This privacy policy describes how Elliott Fine Art Ltd (which we refer to as “Elliott Fine Art”, “us”, “we”, and “our”), a company registered in England and Wales with No. 09955790, collects, uses, shares and stores personal information about clients, prospective clients, suppliers, prospective suppliers and contacts. Personal information is any data which can identify an individual, which would include your name, postal address and email address. We are the data controller and we operate our website www.elliottfineart.co.uk (our site).
Please read this policy carefully and contact us if you have any queries by emailing us at: will@elliottfineart.co.uk
or by writing to:
Elliott Fine Art Ltd
7 Wey Court Road
Guildford
GU1 4QU
United Kingdom
This privacy policy may change from time to time so we recommend that you review it periodically. This version of the privacy policy was last updated on 14/04/2021.
2. WHO THIS PRIVACY POLICY APPLIES TO
This privacy policy applies to all persons whose personal information we collect and use (except as set out below). This includes individuals in the categories below or who work for any the following:
• our clients
• people who are involved in contracts and transactions we are working on
• our business contacts; and
• service providers and suppliers.
For example, general office services, library services and IT service providers. This policy does not apply to our employees, as the way we collect and use their personal information is governed by the privacy policy in our employee handbook.
3. INFORMATION WE COLLECT ABOUT YOU
• We may collect and store the following types of information about you when you visit our site or by corresponding with us (for example, by e-mail).
This includes information you provide when registering to use our sites or sharing any data via our social media functions. The information given to us may include:
• your name;
• your contact information such as your address, email address and telephone number;
• your payment details / financial data i.e. your bank name, account number and sort code;
• when browsing our site, your IP address, your browser type and language;
• information related to your attendance of, and interest in events and art and antiques fairs;
• information about you that you give us in person at our events and at fairs, by filling in forms on our site (our site) (e.g. when signing up to our mailing list) or by corresponding with us by phone, e-mail or otherwise; and
• information in relation to your purchase of our artwork, antiques or use of our services.
4. HOW WE COLLECT INFORMATION ABOUT YOU
You may give us your information by filling in forms on our site or by corresponding with us by post, phone, email, on social media or otherwise. This includes information you provide when you:
• visit us at art and antiques fairs or at our gallery;
• your purchase of any artwork or antique.
5. LEGAL BASIS FOR PROCESSING
Our processing of your personal information is necessary
(i) for the purposes of legitimate interests;
(ii) in order to comply with a legal obligation to which we are subject; or
(iii) for the performance of contracts to which you will be a party to and in order to take steps at your request prior to you entering into those contracts. In relation to any processing of special categories of personal data, we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information.
Legitimate interests
Where our processing is based on the legitimate interest grounds described above, those legitimate interests are:
• collecting personal information to provide you with a smooth and efficient client experience;
• running our business;
• to make sure you receive updated information on Elliott Fine Art's activities and inventory;
• to provide the services you have requested; and
• for our own marketing, research and development.
6. HOW WE USE AND DISCLOSE YOUR PERSONAL INFORMATION
We may collect, use and disclose your personal information in order for us to provide our services as a seller and buyer of legally acquired objects of historical & cultural interest. This includes:
(a) providing sale and purchase related services
(b) complying with our legal obligations or making disclosures to government, regulatory or other public bodies where in our reasonable opinion the disclosure is appropriate and permitted by law. This includes:
• disclosures required by law or court order;
• disclosures to the police, tax authorities, NCA (the National Crime Agency) or other public or government authorities where in our reasonable opinion the disclosure is required in relation to any criminal investigation or prosecution; and
• disclosures to a government, public or regulatory authority, including any data protection authority where in our reasonable opinion the disclosure is required or permitted by law.
(c) providing access to our files for audit, review or other quality assurance checks by regulators, auditors, professional advisers and certification bodies.
(d) the day to day operations of our business. For this, we may use third party service providers. For example IT service providers and shipping contractors.
(e) the use of cookies by the Elliott Fine Art website. The terms under which the Elliott Fine Art website uses cookies are set out under clause 12 of this privacy policy.
(f) providing information to our insurers.
(g) to provide you with information about goods, services and events we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you or which were the subject of a previous purchase or negotiations of a purchase from you. If you are a new customer, we will contact you by electronic means only if you have consented to this by expressly opting in on the Elliott Fine Art website or have provided us with your contact details and consent in communications, whether than be email, phone or in person.
Your personal information may be transferred outside the European Economic Area (the EEA). For example, this may be in relation to an international transaction, or where we are sharing information with our colleagues or third party service providers who operate outside of the EEA. We only transfer your personal information outside of the EEA where we are satisfied that the transfer is in accordance with applicable data protection and privacy laws. As a growing seller and purchaser of objects of historical and cultural interest, we may share personal information with potential investors and other parties in relation to any actual or proposed reorganisation, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion or our business, or assets, but we will only do so once appropriate confidentiality agreements are in place.
(h) administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
(i) for security and to check your identity
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 by law to do so.
7. WHERE YOU PROVIDE US WITH PERSONAL INFORMATION ABOUT ANOTHER PERSON
If you give us personal information about another person, you should ensure that:
(a) you are legally entitled to give us that information;
(b) the disclosure is in accordance with any applicable data protection or privacy law; and(c) such other person has also read this privacy policy.
8. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We take reasonable steps to ensure that the personal information we hold about you is reliable for its intended use and as accurate and complete as is necessary to carry out the relevant purposes described in this privacy policy. We will retain your personal information for so long as is reasonably necessary for us to fulfil the relevant purposes described in this privacy policy, unless a longer retention period is required or permitted by law.
9. HOW WE PROTECT YOUR PERSONAL INFORMATION
We are strongly committed to data security and we take reasonable and appropriate steps to protect your personal information from unauthorised access, loss, misuse, alteration or corruption. We have put in place physical, electronic, and managerial procedures to safeguard and secure the information you provide to us.
10. UPDATING YOUR PERSONAL INFORMATION
At any time, you have the right:
• to request access to or a copy of any personal data which we hold about you;
• to rectification of your personal data, if you consider that the information we are holding is inaccurate;
• to ask us to erase your personal data, if you consider that we do not have the right to hold it;
• to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
• to ask us to stop or start sending you marketing messages as described below in the marketing section;
• to restrict processing of your personal data;
• to data portability (moving some of your personal data elsewhere) in certain circumstances;
• to object to your personal data being processed in certain circumstances; and
• to not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject. 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 change at the following email address will@elliottfineart.co.uk.
or by writing to us at:
Elliott Fine Art Ltd
7 Wey Court Road
Guildford
GU1 4QU
United Kingdom
11. MARKETING
Where you are one of our clients or have otherwise agreed to be contacted for marketing we may use your personal information to send you information about our artwork, antiques, events, and art and antiques fairs. You can stop receiving marketing messages from us at any time by clicking the ‘Unsubscribe’ link at the bottom of any email 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 by emailing will@elliottfineart.co.uk. We will action any opt out request from you without delay.
12. COOKIE POLICY
This cookie policy ("Policy") describes what cookies are and how and they're being used by the elliottfineart.co.uk website ("Website" or "Service") and any of its related products and services (collectively, "Services"). This Policy is a legally binding agreement between you ("User", "you" or "your") and this Website operator ("Operator", "we", "us" or "our"). You should read this Policy so you can understand the types of cookies we use, the information we collect using cookies and how that information is used. It also describes the choices available to you regarding accepting or declining the use of cookies. For further information on how we use, store and keep your personal data secure, see our privacy policy.
What are cookies?
Cookies are small pieces of data stored in text files that are saved on your computer or other devices when websites are loaded in a browser. They are widely used to remember you and your preferences, either for a single visit (through a "session cookie") or for multiple repeat visits (using a "persistent cookie").
Session cookies are temporary cookies that are used during the course of your visit to the Website, and they expire when you close the web browser.
Persistent cookies are used to remember your preferences within our Website and remain on your desktop or mobile device even after you close your browser or restart your computer. They ensure a consistent and efficient experience for you while visiting the Website and Services.
Cookies may be set by the Website ("first-party cookies"), or by third parties, such as those who serve content or provide advertising or analytics services on the Website ("third party cookies"). These third parties can recognize you when you visit our website and also when you visit certain other websites.
What type of cookies do we use?
Necessary cookies
Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our Website and using its features. For example, these cookies let us recognise that you have created an account and have logged into that account to access the content.
Functionality cookies
Functionality cookies let us operate the Website and Services in accordance with the choices you make. For example, we will recognise your username and remember how you customised the Website and Services during future visits.
Analytical cookies
These cookies enable us and third party services to collect aggregated data for statistical purposes on how our visitors use the Website. These cookies do not contain personal information such as names and email addresses and are used to help us improve your user experience of the Website.
What are your cookie options?
If you don't like the idea of cookies or certain types of cookies, you can change your browser's settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit internetcookies.org
Changes and amendments
We reserve the right to modify this Policy or its terms relating to the Website and Services at any time, effective upon posting of an updated version of this Policy on the Website. When we do, we will revise the updated date at the bottom of this page. Continued use of the Website and Services after any such changes shall constitute your consent to such changes.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorised to access or use the Website and Services.
Contacting Us
If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to our use of cookies, you may send an email to will@elliottfineart.co.uk or write a letter to:
Elliott Fine Art Ltd
7 Wey Court Road
Guildford
GU1 4QU
United Kingdom