This policy applies to information held about clients and prospective clients, suppliers and prospective suppliers, artists, contacts and all other persons about whom Entwistle 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 L&R Entwistle & Co Limited, a company registered in England and Wales with No 1341812, registered office 40 Queen Anne Street, London, W1G 9EL and “you” means the individual to whom the information relates.
Email communications
Entwistle adheres to the following policy in relation to the deployment of email communications:
- All emails sent to you by Entwistle will clearly identify Entwistle as the sender.
- The subject line of any email sent by Entwistle will always accurately describe the subject matter of the email.
- All emails sent to you by Entwistle will include an option to unsubscribe from future email messages.
- You may unsubscribe from ALL Entwistle mailing lists.
- All promotional emails sent to you by Entwistle will clearly show by the character of and information within either the body or the footer that the email is a promotional message (mailshot).
- All emails sent to you by Entwistle will include our physical postal address.
- Entwistle sends emails to customers and prospects in both plain text and HTML email formats. Emails are sent using sender email info@entwistlegallery.com
- Entwistle will not use third-party companies to send emails on its behalf. If you receive an email which claims to come from Entwistle which does not use this domain, or if you are suspicious that an email may not be an approved Entwistle email communication, then please send a copy of the email to info@entwistlegallery.com so we can investigate.
Web beacons
Entwistle uses web beacons to track whether recipients of its marketing communications have opened the HTML email. When the email is opened a part of the code that makes up the HTML page calls a web server to load the web beacon which then generates a record showing that the email has been viewed. Web beacons can also be used to record anonymous user information such as IP address, email software, browser type, time/date stamp in addition to personally identifiable information such as the recipients email address. If you do not wish to receive web beacons you will need to set your email client to disable HTML images or refuse HTML emails. You can learn more about web beacons.
What we collect
- your name;
- your contact information such as your address, email address and telephone number;
- If relevant, your payment details / financial data i.e. your bank name, account number and sort code;
- when browsing our site, your IP address, your browser type and language;
- information related to your attendance of, and interest in, Entwistle events, art works, artists and art fairs;
- information about you that you give us in person at our events and art fairs, by filling in forms on our site www.entwistlegallery.com (our site) (e.g. the contact us section or to sign up to our mailing list) or by corresponding with us by phone, e-mail or otherwise; and
- information in relation to your purchase of our art work or use of our services.
How we collect information about you
- collecting information you give to us when you purchase any art work or visit us at each art fair or visit at our Galleries;
- your use of the forms on our website
- In addition to asking you to submit personal information, we may collect information about you automatically when you connect to our website by using cookies.
What we do with the information we gather
We use your information to:
- provide information about our art work and services to you;
- keep you informed about art work, artists and events that we think you may find interesting;
- carry out our obligations arising from any agreements entered into between you and us;
- communicate with you;
- administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- keep our site safe and secure;
- comply with legal and regulatory obligations; and
- for security and to check your identity.
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:
- for the performance of contracts to which you will be a party to and in order to take steps at your request prior to you entering into those contracts;
- for the purposes of legitimate interests pursued by us; or
- 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.
Legitimate interests
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 Entwistle'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 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 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:
- 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 if we undergo a re-organisation with that entity.
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.
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.
Your Rights
At any time, you have the right:
- to request access to or a copy of any personal data which we hold about you;
- to rectification of your personal data, if you consider that the information we are holding is inaccurate;
- to ask us to delete your personal data, if you consider that we do not have the right to hold it;
- to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- to ask us to stop or start sending you marketing messages as described below in the marketing section;
- to restrict processing of your personal data;
- to data portability (moving some of your personal data elsewhere) in certain circumstances;
- to object to your personal data being processed in certain circumstances; and
- to not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
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 info@entwistlegallery.com.
Marketing
Where you are one of our clients or have otherwise agreed to be contacted for marketing we may use your personal information to send you updates about and invitations to Entwistle exhibitions and art fairs. You can unsubscribe from receiving them 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 info@entwistlegallery.com.
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 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 permitted 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.
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.
Links to Other Sites
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. Once you link to another website from our website you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before you submit any data to these websites.
Certain features of our site will 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.
Complaints
Questions, comments and requests regarding this policy are welcomed and should be addressed to info@entwistlegallery.com.
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.
How we use cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.
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.
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. This may prevent you from taking full advantage of the website.
You can read more about our use of cookies on our website: www.entwistlegallery.com/cookie-policy
Notification of changes
This privacy policy is compliant with the GDPR directive approved by the EU Parliament on 14 April 2016 and was last updated on 21 May 2018. We reserve the right to amend or vary this policy at any time and the revised policy will apply from the date posted on the Site. You accept that by doing this, Entwistle has provided you with sufficient notice of the amendment or variation.
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.