OUR PRIVACY PROMISE
Your privacy is important to Unit London (“we“, “us” and “our“). We are committed to protecting your personal data and being transparent about the personal data we hold and use and, wherever possible, giving you control over how we use your personal data.
This notice is intended to be communicated to you in a concise, transparent, intelligible, and easily accessible manner, but we appreciate that you may have queries or want to seek clarification as to its terms. If so, please contact us (using the details set out at paragraph 2 below) and we will endeavour to respond to you as soon as possible.
We may make changes to this notice from time to time, including as may be necessary or prudent to reflect any changes in the ways in which we process personal data or any changes in data protection laws. Any changes and updates to this notice will be posted on the Unit London website. Please check this notice regularly so that you are aware of any changes.
1. INTRODUCTiON
Please read this notice carefully. Amongst other things, it explains:
- What personal data we collect about you;
- Why we collect and use your personal data and the legal bases we rely on for processing your personal data;
- Who we disclose your personal data to;
- Where we store your personal data;
- How long we keep your personal data; and
- Your rights regarding the personal data that you provide to us.
Our website (https://unitlondon.com) is not intended for children, and we do not knowingly collect data relating to children. If you are aged 16 or under‚ please ask your parent or guardian’s permission before providing us with any personal information.
2. WHO WE ARE AND OUR CONTACT DETAILS
For the purposes of data protection laws, the controller who is responsible for your personal data is Unit London Limited, a company registered in England and Wales (company no. 09235339) with its registered office at 3 Hanover Square, W1S 1HD.
If you have any questions about this notice, including any requests to exercise your legal rights, please contact our data privacy manager using the details set out below.
- Email address: privacy@unitlondon.com
- Postal address: FAO The Data Privacy Manager, Unit London Ltd of 3 Hanover Square, W1S 1HD
3. CHANGES TO YOUR PERSONAL DATA
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal details change during your relationship with us or if you become aware that any personal data we hold about you is not accurate.
4. THIRD-PARTY LINKS
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 those third-party websites, and we accept no liability for the privacy practices or content of such sites. When you leave our website, we encourage you to read the privacy notice of every website you visit.
5. THE DATA WE COLLECT ABOUT YOU
5.1 In this notice, “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 person’s identity has been removed (“anonymous data”).
5.2 We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
5.2.1 “Identity Data” includes first name, last name, title, organisation and job title, details in an email signature, biography, photo ID, address, date of birth, gender, nationality, national insurance number, passport number and/or photograph, driving licence number and/or photograph, unique tax reference (UTR) number, national identity card number and/or photograph and the identification confidence score given by information providers, such as Arcarta, who assist us with our “know your client” obligations under the AML Regulations;
5.2.2 “Biographical Data” includes information about the past activities (including, but not only, employment, offices held and other activities) of you and persons associated with you (including but not only family members), applicable sanctions and Special Categories of Personal Data, for example a photograph which may constitute biometric data or may indicate racial or ethnic origin;
5.2.3 “Contact Data” includes email address, telephone number(s) and online presence details (e.g. social media handles or details on publicly available website or social media pages);
5.2.4 “Correspondence Data” includes information which you provide in, or we learn about you from, any correspondence or communications with us, including details of any enquiries relating to sales and acquisitions, press opportunities, events, submissions to feature in our galleries or requests for support and any other information you provide to us;
5.2.5 “Employment Data” includes your CV, résumé, educational background, employment history and any other information you provide in connection with the same;
5.2.6 “Financial Data” includes bank account and payment card details;
5.2.7 “Transaction Data” includes details of payments we make and receive from payments made at any of our exhibitions/art fairs/events/galleries, as well as details of services and/or goods provided by artists, collaborators and/or suppliers and goods purchased at any of our exhibitions/art fairs/events/galleries;
5.2.8 “Technical Data” includes type of device, unique device identifier (e.g. an IMEI number, IDFA, your internet protocol (IP) address), online identifiers, 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 that you use to access our website;
5.2.9 “Usage Data” includes information about how you use our website and services, your use of social media platforms e.g. your Instagram handle; and
5.2.10 “Marketing and Communications Data” includes your preferences about receiving newsletters and communications from us and any information that you may provide to us in any reviews or feedback.
5.3 Information about why we process the above personal data and the lawful bases we rely upon is set out at section 7.2 below.
5.4 We may receive aggregated statistics and insights regarding your use of the website from advertising, analytics and attribution provides such as Google Analytics and may also collect, use and share aggregated data such as statistical or demographic data (“aggregated data“) for any purpose. Aggregated data may be derived from your personal data but are not considered personal data in law as those data neither directly nor indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. If, however, we combine or connect aggregated data with your personal data so that you can be directly or indirectly identified, we treat the combined data as personal data, which will be used in accordance with this notice.
5.5 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 data when requested (or fail to consent to the processing of that data if necessary), 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 services). In that case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
6. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you, including through:
6.1 Direct interactions
You may give us your Identity, Biographical, Contact, Financial, Transaction, Employment and/or Marketing and Communications Data by filling in forms, or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data that you provide when you:
6.1.1 apply for job opportunities;
6.1.2 subscribe to our mailing list (via our website, in person at one of our events or otherwise) for updates on art news, exhibitions, art fairs and events, collecting art and limited edition prints, exclusive releases and other relevant information;
6.1.3 send an email (plus any attachments) to any of our contact email addresses, such as when you send us queries or expressions of interest by email;
6.1.4 phone us, or meet us in person;
6.1.5 send us any correspondence by post;
6.1.6 filling in forms or by corresponding with us by post, phone, email or otherwise;
6.1.7 attend one of our events (where you may speak to us directly and/or appear in any photographs or videos taken at the event);
6.1.8attend one of our galleries;
6.1.9 purchase pieces of art at any of our exhibitions and/or art fairs and/or events and/or galleries;
6.1.10 interact with us via social media or post content on our social media pages (e.g. Facebook, Instagram and Twitter) or any of our other channels; and/or
6.1.11 give us some feedback.
6.2 Third parties or publicly available sources
We may receive personal data about you from various third parties as set out below:
6.2.1 Technical Data and Usage Data from analytics providers such as Google based inside and/or outside the UK and/or the EEA;
6.2.2 Technical Data from social networks such as Facebook, Instagram and Twitter based inside and/or outside the UK and/or the EEA;
6.2.3 Technical Data from search information providers such as Google based inside and/or outside the UK and/or the EEA;
6.2.4 Identity, Biographical and Contact Data from publicly available sources;
6.2.5 Identity, Contact, Financial, Transaction and/or Marketing and Communications Data from our guests, artists, collaborators and/or suppliers that we may work with (e.g. for the purposes of organising events or inviting you as a guest); and/or
6.2.6Identity, Contact and/or Marketing and Communications Data from artists, collaborators and/or suppliers for the inclusion on any guest lists for events.
6.3 Automated technologies or interactions
As you interact with our website, we (or our analytics providers) may automatically collect Technical Data about your equipment, browsing actions and patterns. Such personal data may be collected by using cookies and/or similar technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please see our Cookies Notice for further details.
7. HOW WE USE YOUR PERSONAL DATA
7.1 We use your personal data for a number of purposes but only where we are allowed to by the law.
7.1.1 Generally, we will process your personal data in the following circumstances:
7.1.1.1 Where we need to perform the contract we are about to enter into or have entered into with you.
7.1.1.2 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. These legitimate interests include the purposes identified in the table below at section 7.2 but also include other commercial interests and our internal administrative purposes. Where we rely on legitimate interests as the lawful basis for processing your personal data, we will put in place appropriate safeguards to protect your data and to ensure that your interests or fundamental rights and freedoms are not overridden by those legitimate interests.
7.1.1.3 Where we need to comply with a legal or regulatory obligation, for example the AML Regulations.
7.1.2 Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to unsubscribe from any marketing communications at any time by clicking on the footer link included in our communications with you. Unsubscribing does not affect the lawfulness of any processing that occurred before unsubscribing.
For further information regarding your rights and other matters regarding the lawful bases, please visit the ICO’s website at www.ico.org.uk.
7.2 Purposes of processing
7.2.1 We have set out below, in a table format, a description of all the ways we may 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.
7.2.2 Please note that we may process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data. Please contact us if you would like details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
| Purpose | Type of Personal Data | Lawful basis for processing (including basis of legitimate interest) |
To manage our relationship with you, including:
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| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
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| To use data analytics to improve our website, services, exhibitions, events, arts fairs and other activities, marketing, customer relationships and experiences | Identity Data
Contact Data Correspondence Data
|
Necessary for our legitimate interests (to keep our website updated and relevant, to refine our services, exhibitions, art fairs, events and other activities, to develop our organisation and to inform our communications strategy) |
| To process and keep records of:
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|
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| To make suggestions and recommendations to you about art related services and products we provide that may be of interest to you (including but not limited to: exhibitions, art fairs and events, collectable art and limited edition prints and exclusive releases) |
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Necessary for our legitimate interests (to develop products sold through our website and physical galleries/services and grow our business) |
| For the purposes of preventing and detecting fraud and other criminal activity |
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In addition, in relation to Special Categories of Personal Data and, where such a basis is required, in relation to information about criminal convictions and offences:
|
| For recruitment purposes, including to keep records of any job applications we receive |
|
|
7.3 Marketing
We strive to provide you with choices regarding certain uses of personal information, particularly around communications, where relevant. Please contact us (using the contact details set out in section 2 above) if you would like to update your marketing preferences.
7.3.1 Information from us about our exhibitions, art fairs and events:
We may use your Identity, Biographical, Contact, Technical, Usage, and Marketing and Communications 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 exhibitions, art fairs, events, private art collections, exclusive releases and limited edition prints or other activities it may be relevant for us to contact you about (which we refer to as marketing); and
7.3.1.1 You may receive marketing communications from us if you have (directly or indirectly) provided us with your details (by signing up to our mailing list or by purchasing any pieces at any of our events/art fairs/exhibitions/galleries) and asked us (or asked any of our artists, collaborators and/or suppliers) to receive such communications from us and, in each case, you have not opted out of receiving those communications.
7.3.2 Opting out
To opt out of email marketing communications, please use the unsubscribe link within the relevant email and follow the unsubscribe instructions or you can contact us using the contact details set out in section 2.
7.4 Change of purpose
7.4.1 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.
7.4.2 If we need to use your personal data for an unrelated purpose, we will notify you (which may be by way of an update to this notice) and explain the legal basis that allows us to do so.
7.4.3 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.
8. DISCLOSURES OF YOUR PERSONAL DATA
8.1 We may share your personal data with the external parties set out below (external third parties) for the purposes set out in the table in section 7 above:
8.1.1 Our collaboration partners that we may work with for the purposes of putting on exhibitions, art fairs, events or running our other activities.
8.1.2 MailChimp, the hosting platform for our mailing list;
8.1.3 Arcarta, the customer due diligence platform we use to comply with our obligations under the AML Regulations. Please review the terms of Arcarta’s privacy policy for further details on how they process your data here: https://www.arcarta.com/support/user-agreement;
8.1.4 Service providers acting as processors who provide database, booking, IT and system administration services, including Artlogic, Hubspot, and Salesforce;
8.1.5 Social media platforms including Facebook, Instagram and Twitter;
8.1.6 Professional advisers acting as processors or controllers, including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services;
8.1.7 HM Revenue & Customs, regulators and other authorities acting as processors or controllers based in the UK who require reporting of processing activities in certain circumstances;
8.1.8 Google Analytics, Google Ads, Facebook, Instagram and other analytics, advertising and attribution partners for personalised and non-personalised advertising; and/or
8.1.9 A law enforcement authority or regulator.
8.2 All such third parties have their own legal obligations to respect the security of your personal data and to treat it in accordance with the law.
8.3 In the event that our business or any part of it is sold or integrated with another business, your details may be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
9. INTERNATIONAL TRANSFERS
9.1 Data transfers
9.1.1 We do not typically transfer the types of personal information that we obtain to locations outside the UK. To the extent that we do so (e.g. where we engage a data processor that is based outside the UK), we will strive to ensure that a similar degree of protection is afforded to such information by ensuring that at least one of the following safeguards is implemented:
9.1.1.1 transferring your personal information to a country, organisation or sector that has, at the time of transfer, been deemed to provide an adequate level of protection for personal information;
9.1.1.2 appropriate safeguards are in place as permitted under data protection laws. These safeguards include the use of approved standard contractual clauses; and/or
9.1.1.3 the transfer is otherwise allowed under data protection laws (including where we have consent or the transfer is necessary for the performance of a contract with the data subject).
9.1.2 Please contact us if you would like further information on any specific mechanism used by us when transferring your personal information outside the UK.
9.2 Accessibility of our website and communications
9.2.1 Please note that our website is available to users across the world, and so personal information about you to the extent made available on our website may be accessible outside the UK;
9.2.2 When you provide your personal information to us to be used on our website and/or in our communications (for example, if you are an artist, collaborator or supplier and your work and/or role features at one of our upcoming exhibitions and/or art fairs and/or events), then you do so on the understanding that territories outside the UK in which recipients reside may provide a lower standard of protection for your personal information and so there may not be adequate safeguards in place to protect your information; and
9.2.3 To the extent that, in those circumstances, your personal information on our website and/or in our communications is accessed outside the UK, that is done with your explicit consent, which you give to us by providing that information for use on our website and/or in our communications. You may withdraw that permission at any time by contacting us.
10. DATA SECURITY
10.1 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.
10.2 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. Our database is currently hosted by Hubspot. For further information on their privacy practices and how they safeguard clients’ data, please see https://legal.hubspot.com/privacy-policy.
11. DATA RETENTION
11.1 We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected such information (or for any compatible purpose), including for the purposes of satisfying any legal (including any obligations required of us under the AML Regulations), accounting or reporting requirements. In some circumstances you can ask us to delete your data (please see erasure requests in section 12.1.3 below for further information).
11.2 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.
12 YOUR LEGAL RIGHTS
12.1 In certain circumstances, you have the following rights under data protection laws in relation to your personal information:
12.1.1 right of access to your personal information we hold about you;
12.1.2 right to rectification of your personal information, if you consider that the information we hold on you is inaccurate;
12.1.3 right to erasure of your personal information, if you consider that we do not have the right to hold it;
12.1.4 right to restriction of processing of your personal information (to the extent such processing is based on previously obtained consent);
12.1.5 right to portability of your personal information;
12.1.6 right to object to certain types of processing of your personal information in certain circumstances;
12.1.7 right not to be subject to automated decision-making (including profiling); and/or
12.1.8 right to withdraw consent to processing of your personal information.
To find out more about these rights, please visit the ICO’s website (www.ico.org.uk).
Please note that the above rights are not absolute in all situations and may be subject to conditions and provisions as set out in data protection laws. We cannot therefore guarantee that we will be able to honour any request from you in connection with the rights set out above. For example, if you request that we delete your personal data, we may be required by law to retain some personal data for accounting and record keeping purposes or in order that we comply with our legal and regulatory obligations.
12.2 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). We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those circumstances.
12.3 What information we may need from you
We may need to request specific information from you to help us confirm your identity and to ensure your right to access your personal data (or to exercise any of your other rights). That is a security measure to ensure that personal data is not disclosed to any person that has no right to receive such data. We may also contact you to ask you for further information in relation to your request to speed up our response.
12.4 Time limit to respond
Any request from you for access to or a copy of your personal data must be in writing (via email is sufficient) and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In that case, we will notify you and keep you updated.
13. QUESTIONS AND COMPLAINTS
13.1 We take our data protection obligations seriously. If you have any questions or complaints about this notice or the way that we handle your personal data, we would appreciate the chance to deal with your concerns in the first instance before you approach the relevant data protection authority. Please contact us using the details provided in section 2 above.
13.2 You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues, which in the UK is the Information Commissioner’s Office (ICO) whose website is at www.ico.org.uk.
14. CHANGES TO THIS NOTICE
14.1 As noted above, we may update or otherwise modify this notice at any time. We will notify you of any changes to our notice by posting the modified notice on our website.
14.2 This version was last modified on the date noted below, and historic versions can be obtained by contacting us.
Last updated: August 2023