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Privacy policy
This policy applies to information held about clients and prospective clients, suppliers and prospective suppliers, contacts and all other persons about whom Wilson Stephens & Jones 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 Wilson Stephens & Jones, and “you” means the individual to whom the information relates. We are the data controller and we operate our website www.wsjgallery.com.
Information we collect about you:
We may collect and store the following types of information about you when you our site or by corresponding with us (for example, by e-mail). This includes information you provide when registering to use our sites or sharing any data via our social media functions. The information given to us may include:
•your name;
•your contact information such as your address, email address and telephone number;
•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, events and art and antiques fairs
•information about you that you give us in person at our events and at fairs, by filling in forms on our site www.wsjgallery.com (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
•information in relation to your purchase of our artwork, antiques or use of our services.
How we collect information about you:
You may give us your information by [filling in forms on our site or by corresponding with us by post, phone, email, on social media or otherwise]. This includes information you provide when you:
•visit us at art and antiques fairs;
•your purchase of any artwork or antique; and
•subscribe to our newsletter via our website
Legal basis for processing:
Our processing of your personal information is necessary (i) for the purposes of legitimate interests pursued by us; (ii) in order to comply with a legal obligation to which we are subject; or (iii) 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. 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:
•collecting personal information to provide you with a smooth and efficient client experience;
•running our business;
•to make sure you receive updated information on WSJ Gallery' activities;
•to provide the services you have requested; and
•for our own marketing, research and development.
How we use your information:
We use your information to:
•provide information about our antiques / artworks / works of art and services to you
•keep you informed about antiques / artworks / works of art, 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.
Will we share your information with third parties?
Except as expressly set out in this policy we will never sell or lease your personal information to third parties. We may share your information if we have your permission with the following categories of companies, only if this is necessary to provide you with our artwork, antiques or services, respond to your inquiries or for any of the purposes described in this policy:
•agents, such as shippers
•contractors, such as couriers
•service providers, such as antiques trade organisations
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 reorganisation with that entity.
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 erase 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 by completing the form on the contact page.
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 information about our artwork, antiques, events, and art and antiques fairs. You can stop receiving marketing messages from us at any time by clicking the ‘Unsubscribe’ link at the bottom of any email 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 completing the form on the contact page. 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.
Security and storage of your information:
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. The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It 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.
How we use cookies:
We may send a small file to your computer when you visit our website; this file stores your session identifier. This enables us to identify your computer and to allow our systems to tailor their response to your requests. We only use cookies to save your website preferences, keep you logged into the website or to customise the way you view the website to meet your choices. Except through the use of cookies, we do not automatically log or collect data unless you specifically provide it to us. You can set your computer browser to reject cookies but this may preclude your use of certain parts of this website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. To find out more about cookies, including how to control and delete them, visit www.allaboutcookies.org. If you decide to disable or refusecookies, please note that some parts of our sites may become inaccessible or not function properly.
Google Analytics:
We use Google Analytics to help analyse use of our website. This analytical tool uses 'cookies', which are text files placed on your computer, to collect standard internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website (including your IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity for this website. To find out more about cookies, including how to control and delete them, visit www.allaboutcookies.org, or to opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
We will not (and will not allow any third party to) use the statistical analytics tool to track or to collect any personally identifiable information of visitors to our site. We will not associate any data gathered from this site with any personally identifying information from any source as part of our use of the Google statistical analytics tool. Google will not associate your IP address with any other data held by Google. Neither ourselves nor Google will link, or seek to link, an IP address with the identity of a computer user.
Links to other sites:
Our site may contain links to other websites, 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 Sites 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 sent to us by completing the form on the contact page. 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.
Children under 14:
We do not intentionally collect any information on children under 14 years of age. We will undertake to delete any details of such users where a parent or guardian has notified us that any such details have been obtained.
ANTI-MONEY Laundering:
Under the terms of the Fifth Anti-Money Laundering Directive effective from 10 January 2020, we are required to conduct customer due diligence (CDD) on all sales of works of art over €10,000. Whilst we may agree such a sale in principle, we will not be able to conclude until we have received all the necessary CDD information from you and have been able to verify it as required by the regulation. The completion of sales is contingent on the provision of such information by customers, and any suspicious activity will be reported to the National Crime Agency. The regulation requires us to keep a record of CDD for a period of 5 years from the completion of the transaction.
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.