This privacy policy sets out how iRostrum Limited (use, we, our, iRostrum) uses and protects any information that you give us when you use this website or our Services.

iRostrum is committed to ensuring that your privacy is protected. With any information that we ask you to provide by which you can be identified when using this website you can be assured that it will only be used in accordance with this privacy statement.

iRostrum may change this policy from time to time without notification and therefore advise you to regularly review this policy when you visit this site. This policy is effective from 1 June 2022.

Data controller and contact details

iRostrum Ltd incorporated and registered in England and Wales with the company number 8112845 whose registered office is at 6 Wellington, Warren Row, Reading RG10 8QX is the data controller of your personal data and is subject to the General Data Protection Regulation (GDPR).

If you have any questions about how we use your personal data, whom we share it with, or if you wish to exercise any of the rights set out in this policy, please contact us using the following details:

• Post - Marijke Varrall-Jones | iRostrum Ltd | 6 Wellington | Warren Row | Reading RG10 8QX
• Email - marijke@irostrum.com

How we collect your personal data

We may collect and process personal data from the following sources:

From you when you:

communicate with us by post, email or via our website, for example to make enquiries or completing forms on our website;

interact with us before entering into contract with us, for example when you express your interest in our Services;

instruct us to provide Services to you, sign contractual documentation and provide information in connection with those instructions;

in various other ways as you interact with us during your time as a user (or potential user) of our Services for the various purposes set out below.

Information we may collect from you

• Name and job title;
• Contact information including address, telephone and email address;
• Demographic information such as postcode, preferences and interests;
• Payment details such as credit card and bank account details;
• information that you provide by filling in forms on our website;
• Other information relevant to customer surveys and/or offer

If you do not want your personal data collected, please do not submit it to us.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

Where we have a contractual relationship with you

We will process your personal data because it is necessary for the performance of a contract with you (for example, a contract to use our Services) or in order to takes steps at your request prior to entering into a contract. I this respect, we use your personal data for the following:

• to interact with you before you enter into a contract with us, such as when you express your interest in our Services (for example, to send you information about our Services or answer enquiries about our Services);
• one you have engaged us and entered into a contract, to provide you with the Services set out in any contractual documents.

In this respect we may provide your data to our third party suppliers or subcontractors as necessary whom we engage to help us perform our Services or who assist us in conduction our business, such as our IT suppliers and data storage providers.

Legitimate interests

We may also process your personal data because it is necessary for our or a third party's legitimate interests. Our legitimate interests include our commercial interests. In this respect we may use your personal date for the following:

• for our internal record keeping;
• to evaluate and improve our products and services;
• to contact you for marketing purposes. We may periodically send promotional emails and mailouts about events and other information which we think you may find interesting using the email address or contact information which you have provided. If you do not wish to receive such information you can let us know at any time and your details will be removed from our mailing list;
• to contact you for market research purposes. We may contact you by email, phone, or mail. We may use the information to customise the website and marketing communications according to your interests;
• to collect money owed to us or our consignors;
• to seek advice on our rights and obligations, including obtaining legal advice;
• to deal with any concerns or feedback you may have with the performance of the Services;
• We will not provide your personal data to third party organisations to use for their own marketing purposes.

In this respect we may provide your data to the following:

• our professional advisors;
• third parties who assist us with our marketing;
• our website and email management software providers;
• debt collection agencies.

Legal obligations

We may also process your personal Data for our compliance with our legal obligations. In this respect we may use your personal data for the following:

• to meet our compliance and regulatory obligations, such as our tax reporting requirements or to carry out identity checks;
• in order to assist with investigations including criminal investigations carried out by competent authorities;

In this respect we will provide your date to the following:

• external auditors;
• the police and other competent authorities, including HMRC;

Consent

We may also process your Personal Data where we have your specific consent to do so or where we have sought and obtained your consent to send you direct marketing by email. If you have given your consent and you wish to withdraw it, please contact us using the contact details set out above.

Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our Services to you and/or it may affect the provision of our Services.

Profiling

We may use your geographical location to target our communications and advertising and promotions to you. If you do not wish us to do this, then please contact us using the details provided above.

IP Addresses

We may collect information about your computer including, where available, your IP address, operating system and browser type for system administration. This is data about our users’ browsing actions and patterns and does not identify any individual. We will not collect information from you other than that provided by your browser in normal use.

Cookie Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

What are Cookies?

Cookies are text files containing small amounts of information, which are downloaded to the browser that you use on your device, when you visit a site. The entity that placed cookie on your browser can then read the information on that cookie that it set. You can find more information about cookies at: www.allaboutcookies.org .

Our Sites use the following types of cookies:

Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Sites and use their features, such as logging into secure areas of the Sites and place bids. Without these cookies, services like enabling appropriate content based your type of device cannot be provided.

Performance Cookies: These cookies collect information on the number of visitors on our Sites and how they use them, for instance which pages visitors go to most often, and if they get error messages from web pages. All information these cookies collect is aggregated and is only used to improve how the Sites work.

Functionality Cookies: These cookies allow the Sites to remember choices you make (such as your language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Social Media Cookies: These cookies are used when you share information using a social media sharing button on the Sites. The social network will record that you have done this. This information may be linked to targeting/advertising activities.

Your Choices About Cookies

We require your consent for cookies to be placed on your device as you visit our Sites. You have the right to decide whether or not to accept cookies. However, they are an important part of how our Sites work, so you should be aware that if you choose to refuse or remove cookies, this could affect the availability and functionality of the Sites.

If you don’t want to allow cookies at all, or only want to allow use of certain cookies, please refer to your browser settings.
You can also use your browser settings to withdraw your consent to our use of cookies at any time and delete cookies that have already been set. The website www.allaboutcookies.org contains comprehensive information about the process of opting out on different browsers.

If you are in the EU and would like to opt out of third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu . Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
In the US, the Network Advertising Initiative offers a means to opt out of a number of advertising cookies. Please visit www.networkadvertising.org/choices/to learn more.

How long we keep your information

We will retain your personal data for as long as we are providing you with the Services referred to in any contractual document, and for as long as is required for legal, regulatory, fraud prevention and our legitimate business purposes after the termination of your account/agreement with us, or if your application for a particular Service is declined or abandoned.

In particular:

• in relation to personal data relating to the transactions you have entered into with us as part of the provision of our Services, we will retain that data for period of seven years after your most recent transaction has concluded in case any legal claims arise out of the provision of those Services;
• we will retain your details on our marketing database until you inform us that you no longer wish to receive our marketing communications. However, where you do unsubscribe from our marketing communications we will keep your details on a suppression list to ensure that we do not send you information you have asked not to receive;
• in relation to personal data relating to the provenance of works, we may retain that data indefinitely in our legitimate interests and the legitimate interests of the wider art market in maintaining the integrity of that market.   

Security

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.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Your legal rights

From the 25 May 2018 you have the following rights:

• to require us to correct the personal data we hold about you if it is incorrect;
• to require us to erase your personal data;
• to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
• to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

If you are not satisfied with how we are processing your personal data, you can raise a concern with the Information Commissioner. You can also find out more about your rights under data protection legislation from the Information Commissioner's Office website available at: www.ico.org.uk.