Last update: September 2023
We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and the Data Protection Act 2018 and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Our Contact Details
Albion Barn / AAS Limited
Data Protection Administrator:
Personal information we collect and hold about you
The type of personal information we collect about you depends on the relationship we have with you.
We may collect and use the following personal information about you:
Visitors to website
Visitors to our galleries
This personal information is required to provide services or items to you or to receive services or items from you. If you do not provide personal information we ask for, it may delay or prevent us from providing or obtaining items and/or services to you.
How your personal information is collected
We collect most of this personal information directly from you in person, by telephone, email and/or via our website. However, we may also collect information:
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Reasons and our lawful grounds|
|Where it is necessary to comply with professional, legal and regulatory obligations that apply to our business, such as tax, money laundering or health and safety regulations.||We will only use your personal data to the extent that we are bound to do so by law or regulations in order that we can comply with that obligation. (legal obligation)|
|Statistical analysis to help manage our business||We have a legitimate interest in understanding statistics behind purchases of artwork or usage of our website in order to be able to provide you with artwork and services that best suit your needs and to improve our services. (legitimate interest)|
|Preventing unauthorised access and modifications to systems/websites||We have a legitimate interest in protecting our systems and our website from unauthorised access modification or other malicious activity. (legitimate interest)|
|Updating and enhancing client and artists records||We are required to ensure we take reasonable steps to keep your personal data up to date. (legal obligation). We ensure we can match you with products and services that you would be most interested in or best suit your needs (legitimate interest)|
|Fulfilling Orders for artwork or services or respond to enquiries prior to a purchase||For us to fulfil any purchases you’ve made from us or any purchase we have made from you or facilitate any future purchases. (necessary for contract)|
|Responding to general enquiries||For us to properly respond to any other enquiries with regards our artwork and services or any special events or art fairs. (legitimate interest/necessary for contract)|
|Facilitate art fairs and events||To let you know about exclusive art fairs or events that are likely to be of interest to you where there is or has been some relationship or contact between us. To administrate, organise and facilitate those events (legitimate interest)|
|Marketing our artworks, artists and services to existing and former clients or potential clients who have previously expressed an interest in our artwork, services or a particular artist||To provide you with details of any of our artwork, services or a particular artist that would be relevant to you and any exclusive offers. (legitimate interest).|
|Audits of our Business||For business management and planning, including accounting and auditing, conducting performance reviews, managing performance and determining performance requirements. (legitimate interest)|
|Recruitment||In order to consider you for roles within our organisation we will need to discuss your application and personal information with relevant employees. Only employees involved within the recruitment process will have access to your information and will keep it secure. If you are not selected for an interview, your personal information will be deleted from our systems within 6 weeks.|
|Business contacts||In order to facilitate any business to business relationships with suppliers or other businesses we will need process personal details of persons within those businesses such as names, email addresses and job titles. (legitimate interest)|
|Artists||In order to facilitate any contractual obligations (necessary for contract) and in order to promote you and your artwork to client’s and potential clients. (legitimate interest)|
|Ownership of artworks||Forgeries are a problem within the artworld. In order to combat this it is important to establish a chain of provenance right back to the artist. We have a legitimate interest to keep details of purchases, artists and owners indefinitely to prevent forgery and preserve the value of the artwork. (legitimate interest)|
We may use your personal information to send you updates by email, post or social media communications about our artwork, a particular artist’s products, services, art fairs and events including exclusive offers, promotions, new artworks and new artists.
We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell it to other organisations outside the Albion Group of Companies for marketing purposes.
We may share your personal information for marketing purposes with third parties but only where we have engaged such third parties to market on our behalf and only in relation to our existing or new artwork, artists, events and art fairs. They will only act upon our strict instructions and we will only allow them to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.
You have the right to opt out of receiving promotional communications at any time by:
Who we share your personal information with
We routinely share personal information with:
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and/or to you. We may also share personal information with external auditors for accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Where your personal information is held
Information may be held at our galleries and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
How long your personal information will be kept
We will keep your personal information while we are providing artwork and services to you. Thereafter, we will keep your personal information for as long as is necessary:
We will not retain your personal information for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of personal information, we keep provenance records or artworks indefinitely to prevent forgeries and preserve the value of artworks. For other personal data we carry out an annual audit to establish what is still necessary. Further details on this are available in our retention schedule which is available upon request by contacting us using our details below.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA):
These transfers are subject to special rules under European and UK data protection law. Our art, artists, galleries, events and art fairs are based around the world including our gallery in the US. The US has different laws surrounding data protection than we do in this country which may not offer the same level of protection as our laws. We therefore only use a marketing platform that has signed up to the Privacy Shield framework offering you the same level of protection as you can expect from us. Further details of this framework can be found at www.privacyshield.gov. If we use any provider who has not signed up to the Privacy Shield framework, we will ensure the transfer of any personal information complies with data protection law and all personal information will be secure. We will either obtain your consent to transfer the personal data or we will use standard data protection contract clauses that have been approved by the European Commission. For further information on whether we have in place any of these clauses and to obtain a copy where relevant,. please contact us using our contact details below.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, for example if you contest the accuracy of the data|
|Data portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
|Not to be subject to automated individual decision making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
If you would like to exercise any of those rights, please:
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
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.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: +44 (0)30 3123 1113.
Changes to this privacy notice
We may change this privacy notice from time to time and we will provide you with details of accessing the privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you.
Our contact details are:
Albion Barn / AAS Limited
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