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Birmingham West Midlands, B3 2BJ Brighton East Sussex, BN1 1HN Cambridge
Cambridgeshire, CB2 1TB Cheltenham Gloucestershire, GL50 1NB Chelsea London, SW3
4PW Cobham Surrey, KT11 2LR Covent Garden London, WC2E 9PA Edinburgh Scotland,
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PRIVACY POLICY

How to use this Privacy Notice

There is a Glossary of terms at the end of this document to help you understand
the meaning of some of the terms used in this Privacy Notice.

Table of Contents

 1.  Introduction
 2.  Who we are
 3.  Companies and websites in scope
 4.  How to contact us
 5.  Personal Data we collect about you
 6.  How we get your Personal Data
 7.  How we use your Personal Data
 8.  UK GDPR/EU GDPR Lawful Basis table 
 9.  Using your Personal Data for other reasons
 10. Sharing your Personal Data with others
 11. Marketing and advertising
 12. Promotional Events – Photography and Filming
 13. Sharing your Personal Data overseas
 14. Third-party websites, plugins and services links to other websites
 15. Use by children
 16. Cookies
 17. How long we keep your personal data
 18. How we keep your Personal Data Safe

 

1.    Introduction

Please read this Privacy Notice and any other privacy notice or fair processing
notice we may provide on specific occasions carefully, as it is meant to help
you understand what information we collect, why we collect it, and how you can
update, manage, export and delete your information.

This Privacy Notice supplements the other notices and is not intended to
override them.

We do not and will not sell your data to third parties.

 

2.    Who we are

DeMontfort Fine Art Limited, trading as DeMontfort Fine Art Ltd, Clarendon Fine
Art, Whitewall Galleries and Atelier Galleries.

DeMontfort Fine Art Ltd is the data controller for all the organisations within
the group that are covered by the scope of this Privacy Notice and are
registered with the ICO under registration number Z6531915. This means that
DeMontfort Fine Art Ltd determines what data is collected by each organisation
within the group, how this data is going to be used and how this data is
protected.

 3. Companies and websites within scope

The following companies and websites are within scope for this privacy notice:

Company

Website

DeMontfort Fine Art Ltd

www.demontfortfineart.co.uk

Clarendon Fine Art

www.clarendonfineart.com

Whitewall Galleries

www.whitewallgalleries.com

Atelier Galleries

www.ateliergalleries.co.uk

It includes personal data that is collected in gallery and through our websites,
by telephone, through online chat services and through any related social media
applications.

 

 4. How to Contact us

If you have questions about this Privacy Notice or the processing of your
Personal Data, please contact us at:

Postal address, you can write to:

Privacy Department

DeMontfort Fine Art Ltd, DeMontfort House, Europa Way, Lichfield, Staffordshire,
WS14 9NW

Or via email at privacy@dmfa.co.uk

 

 5. Personal Data we collect about you

We may collect, use, store and transfer different kinds of Personal Data about
you depending on our relationship with you:

Identity data 

Includes title, first name, last name, other names, date of birth, age or email
address, information in support of proof of identification and proof of address.
This may include the processing of official documents such as passports, driving
licences, ID Cards.

Contact data

Includes your contact address, billing address, email address or telephone
number(s).

Location data

We may collect your location data from your IP address or telephone area codes.

Loyalty Data

We may collect proof of purchase, invoice number, personal and Company billing
addresses or trade account numbers.

Transaction data 

Includes notes on your interactions and conversations with us and on any orders
or agreements that you establish with us. Includes details about payments to and
from you and other details of art, products, and services you have purchased
from us.

Technical data

Includes IP address, your login information, time zone setting and location,
browser plugin types and versions, operating system and platform, and other
technology on the devices you use to access our websites.

Profile data

Includes your email and password, Information about your art interests,

the services you have used on our website, your use of social media functions on
our websites for authentication, feedback, survey responses and such information
as you provide to us.

·         contact details that you provide to us, including name, residential
address, date of birth, telephone number, email address, postal address if
different to residential.

·         information about your art interests.

·         notes on your interactions and conversations with us.

·         notes on any orders or agreements that you establish with us.

·         information collected from other source.

Usage data 

Includes information about how you use our websites, the resources you access,
pages you visit, the time and date of your visit or an email opened, the time
spent on those pages, unique device identifiers, the URL (Uniform Resource
Locator) clickstream to, through and from our websites and other diagnostic
data.

Marketing and communications data

Includes your preferences in receiving marketing from us and our third parties
and your communication preferences and records of our correspondence with you.

 We may use various technologies, to collect the above information from your
interaction with emails we send you. This enables us to focus our marketing,
leading to more relevant emails to our subscribers. It also helps us to identify
subscribers that are not engaged with our marketing emails, enabling us to
remove them from our send lists. For more information about the tracking pixels
please see our Cookie Notice.

Aggregated Data

We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data could be derived from your
Personal Data but is not considered Personal Data in law as this data
will not directly or indirectly reveal your identity.

However, if we combine or connect Aggregated Data with your Personal Data so
that it can directly or indirectly identify you, we treat the combined data as
Personal Data, which will be used in accordance with this Privacy Notice.

Special

Category Personal Data

No special category data is collected by us under this privacy notice.

 

 

 6. How we get your Personal Data

We may use different methods to collect data from and about you through our
partner websites, website, website forms, by telephone, and through any related
social media applications, including but not limited to LinkedIn, Facebook and X
(Twitter).

Personal Data provided directly by you

You may give us your Personal Data by placing an order, filling in forms,
surveys, questionnaires, or assessments on our websites, by corresponding with
us by post, phone, email or otherwise. This includes Personal Data you provide
when you:

·         register to use our websites or purchase our art, or to receive
general, marketing or commercial information

·         submitting contact forms

·         start or complete a survey and/or questionnaire

·         enter a promotion or survey

·         give us feedback

Data we collect when you use our Websites

Each time you interact with our websites, we will automatically collect Personal
Data, including technical data about your device, your browsing actions and
patterns, content and usage data. We collect this data using Cookies, server
logs and other similar technologies like pixels, tags and other identifiers in
order to remember your preferences, to understand how our Websites are used, and
to customise our marketing offerings and to continually improve customer
journeys.

Please see our Cookies Notice or further details.

Information we receive from third parties

We may receive Personal Data about you from various third parties, such as
contact, financial, technical data and device data from parties including:

·         analytics providers such as Google Analytics

·         social Media Advertising networks including but not limited to
WhatsApp, Linkedin, X (Twitter), Tiktok Google, Facebook and Instagram.

·         providers of Fraud prevention tools

·         address lookups

Information we receive from public sources

Identity and contact data from publicly available sources such as the UK
Companies House and the electoral register inside the UK. Publicly available
data sources are used for postcode and address data for delivery, as well in the
prevention of fraud.

 

 

 7. How we use your Personal Data

We need your Personal Data to conduct our business and provide you with our art
products and services. Most commonly we will use your Personal Data in the
following circumstances:

 * Where you have consented before the processing.
 * Where we need to perform a contract, we are about to enter or have entered
   with you.
 * Where it is necessary for our legitimate interests (or those of a third
   party) and your interests and fundamental rights do not override those
   interests.
 * Where we need to comply with a legal or regulatory obligation.

 

 8. UK GDPR/EU GDPR Lawful Basis Table 

The table below describes the ways we plan to use your Personal Data, and which
Lawful Basis we rely on to do so. We have also identified what our legitimate
interests are where appropriate.

For more information on the Lawful Basis, we use to process your data under the
UK GDPR and EU GDPR, see our Lawful Basis table below or contact us.

Lawful Basis Table

LAWFUL BASIS

PURPOSE EXAMPLES

Contractual

We use your Personal Data on the basis that it is necessary for us to provide
our services and products to you.

When you sell or purchase a product or service, you are entering into a contract
with us.

Onboarding - when you register as a new client or supplier.

·         we may use your personal, contact, technical, profile and marketing
and communication data.

Delivery - in order to be able to deliver our art products and services or
receive products and services in physical or digital form.

To provide you with information, art products or services that you requested
from us and to notify you about changes to our products and/or services.

The fulfilment and distribution of physical and digital art to our users.

·         we use your personal, contact, technical, profile and marketing and
communication data to deliver our art and/or related services to you.

Account administration - when we administer accounts, take, or receive payment,
deal with any transaction, respond to queries, refund requests and complaints.

When we collect and recover money owed to us

·         we use Identity Data, Contact Data, Loyalty Data, Payment Data,
Transaction Data to administer accounts.

Relationship management - to manage our relationship with you, which may
include:

 * notifying you of changes to our terms or Privacy Notice;
 * notifying you of changes to, any product or service processing, delivering
   your art products and/or services and incentives.
 * processing orders
 * asking you to leave a review or take a survey.

We use Identity Data, Contact Data, Location Data, Transaction Data, Profile
Data, Marketing and Communications Data to manage our relationship with you.

Communication - to be able to contact you regarding updates or informative
communications related to our events, artist updates and new releases that are
likely to be relevant and/or of interest to you.

Handling the information, you submit to us enables us to respond effectively. We
may also keep a record of these queries to inform any future communications
between us and to demonstrate how we communicated with you throughout our
contractual relationship.

·         we use Identity Data, Contact Data, Transaction Data, Profile Data,
Marketing and Communications Data to help us to communicate with you.

Legitimate interest

Our legitimate business interests do not automatically override your interests –
we will not use your Personal Data for activities where our interests are
overridden by the impact on you unless we have your consent or are otherwise
required or permitted to by law.

Managing our business - we hold Personal Data for our own legitimate business
interest. This relates to us managing our business to enable us securely to
provide our service/products:

·         when we respond to your queries and complaints, where you are not a
user, client or supplier, or a potential client, user or supplier.

·         when we monitor trends so we can improve our services websites.

·         in the context of a business reorganisation or group restructuring
exercise.

We may use your use Identity Data, Contact Data, Transaction Data, Profile Data,
Marketing and Communications Data to help us to manage our business.

It is necessary to process this personal data for our legitimate interests for
running our business, provision of administration, network security, to prevent
fraud, and in the context of a business reorganisation or group restructuring
exercise.

Provide and maintain websites - It is in our legitimate interests to process
personal data for our legitimate interests for running our business, provision
of administration and IT services, network security and

·         to prevent fraud.

·         to provide and maintain our websites, including to monitor the usage
of these, troubleshooting, data analysis and system testing necessary for our
legitimate interests (for running our business, provision of administration and
IT services, network security) and to limit our business, cyber and legal risk.

·         to ensure that our website content is presented in the most effective
manner to clients, which is in our legitimate interest to keep users and clients
engaged in our website and services to help towards the growth of our business.

The personal data we use to provide and maintain websites includes Identity
Data, Contact Data, Location Data, Technical Data, Transaction Data, Profile
Data, Usage Data, Loyalty Data, Marketing and communications data, and
Aggregated data.

Recommendations and marketing - It is in our legitimate interests to use
marketing to grow our business and ensure commercial viability by marketing to
and we use personal data to:

·         to measure and analyse the effectiveness of the advertising we serve
you.

·         to ensure that our marketing is tailored to your interests and to keep
our records up to date and to provide you with marketing as allowed by law.

·         to make suggestions and recommendations to you about art, artists or
events that may be of interest to you and necessary for our legitimate interests
(to develop our art products/services and grow our business).

We use personal data from existing clients for these purposes and this data
includes Identity Data, Contact Data, Location Data, Technical Data, Transaction
Data, Profile Data, Usage Data, Loyalty Data, Marketing and Communications Data.

Security - it is in our legitimate interests to process personal data securely
to maintain network security and:

·         to prevent fraud when users are transacting on our website,

·         to ensure our websites and systems are secure. to prevent financial
and reputational loss to our business.

Reviews - when we capture client reviews, for example when you buy art from us,
we may follow it up with an enquiry about your experience of the service to help
us gauge customer satisfaction.

·         it is in our legitimate interests to ensure our survival in a
competitive market by ensuring that our services and art are market appropriate
and delivered satisfactorily to our clients and users.

Valuations – we use your transactional data in order to provide any future
valuations required for insurance purposes.

We use Identity Data, Contact Data, Transaction, Marketing and Communications
Data, to be able to properly communicate and respond to reviews.

Research and analysis - for statistical analysis, so that we can monitor and
improve services and websites or develop new ones and we may also aggregate
personal data for these purposes.

·         it is necessary to us and in our legitimate interests (to study how
customers use our websites, to develop them, to grow our business and to inform
our marketing strategy).

We use Identity Data, Contact Data, Location Data, Loyalty Data, Technical Data,
Payment Data, Transaction Data, Profile Data, Candidate Data, Marketing and
Communications Data, and Usage Data for research and statistical analysis the
type of personal data we use depends on the nature of the research and analysis.

Data analytics - we use data analytics to improve our Websites,
products/services, marketing, customer relationships and experiences.

·         data Analytics are necessary to our business and in our legitimate
interests to define types of customers for our art products and services, to
study how customers use our Websites and services so we are able to develop our
products and services and keep our website updated and relevant. We need this
information to develop our business and to inform our marketing strategy to
ensure the growth of our business.

We may use Location Data, Technical Data, Payment Data, Transaction
Data, Profile Data, and Usage Data for data analytics.

Rights and claims - it is in our legitimate interests to use personal data,
where it is necessary,

·         to enforce or apply our website terms of use, our policy terms and
conditions, or other contracts.

·         to exercise our rights, to defend ourselves from claims and to keep to
laws and regulations that apply to us and the third parties we work with.

Necessary for our legitimate interests (for running our business, provision of
administration services, network security, to prevent fraud.

We may use Identity Data, Contact Data, Location Data, Loyalty Data, Technical
Data, Payment Data, Transaction Data, Profile Data, Marketing and Communications
Data, Aggregated Data, Usage Data for these purposes.

Legal obligations

We may use your Personal Data to comply with laws (for example, if we are
required to co-operate with a police investigation after a court order orders us
to).

Legal requirement - the processing is necessary for compliance with our legal
obligations, such as but not limited to security requirements and accounting
requirements.

·         to comply with applicable law, for example in response to a request
from a court or regulatory body, where such request is made in accordance with
the law.

We may use Identity Data, Contact Data, Location Data, Loyalty Data, Technical
Data, Payment Data, Transaction Data, Profile Data, Marketing and Communications
Data, Aggregated Data, Usage Data for these purposes.

Data subject rights - verifying your identity when you exercise your data
subject rights.

·         fulfilling data subject rights requests.

We may use Identity Data, Contact Data, Location Data, Loyalty Data, Technical
Data, Payment Data, Transaction Data, Profile Data, Marketing and Communications
Data, Aggregated Data, Usage Data for these purposes, dependent on the Data
Subject request itself.

Criminal activity - to detect fraudulent or criminal activity, we may share
information with forces such as the police and the national crime agency.

We may use Identity Data, Contact Data, Location Data, Loyalty Data, Technical
Data, Payment Data, Transaction Data, Profile Data, Marketing and Communications
Data, Usage Data for these purposes.

Consent

We may have to get your consent to use your Personal Data, such as when we
collect and use Special Category Personal Data about you or when we have want to
email you for marketing purposes etc.

We will get your consent before sending third-party direct marketing
communications to you via email or text message or before processing any
Personal Data relating to your health. You have the right to withdraw consent to
marketing at any time by contacting us.

Wherever consent is the only reason for using your Personal Data, you have the
right to change your mind and/or withdraw your consent at any time by clicking
the Unsubscribe button at the bottom of an applicable email or using our contact
us form.

Marketing -

·         for marketing our art and services like email marketing newsletters
generally.

·         to deliver content and advertisements to you.

·         to measure and analyse the effectiveness of the advertising we serve
you.

·         to monitor trends so we can improve our websites,

·         to facilitate visitors’, use of the Websites, we may collect IP
addresses and store Cookies on visitors’ devices.

·         Sending third-party direct marketing communications to you via email,
letters or phone calls. 

We may use Identity Data, Contact Data, Location Data, Technical Data, Marketing
and Communications Data for these purposes.

Location - when you use our website, you may allow us to obtain your precise
location from your device. We use this information to deliver personalised
content and for analytics.

We may use Location Data, Technical Data, Payment Data, and Usage Data for these
purposes.

 

 

 9. Using your Personal Data for other reasons

We will only use your personal information for the purposes for which we
collected it, unless we reasonably consider that we need to use it for another
reason and that reason is compatible with the original purpose.

If we need to use your personal information for an unrelated purpose, we will
notify you and we will explain the Lawful Basis that allows us to do so.

 

 10. Sharing your Personal Data with others

We will, in some circumstances and where the law allows, share your data with
third parties, we require all third parties to respect the security of your
Personal Data and to treat it in accordance with the law.

We do not allow our third-party service providers to use your Personal Data for
their own purposes. We only permit them to process your Personal Data for
specified purposes and in accordance with our instructions.

We ensure that the personal data being supplied is also limited with the minimum
being used for each of the services provided by the third-party service
providers.

We may share your personal information with the following organisations that
help us manage our business and deliver our products, applications, or services,
or where we are legally obliged to share information, including with:

 * HMRC as our Anti Money Laundering supervisor and with law enforcement
   officials or other authorities as required by law.
 * third parties we use to help us run our business such as our bank, marketing
   agencies website hosts, IT support system providers, contractors and our
   telephony system provider.
 * third-party service provider to assist us with client insight analytics and
   track page views such as Google Analytics we may send the 3rd party Page
   Information (URL, Title), Browser Information (Browser name, Viewport or
   Viewing pane, Screen resolution, Java enabled, Flash version), User
   Information (Location - IP address, Language).
 * third-party platforms to manage and deliver customer relationship management.
 * external auditors, e.g., in relation to the audit of our accounts, in which
   case the recipient of the information will be bound by confidentiality
   obligations;
 * professional advisors (such as lawyers and other advisors), in which case the
   recipient of the information will be bound by confidentiality obligations;
 * law enforcement agencies, courts, tribunals and regulatory bodies to comply
   with our legal and regulatory obligations; or
 * other parties in connection with a significant corporate transaction or
   restructuring, including a merger, acquisition, asset sale, initial public
   offering or in the event of our insolvency—usually, information will be
   anonymised, but this may not always be possible, however, the recipient of
   the information will be bound by confidentiality obligations.
 * we may share your personal information with our, third party service provider
   who use credit reference agencies, electoral role and fraud prevention
   agencies to help prevent money laundering and financial crime if required to
   by law.
 * we may share personal information with our interest free credit providers,
   couriers and/or our artwork insurance providers and only then if you have
   opted to use these services.

 

 11. Marketing and advertising

We may use your information to provide you with details about art works, new
launches, events and services.

Where we are legally required to obtain your consent to provide you with certain
marketing materials, we will only provide you with such marketing materials
where we have obtained such consent from you.

You can opt out of us using your personal information for marketing purposes by
following the unsubscribe link included in each marketing email or by contacting
us by emailing privacy@dmfa.co.uk

 

 12. Promotional Events – Photography and Filming

At times we may capture photographic images or record video footage at
promotional events.

By confirming your attendance at any events, you are consenting to your image
being captured.

These images and footage and maybe published through any of the following
channels:

 * press and media (including newspapers, magazines, websites and social media).
 * on our websites.
 * on our social media feeds including but not limited to X (Twitter), Facebook,
   YouTube, Instagram and LinkedIn.
 * in printed publicity literature such as leaflets, broachers, posters or other
   display materials.

Consent for Children under the age of 18 will require a consent from an
appropriate guardian.

Display signs will be present at events informing you, if you wish for your
image not to be captured please raise with the event organiser.

Any data captured will be stored securely and kept in line with our data
retention policy.

You can opt out of us using your personal information by contacting us by
emailing privacy@dmfa.co.uk.

 

 13. Sharing your Personal Data overseas

Please note that we may send personal information outside of the country
generally for, but not limited to, reasons relating to processing and storage by
our service providers.

When we do this, we will ensure it has an appropriate level of protection and
the transfer is made in line with Data Protection Law. Often, this protection is
set out under a contract with the organisation that receives that information.
You can find more details of the protection given to your information when it is
transferred overseas by emailing privacy@dmfa.co.uk

 

 14. Third-party websites, plugins and services links to other websites

You should be aware that information about your use of the websites (including
your IP address) may be retained by your ISP (Internet Service Provider), the
hosting provider and any third party that has access to your Internet traffic.

Our websites may contain links to third-party websites and plugins, for instance
a social media login plugin. If you choose to use these websites, plugins, or
services, you may disclose your information to those third parties. 

We are not responsible for the content or practices of those websites, plugins,
or services. The collection use and disclosure of your Personal Data will be
subject to the privacy notices of these third parties and not this Privacy
Notice. We urge you to read the privacy and Cookie Notices of the relevant third
parties.

For more information on how Google uses your personal data and on site activity
to create more relevant advertising, please click here: Google’s Privacy &
Terms.

 

 15. Use by children

We do not target children, and our websites and art are not intended to attract
children.

If a parent or guardian notifies us, or it is discovered by other means, that a
minor under the age of 18 has provided their Personal Data to us, we will
promptly delete the minor’s Personal Data that is in our possession.

 

 16. Cookies

We use Cookies and similar technologies like pixels, tags, and other identifiers
to remember your preferences, to understand how our Websites are used, and to
customise our marketing offerings.
 

 17. How long we keep your personal data

We will keep your Personal Data in line with our data retention policy for no
longer than is necessary to fulfil the purposes we collected it for, including
for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the
amount, nature and sensitivity of the Personal Data, the risk of harm from
unauthorised use or disclosure of your Personal Data, the purposes for which we
process your Personal Data and whether we can achieve those purposes through
other means, and the applicable legal requirements. When personal data is no
longer required, all reasonable steps will be taken to erase or otherwise
dispose of it without delay.

 

 18. How we keep your Personal Data safe

We have put in place appropriate security measures to prevent your Personal Data
from being accidentally lost, used, or accessed in an unauthorised way, altered
or disclosed. We will notify you and any applicable regulator of a suspected
data security breach where we are legally required to do so. In addition, we
limit access to your Personal Data to those employees, agents, contractors and
other third parties that 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.

Unfortunately, the transmission of information via the Internet is not
completely secure. Although we will do our best to protect your Personal Data,
we do not have any control over what happens between your device and the
boundary of our information infrastructure. You should be aware of the many
Information Security Risks that exist and take appropriate steps to safeguard
your own information.

If you want detailed information from Get Safe Online on how to protect your
information and your computers and devices against fraud, identity theft,
viruses and many other online problems, please visit www.getsafeonline.org. Get
Safe Online is supported by HM Government and leading businesses.

 

 19. Your rights as a data subject

As a data subject whose personal information we hold, you have certain rights.
If you wish to exercise any of these rights, please email privacy@dmfa.co.uk or
use the information supplied in the ‘Contact us’ section. To process your
request, we will ask you to provide two valid forms of identification for
verification purposes.

Table of your rights

YOUR RIGHT

DETAILS

Right to be informed

We have a legal obligation to provide you with concise, transparent,
intelligible, and easily accessible information about your personal information
and our use of it. We have written this Privacy Notice to do just that, but if
you have any questions or require more specific information, you can contact us.

Right of access

You have the right to ask us for copies of your personal information. This right
always applies. There are some exemptions, which means you may not always
receive all the information. When you request this data, this is known as making
a data subject access request (DSAR). In most cases, this will be free of
charge; however, in some limited circumstances, for example repeated requests
for further copies, we may apply an administration fee.

Right to rectification

You have the right to ask us to rectify information you think is inaccurate. You
also have the right to ask us to complete information you think is incomplete.
This right always applies.

Right to erasure

You have the right to ask us to erase your personal information in certain
circumstances. We have the right to refuse to comply with a request for erasure
if we are processing the Personal Data for one of the following reasons:

·         to exercise the right of freedom of expression and information.

·         to comply with a legal obligation.

·         to perform a task in the public interest or exercise official
authority.

·         for archiving purposes in the public interest, scientific research,
historical research or statistical purposes.

·         for the exercise or defence of legal claims.

Right to restriction of processing

You may ask us to stop processing your Personal Data. We will still hold the
data but will not process it any further. This right is an alternative to the
right to erasure. If one of the following conditions applies, you may exercise
the right to restrict processing:

·         the accuracy of the Personal Data is contested.

·         processing of the Personal Data is unlawful.

·         we no longer need the Personal Data for processing, but the Personal
Data is required for part of a legal process.

·         the right to object has been exercised and processing is restricted
pending a decision on the status of the processing.

Right to object to processing

You have the right to object to processing in certain circumstances. You can
also object if the processing is for a task carried out in the public interest,
the exercise of official authority vested in you, or your legitimate interests
(or those of a third party).

Right to data portability

This right only applies if we are processing information based on your consent
or for the performance of a contract and the processing is automated.

You may also find it helpful to refer to the guidance from the UK’s Information
Commissioner on your rights under the UK GDPR.

 

 20. How to exercise your rights

If you would like to exercise any of those rights, please use email DeMontfort
on privacy@dmfa.co.uk

You can call or write to us — see ‘4. How to contact us’.

When contacting us please:

 * provide enough information to identify yourself (e.g., your full name,
   address and customer or matter reference number) and any additional identity
   information we may reasonably request from you, and
 * let us know which right(s) you want to exercise and the information to which
   your request relates

In most circumstances, you do not need to pay any charge for exercising your
rights. We have one month to respond to you.

 

 21. How you can complain to or about us

We hope that we can resolve any query or concern you raise about our use of your
information. Please contact us first and title your email “Complaint”. All
complaints will be treated in a confidential manner, and we will try our best to
deal with your concerns. We are committed to manage complaints promptly,
effectively and fairly.

Should you feel unsatisfied with our handling of your data, or about any
complaint that you have made to us about our handling of your data, you are
entitled to escalate your complaint to a supervisory authority within the EU.
For the UK, this is the ICO (Information Commissioners Office), which is also
our lead supervisory authority. Its contact information can be found
at https://ico.org.uk/global/contact-us/.

 

 22. Changes to privacy policy

We may change this privacy notice from time to time. When we do, we will inform
you by posting the updated versions on our websites and summarising key
amendments.

We have a separate employee privacy notice which describes how we collect and
use personal information about our staff in relation to their employment, which
can be obtained from human resources department.

  

Glossary

Aggregated Data

means data that can be compiled from numeric or non-numeric data.

The data is collected and summarised for the purpose of statistical analysis or
reporting. It is limited to recognising general trends due to the non-specific
nature of the information.

It could be derived from your personal data but is not considered personal
data in law as this data will not directly or indirectly reveal your identity.

Anonymisation

means a type of information sanitisation whose intent is privacy protection. It
is the process of removing personally identifiable information from data sets,
so that the people whom the data describe remain anonymous.

In order to be truly anonymised under the UK GDPR and EU GDPR, the personal data
must be stripped of sufficient elements that mean the individual can no longer
be identified. However, if you could at any point use any reasonably available
means to re-identify the individuals to which the data refers, that data will
not have been effectively anonymised but will have merely been pseudonymised and
subject to data protection law.

For more information visit the ICO website

Consent

he UK GDPR. and EU GDPR. sets a high standard for consent, consent should be
given by a clear affirmative act establishing a freely given, specific,
informed, and unambiguous indication of the data subject’s agreement to the
processing of personal data relating to him or her, such as by a written
statement, including by electronic means, or an oral statement.

Controller

means the natural or legal person, public authority, agency or any other entity
or person who alone or jointly with others determines the purposes and means of
the processing of personal data.

Our entry as a Controller on the ICO’s Data protection register can be found on
the ICO website https://ico.org.uk/





Cookies

means a small file of letters and numbers that is stored on a browser or the
hard drive of a computer. Cookies contain information that is transferred to a
computer’s hard drive.

Controllers must have users’ informed consent before storing cookies or similar
technologies on a user’s device and/or tracking them.

For more information, please read our Cookie Notice.

The ICO provides information about
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DPA 2018

UK Data Protection Act 2018

Data Protection Act 2018 (legislation.gov.uk)

                                         

Data Protection Law

means all applicable data protection and privacy legislation in force from time
to time including the UK GDPR and the EU GDPR, the Electronic Communications
Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and
Electronic Communications Regulations 2003 (SI 2003 No. 2426) as amended, and
any other legislation relating to personal data and all other legislation and
regulatory requirements in force from time to time that apply to the use of
personal data.

Encryption

is the process that scrambles readable text so it can only be read by the person
who has the secret code, or decryption key. It helps provide data security for
sensitive information.

                                                     

EU GDPR

means the Regulation (EU) 2016/679 of the European Parliament and of the Council
of 27 April 2016 on the protection of natural persons with regard to the
processing of personal data and on the free movement of such data and repealing
the Directive.

ICO

means the Information Commissioner’s Office, the UK’s independent authority set
up to uphold information rights in the public interest, promoting openness by
public bodies and data privacy for individuals.

Information Security Risks

comprises the impacts on individuals or organisations that could occur due to
the threats and vulnerabilities associated with the operation and use of
information systems and the environments in which those systems operate.

Lawful Basis

under the EU GDPR and the UK GDPR, you must have a valid lawful basis to process
personal data.

Lawful Basis of processing personal data

There are six lawful bases for processing personal data available:

(a) Consent: the individual has given clear consent to the processing of their
personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract, or because specific
steps have been taken before entering into a contract.

(c) Legal obligation: the processing is necessary for compliance with the law
(not including contractual obligations).

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for you to perform a task in the
public interest or for your official functions, and the task or function has a
clear basis in law.

(f) Legitimate interests: the processing is necessary for an organisation’s
legitimate interests or the legitimate interests of a third party, unless there
is a good reason to protect the individual’s personal data that overrides those
legitimate interests. (This cannot apply if an organisation is a public
authority processing data to perform its official tasks.)

Special category data 

Special category data is personal data that needs more protection because it is
sensitive.

                                                             

Personal Data

this is also referred to as “personal information” and it means any information
relating to an identified or identifiable natural person (‘data subject’); an
identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person.

Personal Data Breach           

means a breach of security leading to the accidental or unlawful destruction,
loss, alteration, unauthorised disclosure of, or access to, personal data
transmitted, stored, or otherwise processed.

Privacy Notice

(also sometimes called a privacy policy or fair processing notice) is a public
document from an organisation that explains how that organisation processes
personal data and how it applies data protection principles under Articles 12,
13 and 14 of the EU GDPR and the UK GDPR.

Processor

means a natural or legal person, public authority, agency, or other body which
processes personal data on behalf of the controller. Processors act on behalf of
the relevant controller and under their authority. In doing so, they serve the
controller’s interests rather than their own.

Special Category Personal Data

some of the personal data that organisations process is more sensitive and needs
higher protection. Under the GDPR, this is known as ‘special categories of
personal data’, and includes information about a person’s:

 * race
 * ethnicity
 * political views
 * religion, spiritual or philosophical beliefs
 * biometric data for ID purposes
 * health data
 * sex life data
 * sexual orientation
 * genetic data

Special Category Personal Data Conditions for Processing

the conditions for processing special category data:

(a) Explicit consent
(b) Employment, social security and social protection (if authorised by law)
(c) Vital interests
(d) Not-for-profit bodies
(e) Made public by the data subject
(f) Legal claims or judicial acts
(g) Reasons of substantial public interest (with a basis in law)
(h) Health or social care (with a basis in law)
(i) Public health (with a basis in law)
(j) Archiving, research and statistics (with a basis in law)

                                   

Supervisory Authorities

means the data protection authority tasked with supervising GDPR compliance in
each member state of the European Union.

Tracking Pixels

a tracking pixel is an HTML code snippet which is loaded when a user visits a
website or opens an email. It is useful for gathering information about
visitors on a website—how they browse, what type of ads they click on, etc.

                                                          

UK GDPR

means the GDPR as transposed into United Kingdom national law by operation of
section 3 of the European Union (Withdrawal) Act 2018, together with the DPA
2018, the Data Protection, Privacy and Electronic Communications (Amendments
etc) (EU

Exit) Regulations 2019, and other data protection or privacy legislation in
force from time to time in the United Kingdom.

Websites

means:

www.demontfortfineart.co.uk

www.clarendonfineart.com

www.whitewallgalleries.com

www.ateliergalleries.co.uk

including all subdomains thereof, present and future.

Clarendon Fine Art
Europa Way, Lichfield WS14 9NW
United Kingdom

01543 624990

clientservices@clarendonfineart.com

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