GDPR: Data privacy policy

John Higgins Contemporary Silver Gallery (“We”) are committed to protecting and respecting your privacy.
This policy  sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we?
Our site is operated by John Higgins Contemporary Silver Gallery of Lindfield, West Sussex. Caroline Lillywhite is the data controller. This means we decide how your personal data is processed and for what purposes. She can be contacted by email john@thecontemporarysilvergallery.co.uk

3. Your Rights
3.1. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:

3.1.1. The right to be informed about Our collection and use of personal data;
3.1.2. The right of access to the personal data We hold about you (see section 10);
3.1.1. The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 12);
3.1.2. The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 12);
3.1.3. The right to restrict (i.e. prevent) the processing of your personal data;
3.1.4. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
3.1.5. The right to object to Us using your personal data for particular purposes; and
3.1.6. Rights with respect to automated decision making and profiling.
3.2. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 12 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
3.3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

4. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data (please also see section 11 on Our use of Cookies and similar technologies):
4.1. the contents of any contact forms of user completed fields on the website, including your name, address and contact details;
4.2. any user submitted contact information such as email addresses and telephone numbers;
4.3. demographic information such as post code, preferences, and interests;
4.4. IP address;
4.5. web browser type and version;
4.6. operating system;
4.7. a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;

5. How do we use your Data?

5.1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 6, below.

5.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

5.2.1 Providing and managing your Account;

5.2.2 Providing and managing your access to Our Site;

5.2.3 Personalising and tailoring your experience on Our Site;

5.2.4 Supplying Our products or services to you (please note that We require your personal data in order to enter into a contract with you);

5.2.5 Personalising and tailoring Our products or services for you;

5.2.6 Replying to emails from you;

5.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by following the unsubscribe link in any of these emails);

5.2.8 Market research;

5.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

5.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message or post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

5.4 Third parties (including but not limited to Google, YouTube, Facebook and Twitter) whose content may appear on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.

5.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.

5.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

5.6.1 Personal data will be stored for no more than 3 years unless you have created an Account, if you create an Account your data will be stored until such a time as you close the Account and then for no more than 3 years afterwards.

6. How and Where Do We Store Your Data?
6.1 We only keep your personal data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.

6.2 Our server is entirely based within the UK, however some of your data (for example your name and email address) may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:

6.2.1 Ensuring that any information transferred outside the EEA is handled in accordance with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework

6.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

6.4 Steps We take to secure and protect your data include:

6.4.1 Server side encryption of personal information
6.4.2 Strict access limitation and logging for our physical servers
6.4.3 Limited and heavily monitored access to our front end systems

7. Do We Share Your Data?
7.1. We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

7.2. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

7.3. We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.

7.4. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

8. How Can You Control Your Data?
8.1. We aim to give you control on Our use of your data for direct marketing purposes by giving you the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and by requesting to no longer receive catalogues by post by emailing john@thecontemporarysilvergallery.co.uk

8.2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

9. Your Right to Withhold Information
9.1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
9.2. You may restrict Our use of Cookies. For more information, see section 13.

10. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at john@thecontemporarysilvergallery.co.uk, or using the contact details below in section 12.

11. Our Use of Cookies
11.1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

11.2. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies may be used on Our Site for the purposes of embedded content (for example embedded advertising or embedded content). For more details, please refer to section 4, above, and to section 11.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

11.3. All Cookies used by and on Our Site are used in accordance with current Cookie Law.

11.4. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

11.5. Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 11.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 11.10, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

11.6. The following first party Cookies may be placed on your computer or device:

 Name of Cookie Purpose Strictly Necessary
PHPSESSID Maintaining your PHP session Yes

11.7. Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

11.8. The analytics service(s) used by Our Site use(s) Cookies to gather the required information.

11.9. The analytics service(s) used by Our Site use(s) the following Cookies:

 Cookie Name Expiration Time Description
_ga 2 years Used to distinguish users.
_gid 24 hours Used to distinguish users
_gat 1 minute Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.
AMP_TOKEN 30 seconds to 1 year Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service
_gac_<property-id>  90 days Contains campaign related information. AdWords website conversion tags will read this cookie.

11.10. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

11.11. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

11.12. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

11.13. Due to changes by Third Party services which are beyond our control the specific cookies stored may change without prior warning. We will update this privacy policy whenever we are notified of such changes.

12. Contacting Us
If you have any questions about Our Site or this Privacy Policy, please contact Us by email at john@thecontemporarysilvergallery.co.uk. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

13. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

14. 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.

15. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact john@thecontemporarysilvergallery.co.uk
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.