LAST UPDATED: 9 August 2018
A. WHO ARE WE?
This website at ArtOrigo.com (the “Website”) is owned and operated by GT Art Consulting Ltd.
GT Art Consulting Ltd, with registered office at Kemp House, 152 City Road, London, EC1V 2NX (United Kingdom), company number 0879221, is the data controller of the personal information collected on this Website.
“Personal Information” is information about you which can be used alone, or combined with other information, to identify you personally.
C. HOW, WHEN AND WHY DO WE COLLECT AND USE PERSONAL INFORMATION?
1. Information that we collect
The types of information that we may collect from you, depending on how you use our Websites include:
a. your name;
b. your email address;
c. your address (business and personal);
d. your landline and mobile telephone numbers (business and personal);
e. any other information that you choose to provide to us when filling out a contact form on our Websites;
f. your geographic location (country/territory where you are living and/or working);
g. your job title, role and the name of your employer;
h. if you are a Seller, also certain information relating to your business, such as Years in business, Estimated inventory size, Average item price, types of items sold, associations in which you are a member,
2. How we use your Personal Information
a) Website registration and provision of our services through the Website – we collect your Personal Information to let you register to the Website, in compliance with our terms and conditions, and provide you with the services/products offered from time to time on the Website;
b) Contact Forms - we may collect your Personal Information, which you choose to provide when you fill in forms on our Websites, including the information set out in a.-e. above. We may use this Personal Information to respond to your queries, and/or provide the services and/or information that you have requested.
c) Mailing List - if you choose to subscribe to our Mailing List, we use Personal Information that you provide during the subscription process to send you our updates and marketing messages. Your agreement to the use of your Personal Information for these purposes is optional. If you decide not to subscribe to our Mailing List, we will not send you the relevant communications, but your use of our Website will remain otherwise unaffected.
d) Marketing – where you have provided us with your contact details, we may contact you by telephone or by post for marketing purposes relating to our services, our Website, and/or to research opinion on proposed legal or business developments where legally permitted to do so, unless you let us know that you do not want to receive this type of marketing. We will only contact you for these marketing purposes by electronic means (email or SMS) where you have agreed to this. Your agreement to the use of your Personal Information for these purposes is optional and if you fail to provide your agreement, your visit to and use of the Website will not be affected.
e) Our Business Purposes - we may also use your Personal Information for our business purposes such as:
- record keeping, statistical analysis, internal reporting and research purposes;
- to ensure network and information security;
- to notify you about changes to our services;
- to investigate any complaint, you make;
- to provide evidence in any dispute or anticipated dispute between you and us;
- to customize various aspects of our Websites to improve your experience;
- to host, maintain and otherwise support the operation of our Websites;
- for the detection and prevention of fraud and other criminal offences and for risk management purposes;
- for business and disaster recovery (e.g. to create back-ups);
- for document retention/storage;
- for database management;
- to protect the rights, property, and/or safety of our organization, its personnel and others; and
- to ensure the quality of the services we provide to our users.
f) Other - in addition, we may use your Personal Information to comply with legal obligation to which we are subject and for further specific purposes made clear at the point of collection on particular pages of our Websites.
If you choose not to provide Personal Information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information. Aside from this, your visit to our Website will remain unaffected.
3. Legal grounds for collection and use of Personal Information
We ask for your consent to process your Personal Information in relation to our Mailing List and for marketing purposes (paragraph 2 points c and d above), where this is made clear to you at the point where you provide your information (Art. 6, paragraph 1, letter a) of the Regulation (EU) 2016/679, the General Data Protection Regulation –GDPR);
In other cases, we process your personal information where we need to do so:
- to provide you with the service and perform a contract to which you are party or to take steps at you request prior to entering into a contract (Section C, Paragraph 2 Points a and b above, Art. 6, paragraph 1, letter a) of the,GDPR);
- to comply with our legal and regulatory obligations (Section C, Paragraph 2 Paragraph 2 points e and f above, Art. 6, paragraph 1, letter b) of the,GDPR);
- for our legitimate interests (Art. 6, paragraph 1, letter e) of the,GDPR) in: (i) responding to your queries (Section C, Paragraph 2 Paragraph 2 point b above); (ii) providing services and/or information to you where we do not have a contract (Section C, Paragraph 2 Paragraph 2, point a above); (iii) our internal business purposes, as set out in Section C, Paragraph 2 Paragraph 2. Point e above.
You can object to processing based on our legitimate interests at any time by contacting us as specified in Section J below. See also “Your Rights – The right to object”, Section I below. We consider that the risk to your data protection rights in connection with Personal Information that we process on the basis of our legitimate interests is not excessive or overly intrusive. We have also put in place protections for your rights by ensuring proper retention periods and security controls.
If you would like to find out more about the legal grounds on which we process your Personal Information for a particular purpose you can contact us as specified in Section J below..
5. Information from other sources
Where permissible under applicable local laws, we may combine information that you have provided to us with other information that we already hold about you and which we have collected for a compatible purpose.
D. HOW AND WHEN DO WE SHARE INFORMATION WITH THIRD PARTIES?
Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your Personal Information is adequately protected.
1. Google Analytics
This Website uses Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics works using cookies.
Google Analytics cookies collect your IP address, however because IP anonymisation is used on this Website, your IP address will be shortened (and therefore anonymised) as soon as technically possible and before it is stored or otherwise used in connection with Google Analytics.
The anonymisation process takes place within the European Union or the European Economic Area, except in exceptional cases, where your full IP address may be sent to a Google server in the U.S.A. and shortened there.
We use the information collected by Google Analytics cookies to find out about how visitors use our Website.
The IP address sent by your browser in connection with Google Analytics will not be combined by Google, with other data.
You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
2. Sharing to Service Providers
The Personal Information you provide on the Website is collected by GT Art Consulting Ltd..
3. Sharing with other third parties
We may also provide your information to other third parties such as regulators and law enforcement agencies, where we are required by law to do so, where necessary for the purposes of preventing and detecting fraud, other criminal offences and/or to ensure network and information security.
When you "like" or "follow" us on Facebook, Instagram, Pinterest, Twitter, Tumbler or other social media sites, we may collect your information. This information may include your name, e-mail address, and any comments or content you post relevant to us. We may also collect your information if you sign up for one of our promotions or submit information to us through Facebook, Pinterest, Instagram, Twitter, Tumbler or another social media site. These links may include the use of so-called "share links." A "share link" is a button and/or text link appearing on our websites that launches a sharing mechanism that allows you to post links to, and content from, our websites or application onto other websites.
E. INTERNATIONAL TRANSFERS
The transfer of your Personal Information to our third-party service providers may involve your Personal Information being sent outside of the EEA, to locations that may not provide the same level of protection as those where you first provided the information.
However, we will only transfer your Personal Information outside of the EEA:
• where the transfer is to a place that is regarded by the European Commission as providing adequate protection for your Personal Information; or
• where we have put in place appropriate safeguards, for example by using a contract for the transfer which contains specific data protection provisions that have been adopted by the European Commission or a relevant data protection authority. You can request a copy of these contracts by contacting us at: firstname.lastname@example.org; or
• where you have consented to this, or there is another legal basis on which we are entitled to make the transfer.
F. HOW LONG DO WE STORE PERSONAL INFORMATION?
We employ appropriate security measures to help protect your Personal Information and guard against access by unauthorised persons. Information storage is on secure computers in a locked and certified information centre and information is encrypted wherever possible. We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. However, as the transmission of information via the Internet is not completely secure we cannot guarantee the security of your information transmitted to our Website.
I. YOUR RIGHTS
The following section explains your rights. The various rights are not absolute, and each is subject to certain exceptions or qualifications. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under data protection laws. Nothing in this Privacy Notice is intended to provide you with rights beyond or in addition to your rights as a data subject under data protection laws.
What does this mean?
1.The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Information and your rights. This is why we are providing you with the information in this Privacy Notice.
2. The right of access
You have the right to obtain a copy of your Personal Information (if we are processing it), and other certain other information (similar to that provided in this Privacy Notice) about how it is used.
This is so you are aware and can check that we are using your information in accordance with data protection law.
We can refuse to provide information where to do so may reveal Personal Information about another person or would otherwise negatively impact another person's rights.
3. The right to rectification
You can ask us to take reasonable measures to correct your Personal Information if it is inaccurate or incomplete. E.g. if we have the wrong name or address for you.
4. The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Information where there’s no compelling reason for us to keep using it or its use is unlawful. This is not a general right to erasure; there are exceptions, e.g. where we need to use your Personal Information in defence of a legal claim.
5. The right to restrict processing
You have rights to ‘block’ or suppress further use of your Personal Information when we are assessing a request for rectification or as an alternative to erasure. When processing is restricted, we can still store your Personal Information, but may not use it further. We keep lists of people who have asked for further use of their Personal Information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability
You have rights to obtain and reuse certain Personal Information for your own purposes across different organisations.
7. The right to object
You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by us or by a third party. We will be allowed to continue to process your Personal Information if we can demonstrate “compelling legitimate grounds for the processing which override your interests, rights and freedoms” or we need this for the establishment, exercise or defence of legal claims.
J. HOW TO CONTACT US
If you have any questions about our privacy or security practices you can contact us:
(a) By post, using the postal address (GT Art Consulting Ltd., d/b/a/ ArtOrigo.com: 483 Green Lanes, London N13 4BS, United Kingdom)
(b) Click on "Contact us" on www.artorigo.com
(c) By email, using email@example.com
If we need, or are required, to contact you concerning any event that involves your personal information we may do so by email, telephone, or mail.