PRIVACY AND COOKIES POLICY
Effective Date: 8 November 2023
Welcome to the ARTconnects privacy and cookies policy.
ARTconnects respects your privacy and is committed to protecting your personal data. This policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you when you visit our website (regardless of where you visit it from), enter into a contractual relationship with us, contact us, or purchase our products and services.
1. Important information and who we are
Purpose of this policy
This policy aims to give you information on how ARTconnects collects and processes your personal data through your use of this website (including any data you may provide through this website when you submit a contact request, sign up to receive email updates from us, or purchase a product or service) or as otherwise provided to us (including as part of a contractual relationship with you).
This website is not intended for children, and we do not knowingly collect data relating to children.
SBZ Creative Media Limited is the controller and responsible for your personal data (collectively referred to as "ARTconnects", "we", "us" or "our" in this policy).
If you have any questions about this policy, including any requests to exercise your legal rights as set out in Section 9 of this policy, please contact us using the details set out below.
If you have any questions about this policy or our privacy or cookie practices, please contact us in the following ways:
Full name of legal entity: SBZ Creative Media Limited
Email address: firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection 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.
Changes to the policy and your duty to inform us of changes
We keep this policy under regular review. This version was last updated on the Effective Date as set out at the beginning of this policy. If we make any changes, we will notify you by posting the revised policy on this page and by revising the Effective Date. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about 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 transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or other similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, products, and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may 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) where you have given your explicit consent for us to do so.
We do not collect any information about criminal convictions and offences.
If you fail to provide personal 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 products or services). In this case, we may have to cancel a product or service you have ordered from us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
purchase our products or services;
give us feedback or contact us; or
request email updates to be sent to you.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you. This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Where we need to comply with a legal obligation. This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Where you have given us your consent to the processing your personal data. Where consent has been specified as the legal basis for processing your personal data, you have the right to withdraw your consent at any time by contacting us.
Purposes for which we will use your personal data
We process your personal data for the purposes set out in this policy only where we have a valid legal basis for doing so under applicable data protection law. The legal basis will depend on the purpose for which we process your personal data.
We will use your personal data for the following purposes as is necessary for the performance of our contract with you, or to answer questions or take steps at your request prior to entering a contract with you:
to register you as a new customer;
to process your order and payment for our products and services, including managing payments, fees and charges and collecting and recovering money owed to us;
to provide you with the products and services, manage our relationship with you and provide you with customer support;
to verify your identity, investigate and prevent fraudulent activities and other illegal activities;
to provide personal information to third parties as set out in this policy;
to process your personal data as is necessary as part of and in conjunction with the services provided by you to us under a contract.
We use your personal data for the following purposes as is necessary for our legitimate interests, or where you have given your consent to such processing to the extent required by applicable law:
to provide you offers and recommendations and to tailor and enhance your experience on our website;
to notify you of any new or changed products or services and to communicate with you about products or services that may be of interest to you;
to confirm, update and improve our records, and to analyse and develop our relationship with you;
to deal with enquiries and complaints made by or about you relating to our products and services;
to seek your views or comments on our products and services;
to pseudonymise your personal data where you have requested that we do so. This means, for example, replacing your name or other personal data with a pseudonym;
for any specific processing purposes for which you have provided your consent under a separate contract between you and us; and
to (i) comply with legal obligations; (ii) respond to requests from the ICO and other competent authorities; (iii) protect our interests; (iv) protect our rights, safety, or property, and/or that of our partners, you, or others; and (v) enforce or defend our legal rights.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
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 compatible 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 us.
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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in Section 4 above.
Service providers acting as processors based who provide IT and system administration services and payment processing services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in who provide consultancy, banking, legal, insurance and accounting services.
Third parties to whom it is necessary to share your personal data as specified under a contract between you and us or to whom you have consented to us sharing your personal data.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Where we transfer your personal data outside of the UK, we ensure that a similar degree of protection is afforded to it by ensuring that (i) we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, or (ii) we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an 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.
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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting, or other requirements.
In some circumstances you can ask us to delete your data. See Section 9 below for further information.
In some circumstances we will 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful, but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at the details set out in Section 1.
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 could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
Strictly necessary or Essential cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings, but you may then not be able to access all or parts of our website.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting or Marketing cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. [We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Our site also uses the following third party cookies for the purposes set out in the below table. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies, or essential cookies if they relate to security:
Managing your cookie preferences
You can choose which analytical, functionality and targeting cookies we can set, or you can also choose to "Decline All" cookies in the cookie banner or by visiting our [Cookie Preference Centre]. You can also choose to deactivate the use of third party advertising cookies on the same page.
However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
 Cookie Preference Centre to be hyperlinked once the page has been set up. Please amend the name of the page as relevant.