Looking after your personal data is hugely important to Eden Fine Art London Limited (collectively referred to as “Eden Fine Art”, “we”, “us”, or “our” in this privacy policy). This privacy policy sets out the basis on which we process your personal data throughout the course of our relationship with you, including where you use our website www.eden-gallery.com (the “Website”). This privacy policy has been compiled to help you better understand the personal data we collect, how and why we use personal data, how we share your information, how we protect it, and the rights you have when it comes to your personal data.

It is important that you read this privacy policy together with any other privacy policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Our Website is not intended for children (under the age of 13) and we do not knowingly collect personal data relating to children.

Our Website 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 policy of every website you visit.

CONTROLLER

Eden Fine Art London Limited is the controller and responsible for your personal data.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the contact details set out at the end of this privacy policy.

WHAT THIS POLICY COVERS:

  • The type of personal data that we collect
  • How we collect your personal data
  • How we use your personal data
  • Marketing
  • Your data protection rights
  • How we use cookies and similar technologies
  • How we use personal data to contact and interact with you
  • International transfers
  • How and why we share your personal information
  • How we protect personal data
  • Data retention
  • How to contact us
  • Changes to our privacy policy
  • How to contact the appropriate authority

PERSONAL DATA WE COLLECT

Personal data 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 collect personal data from you as set out below.

We may process the following types of personal data:

  • Full name and title;
  • Gender;
  • Date of birth;
  • Contact details including your postal and billing address, email address and phone number(s);
  • Bank account and payment card details;
  • Details of products that you purchased from us;
  • Job title;
  • Personal interests and preferences including your marketing preferences;
  • Feedback and survey responses;
  • Details of the emails and other digital communications we send to you;
  • Information about how you use our Website, products and services and how you view emails that we send to you, including whether you open our emails, links that you click on and pages that you then visit on our Website;
  • Details of correspondence between us;
  • Information about your online browsing behavior; and
  • Information about the devices you have used [including your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity i.e. you will not be able to be identified from that data. For example, we may aggregate information about your use of our Website to calculate the percentage of users accessing a specific feature. 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 policy.

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, and you fail to provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

HOW WE COLLECT PERSONAL DATA

We use different methods to collect data from and about you including:

  • When you subscribe to our newsletter or complete a form on our Website;
  • When you contact us or we contact you (by email or otherwise);
  • When you browse our Website; and
  • From third parties including:
    • analytics providers such as Google Analytics; and
    • advertising networks such as Google Ads, Bing, Facebook, Instagram, LinkedIn.

HOW WE USE 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:

  • Where we have your consent;
  • Where we need to perform the contract we are about to enter into or have entered into with you;
  • 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; and
  • Where we need to comply with a legal obligation.

We process your personal data for the purposes set out below.

  • To register you as a new customer in order to perform our contract with you.
  • To process and deliver your order including managing payments received by you in order to perform our contract with you.
  • To collect and recover money owed to us which is necessary for our legitimate interests (to recover debts due to us).
  • To manage our relationship with you which will include notifying you about changes to our terms or privacy policy or asking you to leave a review or take a survey. We will do that in order to comply with a legal obligation, or where it is necessary in our legitimate interests (in order to effectively run our business).
  • For administration and maintenance of our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) which is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise).
  • To deliver relevant Website content and advertisements to you and to measure or understand the effectiveness of the advertising we serve to you either on the basis of your consent or where it is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
  • To make suggestions and recommendations to you about goods or services that may be of interest to you which is necessary for our legitimate interests (to develop our products/services and grow our business).
  • To provide you with the information that you have requested from us (including receipt of marketing emails/ newsletters or other information). We will provide such information on the basis of your consent or where it is necessary in our legitimate interests to effectively run our business.
  • To respond to queries raised by you either in order to perform our contract with you or where it is necessary in our legitimate interests (to effectively run our business).
  • To ensure compliance with our terms of use in order to perform our contract with you.
  • To comply with legal obligations or for the protection and enforcement of legal rights.
  • In connection with any sale of our business or assets in our legitimate interests (to allow us to sell our business or assets).

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. 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.

MARKETING

Eden Fine Art will send you information about products and services of ours that we think you might like either on the basis of your consent, or in our legitimate interests in order to provide the best possible service to our customers.

If you have agreed to receive marketing, you may always opt-out at a later date. You have the right at any time to stop us from contacting you for marketing purposes.

To unsubscribe from receiving marketing emails, you can follow the instructions at the bottom of each email.

If you no longer wish to be contacted for marketing purposes, please click here, or contact us using the details below.

To help us better understand the information you would like to receive, you can always update your email marketing preferences by emailing us at [email protected]

DATA PROTECTION RIGHTS

Under certain circumstances, you have the rights set out below.

  • The right to access - You have the right to request from us copies of your personal data.
  • The right to rectification - You have the right to request that we correct any information about you that is inaccurate or incomplete, though we may need to verify the accuracy of the new data you provide to us.
  • The right to erasure - You have the right to request that we erase your 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.
  • The right to restrict processing - this enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data's accuracy;
    • Where our use of the data is unlawful but you do not want us to erase it;
    • 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; and
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • The right to object to processing - 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • The right to data portability - You have the right to request that we transfer the data that we have collected to another organization, or directly to you 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.

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 could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

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.

If you would like to exercise any of these rights, please contact us at our email: [email protected].

COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small data files that allow a website to collect and store a range of data on your desktop computer, laptop, or mobile device. We use cookies and similar technologies (e.g., tags) on our Website to distinguish you from other users, helping us to personalize and improve your experience of our Website and the gallery.

We use cookies to:

  • Understand how our Website is being used, for example, by telling us if you get an error message when you browse;
  • Understand and save your preferences and contact details, so you do not have to submit this information twice;
  • Measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you; and
  • Help us compile data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may use trusted third-party services, like Google Analytics, that track this information on our behalf.

Some cookies are necessary, so you should not disable these if you want to be able to use all the features of our Website. You can disable cookies, but this may affect your full experience of the Website. Learn more about cookies here.

INTERNATIONAL TRANSFERS

The personal data that we collect from you is 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 our associated companies. Such staff may be engaged in, among other things, the provision of support and sales services. By submitting your personal data, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

We will only transfer your personal data outside the EEA where one of the following safeguards applies:

  • An adequacy decision has been made by the European Commission in respect of the country to which we are transferring your personal data;
  • We have put in place specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield.

PERSONAL DATA SHARING

We may share your personal data with the following third-party processors for the purposes set out above:

  • service providers including delivery partners and website hosting partners who assist us in operating our Website, conducting our business, or serving our users.

We may also share your personal data with third parties as set out below.

  • Other companies in our group.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • 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 policy. HM Revenue & Customs, regulators and other authorities require reporting of processing activities in certain circumstances.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention of money laundering and credit risk reduction.

HOW WE PROTECT YOUR DATA

We implement a variety of security measures to maintain the safety of your personal information.

Personal data collected on our Website is hosted and managed by Amazon Web Service (AWS), our customer relationship management provider. They are the world leader in their field and provide and document audited security measures to maintain the safety of your personal information.

Additionally, please note:

  • We use computer firewalls and physical, electronic and procedural safeguards in connection with the collection, storage, and disclosure of personal data;
  • Your personal information is only accessible by a limited number of employees who have special access rights to such systems and who are required to keep the information confidential;
  • All communications between your browser and our Website are encrypted; and
  • External to these networks, our data is only accessed on equipment owned and maintained by the company; safeguards are in place to prevent unauthorized external access to our data.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

HOW TO CONTACT US

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Full name of legal entity:
Eden Fine Art London Limited.
Address: 103 New Bond St, Mayfair, London W1S 1ST, United Kingdom
Email address: [email protected]
Telephone number: +4420 3769 0150

CHANGES TO OUR PRIVACY POLICY

Eden Fine Art keeps its privacy policy under regular review and places any updates on this Website. We reserve the right to change this policy at any time, so please check back regularly to keep informed of updates. This privacy policy was last updated on Thursday, April 23, 2020.

HOW TO CONTACT THE APPROPRIATE AUTHORITY

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Chief Digital Officer (“CDO”) at [email protected]

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).