Lawful basis for processing including basis of legitimate interest
Legitimate Interests Reason (because of a contract we have entered into with our customer or supplier and it is in our legitimate interests to perform that contract)
Legitimate Interests Reason (because of a contract we have entered into with our customer and it is in our legitimate interests to perform that contract and to recover any debts due to us)
Legal Obligations Reason
Legitimate Interests Reason (to keep our records updated and to study how customers use our products/services)
Legitimate Interests Reason (because of a contract we have entered into with our supplier and it is in our legitimate interests to perform that contract)
Legitimate Interests Reason (because of a contract we have entered into with our customer or supplier and it is in our legitimate interests to perform that contract)
Legitimate Interests Reason (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Legal Obligations Reason
Legitimate Interests Reason (to study how customers or subscribers use our products/services or marketing communications, to develop them, to grow our business and to inform our marketing strategy)
Legitimate Interests Reason (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Legitimate Interests Reason (to develop our products/services and grow our business)
To register you (or our customer) as a new customer or supplier
To process and deliver your (or our customer’s) order including:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us
To manage our relationship with you (or our customer or supplier) which will include:
(a) Notifying you about changes to our terms or privacy notice.
(b) Asking you to leave a review or take a survey
To manage our relationship with suppliers, including to pay our suppliers and to administer our contract with them.
In certain circumstances, to put our suppliers and customers in touch with one another to fulfil certain terms of the contract we have with them.
To administer and protect our business and our website (including data analysis, testing, system maintenance,
To deliver relevant content to you and measure or understand the effectiveness of the marketing communications we send to you
To use data analytics to improve products/services, marketing, customer relationships and experiences.
To market to you and make suggestions and recommendations to you about goods or services that may be of interest to you (or the organisation which you are representing).
PRIVACY NOTICE (ARTELIER ARTS LIMITED) INTRODUCTION
Artelier Arts Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when we correspond with you, deal with you as a customer, supplier or business contact, when you visit our website (regardless of where you visit it from) or when you receive our newsletter and it tells you about your privacy rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Artelier Arts Limited collects and processes your personal data through your interactions with us, through any use of our website, including any data you may provide through our website or otherwise when you contact us and when you sign up to our newsletter or purchase a product or service.
Our website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Artelier Arts Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).
We have appointed a data protection manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (explained in paragraph 9 below) please contact the data protection manager using the details set out below.
Our full details are:
Full name of legal entity: Artelier Arts Limited
Name of data protection manager: David Knowles
Email address: firstname.lastname@example.org
Postal address: 77 Stokes Croft, Bristol, United Kingdom, BS1 3RD
Telephone number: +44(0)117 905 9882
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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 PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 22 June 2018.
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.
Our website and newsletters may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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 follows:
Identity Data includes first name, maiden name, last name, title, employer or organisation for which you work and job title.
Contact Data includes address(s), email address(es) and telephone numbers (including mobile and landline numbers).
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us or which you have enquired about including copies of correspondence between us and copies of any contracts or other agreements entered into.
Profile Data includes your username and password, purchases or orders made by you (including details of portfolios, proposals or projects prepared for you), your interests, preferences and feedback.
Usage Data includes information about how you interact with our marketing communications.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication
The types of personal information we collect may differ from person to person depending on who you are and the relationship between us and you. For instance, the types of personal data that we collect about clients will be different to the types of personal data that we collect about subscribers to our newsletters or about our suppliers or about our business contacts.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of a marketing communication which we send to you. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any 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). Nor do we 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 (or an organisation which you represent) 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 (or the organisation which you represent) (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with 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, Contact, Financial and Transaction Data by filling in forms or by corresponding with us by post, phone, email, on our website or otherwise. This includes personal data you provide when you:
apply for our products or services;
create or are assigned an account on our website;
subscribe to our service or publications;
request marketing to be sent to you; or
give us some feedback.
Third parties or publicly available sources. We may receive or access personal data about you from various third parties and public sources as set out below:
Usage Data from analytics providers such as MailChimp based outside of the EU;
Transaction Data from providers of delivery services.
Identity and Contact Data from publicly available sources such as via websites, magazines, articles and other publicly available sources.
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:
For the performance of a contract which means we need to process 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 (“Contract Reason”).
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 Interests Reason”). This means the legitimate interest of our business in conducting and managing our business to enable us to give our clients 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).
Where we need to comply with a legal or regulatory obligation which means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to (“Legal Obligations Reason”).
In very limited circumstances, we may rely on your consent (“Consent Reason”). We may rely on this for sending direct marketing communications to you, including in particular if we want to pass your details on to third parties to send direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us on the details set out at the beginning of this notice or by following the unsubscribe/opt-out link in any marketing message which we send to you. If we do want to rely on your consent, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details set out at the beginning of this privacy notice if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
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, Usage and Profile 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 goods or services from us and, in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from us if you have requested them from us, provided your consent to receive them or if we are contacting your company/organisation in relation to our products and services.
We will get your express opt-in consent before we share your personal data with any other third party company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out or unsubscribe links on any marketing message sent to you or by contacting us on the details set out at the beginning of this notice 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, product/service experience or other transactions between us.
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 using the details set out at the beginning of this notice.
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 have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
External Third Parties including:
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs and other authorities acting as processors or joint controllers based in the United Kingdom.
Freelancers and consultants acting as processers based in the United Kingdom.
Suppliers who usually act as processors and may be based worldwide.
Customers who act as processors or controllers and may be based worldwide.
Email marketing platforms (such as Mailchimp) acting as processors based outside of the European Economic Arca (EEA).
File sharing and storage solutions (such as Dropbox) acting as processors based outside of the EEA.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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
Some of our external third party providers/suppliers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe..
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us using the details set out at the beginning of this privacy notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial, Profile and Transaction Data) for seven years after they cease being customers for tax and accounting purposes and in case of any legal claims made against us.
We will keep Marketing and Communications Data (including Contact and Identity Data) whilst you are subscribed to our newsletters and after you opt out/unsubscribe. We keep this data after you opt out/unsubscribe in order to ensure we comply with your request not to receive marketing communications from us.
We will keep Usage Data for 2 years from the date of collection.
In some circumstances you can ask us to delete your data: see paragraph 9 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.
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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 on the details set out at the beginning of this notice.
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 may 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 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.