Rosebery Fine Art Limited (“Roseberys”) are committed to protecting and respecting the privacy of both our personal and corporate clients.
WHO ARE WE?
Our full details are:
Full name of legal entities Rosebery Fine Art Limited (06772322)
Name and title of DPO: Vicki Wonfor, Director
Email Address: firstname.lastname@example.org
Postal Address: 74-76 Knights Hill, London, SE27 0JD
Telephone Number: 020 8761 2522
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data processing issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
For the purpose of the EU General Data Protection Regulation (Regulation (EU) 2016/679 (the “GDPR”), the data controllers are Roseberys and Vertu at Roseberys.
INFORMATION WE MAY COLLECT FROM YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and process different types of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, title, photographic identification, date of birth, and gender.
- Contact Data includes billing address, delivery address, email address, telephone numbers, and website URL.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol address, your login data, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our sites.
- Profile Data includes your purchases or sales made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our services.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from you and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data when you: complete forms on our website roseberys.co.uk (“our site”) and complete our hard copy forms, or by any other means.
- provide information at the time of registering to use our sites, purchasing items through our sites, subscribing to receive email or SMS alerts, or completing an online form on our sites.
- you report a problem with our sites.
- Apply for our services.
- Subscribe to our service or publications.
- Enter a promotion or survey; or
- Give us some feedback.
Third Party Platforms. We receive personal data from third party platforms such as Saleroom, Artsy and Invaluable that you register with to enable you to participate in online sales using their websites or technology.
Automated Decisions. Our assessment of your on line registration may involve an automated decision. The decisions involve the use of systems, such as bank card verification, and are dependent on the information you provide us to produce a result as to whether we are able approve you to bid. If you object to an automated decision then then you can ask that a person reviews it.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:-
- Analytics and search providers such as Facebook based outside the EU;
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
USES MADE OF THE INFORMATION YOU PROVIDE US
We only use your personal data when the law allows us to. Most commonly, we use information held about you in the following ways:
- To carry out our obligations arising from any contracts entered into between you and us.
- To prevent and detect fraud, financial crime and anti-money laundering.
- To supply other third parties with the required information (including credit card details) for the purposes of payment.
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented or otherwise agreed to be contacted for such purposes e.g. through registering to bid with us, or as otherwise provided in this policy.
- If you choose to provide information to us regarding your interests and/or preferences we may send you content based on the information that you have provided to us. We may use the information provided by you to display information about products and services that we believe may be of interest to you. We do not share this information with any other third party.
- To notify you about changes to our service.
Under no circumstances will we pass your details on to third parties for marketing purposes.
- If you register to bid with Roseberys, we may use your data to provide you with information about goods and services supplied by us which may be of interest to you, and we may contact you about these by post, email or by SMS message.
- If you do not wish to receive communication from us you can opt-out of the communication at any time by emailing us at email@example.com.
Change of Purpose
We will only use your personal data 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 incompatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may identify you by using a cookie file which is stored on the hard drive of your computer.
Cookies enable us:
- To estimate our audience size and usage pattern.
- To store information about your preferences, and so allow us to customise our site according to your individual interests.
- To remember your session identification, thereby maintaining your session while you are logged in to our site.
- To store the contents of your shopping basket (“my basket”.)
All of our online transactions are processed securely by our merchant service providers Streamline Merchant Services and SagePay. We do not store your credit/debit card information ourselves. Your credit card number will be encrypted when your order is placed, or you settle an invoice online, using SSL encryption software. Our merchant providers then inform us, via the encryption system, the outcome of that transaction.
DISCLOSURE OF YOUR INFORMATION
We may have to share your personal data with third parties in the following circumstances:
- We may disclose your personal information to any member of Rosebery Fine Art Ltd from time to time. We may disclose your personal information to third parties or to our suppliers, or by law, where necessary.
- In order to prevent and detect fraud, financial crime and anti-money laundering we may check your personal information against databases and share your information with operators of such databases.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Roseberys or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- We require all members of staff and any 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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
By submitting your personal data, you agree to this transfer, storing or processing.
Roseberys ensure all reasonable and appropriate steps are taken to protect the security and integrity of the personal information you provide to us via our sites, or by any other means electronic or otherwise.
We will protect any personal information provided to us by you from being accidentally lost, used or accessed in unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
The security measures we undertake include electronic firewall and other protection procedures involving virus scanning, security patches, vulnerability testing, backup and recovery planning, employee training, security audits and other steps designed to secure your data.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping your password confidential. We will never ask you to disclose your password and we ask you not to share your password with any third party. We cannot be responsible for any loss or damage caused by your negligence, misuse of log-in details or your decision to share account access with others.
THIRD PARTY WEBSITES
Our sites may, from time to time, contain links to and from the websites of auctioneers, industry associations, our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
LENGTH OF STORAGE
We will only retain your personal data for as long as 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 potential 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.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we need from you
We may need to request specific information from you to help us to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.