This policy applies to information held about clients and prospective clients, suppliers and prospective suppliers, contacts, and other persons about whom UPSTONE (trading as Robert Upstone Ltd) holds information. By ‘information,’ we mean personal information about you that we collect, use, share and store.
In this policy, "we", "us", and "our" means Robert Upstone Ltd, a company registered in England and Wales with Number 0810893, registered office 40 Frith Street, London W1D 5LN and "you" means the individual to whom the information relates.
What we collect
How we collect information about you
What we do with the information we gather
We use your information to:
Whether information has to be provided by you, and if so why
The provision of your personal details is required to sell and deliver an art work to you and for us to collect payment. If you do not provide this information we will not be able to perform our contract or enter into our contract with you and you may also be in breach of contract.We also require your personal details in order to send you marketing communications – you are not obliged to provide this information to us for this purpose.
Legal basis for processing
Our processing of your personal information is necessary:
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.
Where required for certain marketing activities we will obtain consent for this.
Where our processing is based on the legitimate interest grounds described above, those legitimate interests are: (i) collecting personal information to provide you with a smooth and efficient client experience; (ii) to make sure you receive updated information on Robert Upstone Ltd's business activities; (iii) to provide the services you have requested; and (iv) for our own marketing and research.
Sharing your information
Except as expressly set out in this policy we will not sell, distribute or lease your personal information to third parties outside our company unless we have your permission or are required by law to do so.
The personal information you provide to us may be shared with third party companies, agents, contractors, service providers or affiliated companies or any buyer or their agent of works you may have consigned to us if this is necessary to provide you with our art work or services, respond to your inquiries or for any of the purposes described in this policy.
We may also share your personal information with:
Transferring Your Information outside Europe
Your personal information may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers. This may be in connection with an art fair or where we use certain offshore service providers, typically for IT and marketing services.
When we, or our permitted third parties, transfer your information outside the European Economic Area, we or they will impose obligations on the recipients of that data to protect your information to the standard required in the European Economic Area or otherwise require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer your information where: (i) the transfer is to a country deemed to provide adequate protection of your information by the European Commission; or (ii) where you have consented to the transfer. In general the safeguards we use to protect your personal information are the European Commission's approved contract clauses, Privacy Shield where applicable and/or ensuring the country is deemed to have adequate protection. Please contact us (details below) if you wish to obtain further information about the safeguards we use for such international data transfers.
At any time, you have the right (which in general is free of charge):
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: email@example.com
Where you are one of our clients or have otherwise provided us contact information for marketing purposes we may use your personal information to send you information by post or email about UPSTONE gallery events, art fairs, works of art and news. You can unsubscribe from receiving such communications at any time; details of how to unsubscribe from marketing emails will be included on each electronic mailing we send you.
You also have the option of "unsubscribing" from our mailing list at any time thereby disabling any further such e-mail and / or other communication from being sent to you by emailing firstname.lastname@example.org.
We will action any opt out request from you without delay.
Where we require your consent in order to send you certain marketing communications we will obtain this.
How long will we keep your information?
We will only keep the information we collect about you for as long as required for the purposes set out above, for provenance/authenticity purposes or in relation to any potential disputes or as required to comply with any legal obligations to which we are subject. This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.
Where we are entitled to send you direct marketing communications we may retain your contact information necessary for this purpose, for as long as you do not unsubscribe from receiving the same from us. If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Links to Other Sites
Certain features of our site may allow for social networking. You should ensure when using these features that you do not submit any personal data that you do not want to be sent, collected or used by other users, such as profile details or e-mail address.
Questions, comments and requests regarding this policy are welcomed and should be addressed to email@example.com. You can also contact us by post at 40 Fritsh Street, London W1D 5LN and by telephone on +44 (0)7950 075 934.
If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner's Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.
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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
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Changes to this policy
Any changes we make to our policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our policy.