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:
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:
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:
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:
Under no circumstances will we pass your details on to third parties for marketing purposes.
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:
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:
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:
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:
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.