PRIVACY POLICY

The Society of London Art Dealers Ltd (“SLAD“, “us”, “we”) is committed to protecting and respecting your privacy.
This statement explains how we collect and look after your personal data when you visit our website and tells you about your privacy rights and how the law protects you.

Purpose of this privacy statement

The purpose of this privacy statement is to explain how SLAD collects and processes your personal data through your use of this website (the “Site“)(and each user being a “Site User“), or where you become a member of SLAD (each a “Member“). This Site is not intended for use by children and we do not knowingly collect data relating to children.
It is important that you read this statement as well as any other privacy, transparency or fair processing notice we may bring to your attention on specific occasions when we are collecting or processing personal data about you. This privacy statement supplements our website terms of use.

Why do we collect your personal data?

If you are a Site User, we may collect and process your information in order to permit you to use our Site, If you are a Member, we may collect and process information relating to you or your clients in order to provide our services to you.
Regardless of whether you are a Site User or a Member, we shall process any information we collect as we are required to under UK data protection law and the provisions of this Policy.

What personal data may we process and where do we get it?

If you are a Site User, the information referred to above may include your personal information including the following types of personal information:

• Communication information we collect when you communicate with us or any other time you contact us, including information we obtain from the instructions you give us; and
• Cookie and tracker information we collect through the use of cookies and similar technologies, including traffic data and information about features of the Site you interact with.

If you are a Member, the information referred to above may include your personal information including the following types of personal information:

• Identifying information such as your name which you provide to us;
• Contact information such as your address, email address or phone number which you provide to us;
• Profile information such as your date of birth, age, gender or an other information required as part of your registration to become a Member;
• Communication information we collect when you communicate with us or any other time you contact us, including information we obtain from the instructions you give us; and
• Cookie and tracker information we collect through the use of cookies and similar technologies, including traffic data and information about features of the Site you interact with.

Why do we process your information?

If you are a User, we may use your information for the following limited purposes:

• To understand how you use the Site and for what purposes; or
• To fulfil requests for information placed by you; or
• To respond to or investigate enquiries submitted by you; or
• To enforce or apply this Policy or any other legal rights we have in relation to you.

If you are a Member, we may use your information for the following additional purposes:

• providing our membership services to you; or
• to administer and operate your membership with SLAD and matters associated with you membership; or
• to monitor and analyse your conduct as a Member, including to prevent abuse of our memberships; or
• to meet our legal or regulatory obligations; or
• for our reasonable commercial purposes (including to assist us to develop new and improved services for our Members); or
• to confirm your identity and carry our background checks, including anti-money laundering due diligence and compliance screening to prevent fraud and other crimes; or
• to circulate attendee lists for events or exhibitions we hold for our Members.

What is the legal basis for our processing?

We are allowed to process such information in this way, in compliance with UK data protection law, by relying on one or more of the following lawful grounds:

• you have explicitly agreed to us processing such information for a specific reason;
• the processing is necessary to perform our obligations under an agreement we have with you;
• to take steps to enter into an agreement with you;
• the processing is necessary for compliance with a legal obligation we have; or
• the processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
  1. to ensure that our memberships are well-managed;
  2. to prevent fraud;
  3. to protect our business interests;
  4. to ensure that complaints are investigated;
  5. to evaluate, develop or improve our services; or
  6. to keep our clients informed about relevant services.

Who may receive your data?

We will keep all your information confidential. However, in order to be able to provide our services to the best of our ability (be that the provision of the Site or administration of your membership), we may share any information you provide to us with to our agents, counterparties and support service or data providers, where they provide services to us.
Each of the companies authorised to process your information as mentioned above will do so in accordance with UK data protection laws.
Some parties we may transfer information to are located outside the United Kingdom (UK) and we note that these countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information they hold about you and that such information can become subject to the laws and disclosure requirements of such countries.. For all transfers of your information outside of the UK and whilst your data remains outside the UK, we will make sure that it will continue to be handled in accordance with UK data protection standards.
In particular, when we, or our permitted third parties, transfer information outside the UK, we or they will impose contractual obligations on the recipients of that data to protect such information to the standard required in the UK. We or they may 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:

• the transfer is to a country deemed by the UK government to provide adequate protection of your information;
• you have consented to the transfer, or
• such transfer is otherwise permissible under the law (for example if we are required to provide such information by law).

Other disclosure of information

In the unlikely event that a liquidator, administrator or receiver is appointed over us or all or any part of our assets that insolvency practitioner may transfer your information to a third party purchaser of the business provided that purchaser undertakes to use your information for the same purposes as set out in this policy. Your information will not be disclosed to government or local authorities or other government institutions save as required by law or other binding regulations.

Automated processing

We do not carry out automated decision-making or profiling in relation to our Site users or Members.

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.

What about direct marketing?

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.
You may, at any time, request that we cease or do not send such information by one, some or all channels, by contacting us using the contact details set out below or by clicking “unsubscribe” for the relevant communication .If you opt out from marketing, we will retain your information only to the extent required to enable us to respect your wishes to not be contacted for marketing purposes.

Third-party links:

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties also to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies or statements. When you link to them, we encourage you to read their privacy statements as well.

You have the right to:

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us at [email protected].
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 if we are required to keep your information for a legal obligation. If there are specific legal reasons preventing us from deleting your information, these will be notified to you 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 (see “What about direct marketing?” above). 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 (also known as the right to portability). 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. Withdrawing your consent will not affect the lawfulness of any processing carried out before the withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. Please note that 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.

Changes to the privacy notice:

We always publish the latest version of our privacy statement here on our Site. This version of was updated and published in [May] 2022. Previous versions can be obtained by contacting us using the contact details below.

Contact

If you have any questions, comments or requests regarding this privacy policy or how we handle your personal data, please address these to The Society of London Art Dealers Ltd at [email protected].