, may transfer your personal data to the United Kingdom and the United States, in compliance with the adequacy decisions adopted by the European Commission.

Art. 7. Rights of the data subject

Pursuant to Art. 13 of the GDPR, Kruso Art informs you that you have the right to:

• request from Kruso Art access to your personal data and the rectification or erasure thereof, or the restriction of processing concerning you, or to object to their processing, in addition to the right to data portability;
• withdraw consent at any time without affecting the lawfulness of processing based on consent given before the withdrawal;
• lodge a complaint with a supervisory authority (e.g.: the Italian Data Protection Authority);
• know of the existence of an automated decision-making process, including profiling as referred to in Article 22, paragraphs 1 and 4 of the GDPR and, at least in such cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

The above rights may be exercised by making a request without formalities to Kruso Art at the contacts indicated above.