PRIVACY POLICY
We are committed to protecting and respecting the privacy of our clients and customers. This policy sets out the basis on which any personal data we collect from you or you provide to us will be processed, shared or transmitted by us when you visit this website or visit any of our galleries or events, or otherwise interact with us.
We are Skarstedt Gallery London Ltd and together with our sister companies Skarstedt Paris SA and Skarstedt New York, we act as Data Controllers, for the purpose of compliance under the Data Protection Act 2018, the Privacy and Electronic Communication (EC Directive) Regulations 2003, the UK General Data Protection Regulation 2021 and the EU General Data Protection Regulation 2018. Skarstedt Gallery London Ltd (ICO registration number ZA851869) is located at Skarstedt, 8 Bennet Street, London, SW1A 1RP. Skarstedt Paris SA is located at 2 Avenue Matignon, 75008 Paris and Skarstedt New York is located at 20 East 79th Street, New York, NY 10075.
Each of the Skarstedt Galleries collects data about its respective visitors and clients in line with this policy. We sometimes share personal information intra-group where it makes sense from an operational perspective to do that. Skarstedt New York manages all personal data collected through our website and in relation to direct marketing.
If you have any questions or comments about this privacy policy, please contact us via: london@skarstedt.com
Data privacy last updated: November 2022
1. What type of information and data do we collect about you?
We may collect and process the following data about you:
1.1 You may provide us with personal information by corresponding with us by phone, e-mail, meeting in person, visiting our galleries or otherwise. We may collect your personal data if you wish us to inform you of the various services we offer relating to your interest in our Skarstedt Galleries, associated exhibition programmes, artists, events and art fairs. The information you may choose to give us could include your name, address, e-mail address, phone number, occupation and details of your interests.
1.2 We may also collect information when you purchase any artwork whether in person when you visit the gallery or an art fair or meet with a member of our gallery staff. The type of information that we may need to collect in this instance could include your name, address, email address, phone number, payment details, passport, driving licence or other identity documents in order to comply with current “know your client” requirements, and other relevant information in order to process the sale and fulfil your request.
1.3 As a visitor to this website, we will collect certain information about use of the website, through the use of analytical cookies (see section on Cookies below).
1.4 If you visit our galleries, we have CCTV in operation in order to protect the security of our buildings, staff and art work. This is clearly signposted, and our use of CCTV is subject to a separate CCTV policy.
2. How do we use your information?
We use information held about you to:
2.1 provide information about our art work and services to you;
2.2 keep you informed about art work, artists and events that we think you may find interesting;
2.3 carry out our obligations arising from any agreements entered into between you and us (e.g. for sale of artwork);
2.4 communicate with you;
2.5 for internal operations, including research and assessing how best we can serve our clients;
2.6 in order to comply with legal and regulatory obligations;
2.7 for security and to check your identity.
3. Legal basis for processing
Our processing of your personal information is necessary because of one of the following reasons:
3.1 so that we can fulfil any agreement with you and in order to take steps at your request prior to you entering into any such agreement;
3.2 for the purposes of legitimate interests pursued by us;
3.3 where you give us specific consent to hold that information; or
3.4 in order to comply with a legal obligation to which we are subject.
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. This specific consent can be withdrawn at any time.
4. When we may disclose your information to others
The personal information you provide to us may be shared intra-group where it is necessary to do so from an operational perspective. It may also be shared with third party companies, agents, contractors, service providers or affiliated companies 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. Typically, these entities will act as “data processors” of your data, and only use your data in accordance with our instructions. 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.
We may also share your personal information with: law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and other business entities should we plan to merge with or be acquired by that business entity (or sell certain assets of the business), or if we undergo a re-organisation with any acquiring entity.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
Your data may be shared between the London and Paris galleries. Both galleries are subject to either the UK or the EU General Data Protection Regulation in respect of the way that they look after your data. Should we need to share your data with our sister companies in the US for a specific reason, we would ensure any transfer was compliant with the UK and EU’s data protection laws.
5. Security
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 and on our internal systems.
6. Data Retention: How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
In some circumstances you can ask us to delete your data: (see below for further information).
In some circumstances we may 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.
7. Your rights
We will comply with our legal obligations as regards your rights as a data subject. You have the right under data protection laws in certain circumstances to:
• Request access to your personal data (a "data subject access request").
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data.
• 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.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party.
We will comply with our legal obligations as regards your rights as a data subject. For more information on these rights and when they apply is available here:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
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 by emailing us at: london@skarstedt.com.
8. Email Marketing
Where you have agreed to be contacted for marketing we may use your personal information to send you information by email about Skarstedt Gallery events, art fairs and works of art. You can unsubscribe from receiving these emails at any time, (details of how to unsubscribe 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 or other communication from being sent to you by emailing london@skarstedt.com. We will action any opt out request from you without delay.
9. Links to other websites
Our website may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Please check these policies before you submit any personal data to these websites.
10. Complaints and contact details
Questions, comments and requests regarding this policy are welcomed and should be addressed to london@skarstedt.com or paris@skarstedt.com.
If you have any concerns about our use of your information we would welcome the opportunity to deal with these directly - you also have the right to make a complaint to the local regulatory authority. These are as follows:
In the UK: the Information Commissioner's Office, via their helpline on +44 (303) 123 1113 or website www.ico.org.uk
In France: Commission Nationale de l'Informatique et des Libertés via their website www.cnil or their phone number +33 (0)1.53.73.22.22
11. How we use cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. The file is a tool that is commonly used on websites to help website operators analyse web traffic and user activity.
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 our users’ 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 other information about you, other than as described above.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.
12. Changes to our privacy policy
Any changes we may make to our privacy 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 privacy policy.
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ADA COMPLIANCE
Skarstedt Gallery, Ltd. is committed to making this website available to as many people as possible and is engaged in continued efforts to ensure that this website is accessible to those with special needs, including those with visual, hearing, cognitive and motor impairments. Our efforts in that regard are ongoing. Many internet users can find websites difficult to use. We recognize that this is an important issue, and we are working to ensure that this website is accessible to all persons who wish to use it. Our efforts to improve this website in this regard are in process, so if you come across a page or feature you find inaccessible or difficult to use, please send your feedback to: jamie@skarstedt.com.