This policy applies to information held about clients and prospective clients, suppliers and prospective suppliers, artists, contacts and all other persons about whom Hamiltons Galleries Ltd. [Hamiltons Gallery / “the gallery”] holds information. By ‘information,’ we mean personal information about you that we collect, use, selectively share and store when you:
- Use this website;
- Engage with the gallery’s employees in person, by phone, by email or by post;
- Consent to receive our email marketing announcements or newsletters;
- Consent to be emailed about artwork of interest; or
- Engage in trade directly or indirectly with the gallery.
In this policy, “we,” ,”the gallery,” “us,” and “our” means Hamiltons Galleries Limited (trading as Hamiltons Gallery), a company registered in England and Wales with No 01333111 registered office 13 Carlos Place, London, W1K 2EU, United Kingdom and “you” means the individual or business to whom the information relates.
Hamiltons Gallery is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website or communicating with gallery staff, then you can be assured that it will only be used in accordance with this privacy statement.
What we collect:
- Your name;
- Your contact information such as your address, email address and telephone number;
- Your proof of identification or, in the case of businesses, certificate of incorporation or other registration documents;
- 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, Hamiltons Gallery events and art fairs;
- Information about you that you give us in person at our events and art fairs, by filling in forms on our website (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 purchases or use of our services.
What we do with the information we gather:
We require this information to understand your needs and provide you with a better service as well as to engage in trade. We gather this information in particular for the following reasons:
- Internal record keeping;
- To meet financial and accounting requirements;
- To improve our exhibitions, works of art and services;
- To communicate with you regarding updates about the gallery, news about our artists, upcoming projects and exhibitions, etc. We may periodically send promotional emails about new exhibitions, works of art, special offers or other information which we think you may find interesting using the contact details which you have provided;
- To contact you for market research purposes. We may use the information to customise the website according to your interests;
- To transfer necessary information to third parties including but not limited to shippers, framers or other suppliers with whom we work to complete our services;
- For security and to check your identity using a leading AML compliance service; and
- To abide by UK and EU law.
Hamiltons Galleries Ltd. keeps this information and all information relevant to past sales processes for legal and financial records but endeavours to keep actively used information up to date.
If you choose to limit specific personal or business data, this may impact Hamiltons Gallery’s ability to adequately provide its services to you;
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 (for example, under the terms of the anti-money laundering regulation effective from 10 January 2020 we are required to keep a record of any Customer Due Diligence information we obtain on customers for a period of five years from the completion date of the transaction).
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 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 effective client experience; (ii) to make sure you receive updated information on Hamiltons Gallery’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 artwork 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 the UK and Europe:
Your personal information may be transferred to, and stored at, a destination outside the United Kingdom (UK) and may also be processed by staff operating outside the UK who work for us, or for one of our service providers.
When we, or our permitted third parties, transfer your information outside the UK, we or they will endeavour to encourage reasonable protection of your data. 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 UK government; or (ii) where you have consented to the transfer.
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 to 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: firstname.lastname@example.org
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 information about events, art fairs and works of art. 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 email@example.com.
We will action any opt out request from you without delay.
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.
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.
Links to Other Sites:
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.
Questions, comments and requests regarding this policy are welcomed and should be addressed to firstname.lastname@example.org
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.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. 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.
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.
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. This policy is effective from 31 July 2020.