PRIVACY POLICY
INTRODUCTION
This Privacy Policy sets out how Priestley & Ferraro holds and processes any information you give to us. This policy covers all our activities worldwide and explains the type of information we may hold and process.
This policy applies to information held about clients and prospective clients, suppliers and prospective suppliers, service providers and all other persons about whom Priestley & Ferraro holds information. By 'information' we mean personal information about you that we collect, use, share and store. In this policy, 'we', 'us' and 'our' means Priestley & Ferraro and 'you' means the individual to whom the information relates.
This policy is effective from 25th May 2018 in accordance with the General Data Protection Regulation. The policy may change from time to time and any changes will be updated on our website so we recommend that you check this page regularly.
WHO WE ARE
HOW AND WHEN WE COLLECT YOUR PERSONAL DATA
Most of the personal data we hold about you comes directly from you and is provided face to face, by mail or email, or over the telephone. This is usually because you have expressed an interest in buying or selling artworks or hearing about our exhibitions or events. In addition, your image may be collected by CCTV monitors when you visit our gallery.
WEBSITE
We also collect data when you visit our website. This may include information about your IP address, computer, browser type and language and your visits to and use of our website, information that you provide for the purposes of corresponding with us and any other information you may choose to send us. In addition, data is collected through cookies. Cookies are small text files that are placed on your computer or mobile device by our website that allow our website to remember your preferences, to help our website work more efficiently and give us data about the use of our website. The list below gives examples of cookies we may use and why:
ASP.NET_SessionId This is a user session cookie that is used to identify the user to the system, it holds an identifier eg. d2tgz51xt44nlmbol4kjqpkg. This cookie expires as the user ends their browser session.
Google Analytics These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. For more information please view an overview of privacy at Google: http://www.google.com/analytics/learn/privacy.html.
Most web browsers allow you to modify your preferences to notify you when a cookie is set, or to reject all cookies. This setting could result in a diminished experience of a website or the website not functioning correctly. You can usually control cookies through your browser settings. To find out more visit: www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites you can visit: http://tools.google.com/dlpage/gaoptout
DATA FROM OTHER SOURCES
From time to time we may receive data about you from a third party. This may happen if you are collecting property from us on behalf of someone else or if we are assisting in the provision of services including (but not limited to) shipping, restoration, insurance or photography. We may collect information from public sources when researching the history and provenance of an artwork. These could include auction catalogues, newspaper articles or other published material. We may also be given your information by a person or organisation who thinks you may be interested in hearing from us or who gives us information in the course of our research into the history or provenance of an artwork.
WHAT PERSONAL DATA DO WE PROCESS AND WHY?
| PURPOSE |
EXAMPLES OF PERSONAL DATA |
LEGAL GROUNDS FOR PROCESSING |
| To provide you with requested services (for example, but not limited to, buying, selling, storage, shipping, restoration, insurance, photography, catalogue subscription, exhibitions and events) |
- Name, title, contact details (including email address(es), postal address(es), telephone numbers)
- Your bank account details (if we need to pay you) or payment card details or bank transfer receipt (if you pay us)
- information related to your attendance of, and interest in, events and art fairs
- Details of the person who has introduced you to us
- Details of artworks you have purchased from us, are interested in or already own
- Details of any services we have provided and of the artwork to which they may relate
- Records of your communications with us
|
Legitimate interests
Fulfilling our legal obligations
|
| To evidence our compliance with legal requirements (for example identity verification, anti-money laundering, payment of taxation and customs duties, anti-discrimination) |
- Your date of birth and identification documents
- Details of your past transactions with us (including any related taxation) and related services (such as shipping, including licences obtained, customs duties paid)
- Any requirements relating to our obligations to meet any specific needs you may have
- Any information relating to a dispute or legal proceeding
|
Compliance with a legal obligation |
| To keep you, our staff and property on our premises secure |
|
Legitimate interests |
| To provide you with details about upcoming exhibitions, events or types of artwork that may interest you |
- Your name, email and postal address(es)
- Your interests and communication preferences
|
Legitimate interests |
| To create and maintain records on art objects to assist with checks on authenticity, provenance and title and to prevent fraud, theft or other unlawful activities |
- Your interest in, possession of, or ownership (historic or current) of any relevant art object or similar object
- Allegations of fraud, theft or other unlawful activities relating to an object connected to you
- Communications with the police, courts, regulators or other government or law enforcement agencies in relation to you or your object(s)
|
Legitimate interests
Public interest
|
| To monitor the performance of our website and improve your user experience |
- Your internet address
- Your browser type and operating system
- the pages you visit on our website
- The data obtained by cookies, web logs, Google Analytics and other similar technologies that monitor the use of our website and optimise the user experience
|
Legitimate interests |
WHO GETS TO SEE YOUR PERSONAL DATA?
Except as expressly set out in this policy we will not sell, distribute or lease your personal information to third parties unless we have your permission or are required to do so by law. The personal information you provide to us may be shared with third party companies, agents, contractors, service providers or affiliated companies if this is necessary to provide you with artworks or services, respond to your inquiries or for any of the purposes described in this policy.
We may also share your personal information with law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE THE EUROPEAN ECONOMIC AREA?
In the course of our normal business we may transfer your personal information to organisations (including for example shippers, restorers or foreign government agencies) who need to process your data in connection with the services we provide to you. Your personal information may be transferred to, and stored at, a destination outside the EEA and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers. Countries outside the EEA offer varying standards for the protection of personal data and your privacy rights, and in some cases these standards are lower than equivalent EEA standards. When we send your personal data outside the EEA, we have in place the EU Commission approved standard contractual clauses in the form of an appropriate data transfer agreement. More details about the typical standard clauses can be found here: https://ec.europa.eu/info/law/law-topic/data-protection_en
HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
We will retain your personal data for six years to satisfy our legal obligations and in the context of our research and records on the history, provenance and authenticity of artworks will retain this information for as long as it is relevant to these pursuits and/or in the public interest.
WHAT STEPS DO WE TAKE TO KEEP YOUR PERSONAL DATA SECURE?
We will take all reasonable and appropriate steps to protect the security and integrity of all personal information provided to us however we cannot guarantee the complete security of personal data held on our systems, nor that that information you supply through the internet or any computer network is entirely safe from unauthorised intrusion, access or manipulation during transmission. Any transmission is at your own risk. We cannot be held liable for any resulting misuse of your personal data.
THIRD PARTY WEBSITES
Priestley & Ferraro's website may contain links to other websites not operated by us. The information you provide to us will not be transmitted to other websites, but these other websites may collect personal information about you in accordance with their own privacy policies. We cannot accept responsibility for the privacy practices or content of these other websites. Please check these policies before submitting any data to these websites.
YOUR RIGHTS AND ACCESS TO YOUR DATA
If you have any questions about the way we process your data you can contact us at any time by emailing gallery@priestleyandferraro.com. We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details or preferences change. We may ask for proof of your identity before providing any information and reserve the right to refuse to provide information requested if identity is not established.
Your specific rights are as follows:
Subject Access Requests
If you are a resident of the EU, you have the legal right to make 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, we are required to provide you with a description and copy of that personal data, and tell you why we are processing it, within one month of the request being made.
Other rights for EU residents
As well as your subject access right, you have the right to request rectification or erasure of personal data or restriction of processing or to object to processing as well as the right to data portability.
Please contact us if you would like to exercise any of your rights explained above in relation to your personal data.
MARKETING
If you have agreed to be contacted for marketing purposes we may use your personal information to send you information about events, art fairs and works of art. You can unsubscribe from receiving them at any time. Details of how to unsubscribe will be included on each electronic mailing we send you. You also have the option of "unsubscribing" from our mailing list at any time thereby disabling any further such e-mail or other communication from being sent to you.
Certain features of our site may allow for social networking. You should ensure when using these features that you do not submit any personal data that you do not want to be sent, collected or used by other users, such as profile details or e-mail address.
We will action any opt out request from you without delay.
COMPLAINTS
If you have any complaints relating to the processing of your personal data, please contact us at gallery@priestleyandferraro.com. You may raise a complaint with the UK Information Commissioner (https://ico.org.uk/ or Tel: 0303 123 1113) or your local regulator if you consider that we have infringed applicable data privacy laws when processing your personal data. This right is without prejudice to any other administrative or judicial remedy you might have.