FAS Edinburgh
PRIVACY POLICY

FAS EDINBURGH LTD

The Fine Art Society in Edinburgh is the trading name of FAS Edinburgh Ltd, registered in Scotland No. 63978. FAS Edinburgh Ltd is the Data Controller for the purpose of compliance under the Data Protection Act 1998, the Privacy and Electronic Communication (EC Directive) Regulations 2003 and the EU General Data Protection Regulation FAS Edinburgh Ltd can be contacted at our Registered Office: 6 Dundas Street, Edinburgh, EH3 6HZ.

FAS Edinburgh Ltd is a wholly owned subsidiary of the Fine Art Society Plc based in London. We deal in Fine Art, specialising in Scottish Artists from 1700 to the present day, antiques and books, rent exhibition space and through our division FAS Frames and Conservation, undertake framing and picture conservation for the public together with related services.

FAS Edinburgh Ltd is committed to ensuring that your privacy is protected and complies with its statutory obligations. Should we ask you to provide certain information by which you can be identified when using this website and our services, then you can be assured that it will only be used in accordance with this privacy statement. We may update this privacy policy when our safeguards change and we recommend you check this page regularly. The current policy is effective from 25th April 2018.

WHAT INFORMATION WE COLLECT
We collect information from you where we have a legal basis for doing so, such as to fulfil a contract or because you have given your consent to the sharing. We will always explain to you our purpose for collecting the information at the point of collection and will let you know if our purposes change.

Information you give us
We may collect personal information which we receive when you make a purchase or use our services or contact us to make an enquiry or to access information. We may collect your personal data to inform you of the various products and services we offer.
The information you give us may include:
• your name, title, address, e-mail address, telephone number(s) and other contact details
• information required to provide you with a service and details of the service used (e.g. your preferences and interests)
• your Company’s name, your position in the Company, the Company’s address, e-mail address and telephone number
• your payment information such as credit card, debit card or bank account details required to complete and process your order
• information collected through your transactions and use of our services
• details of any enquiry or complaint you make
• your communication preferences

Information we collect about you
Each time you visit our website, we may automatically collect the following information:
• technical information, including the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; browser version; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. This information may be collected by placing Cookies on your computer. Please see below for more information about the way we use Cookies.

Information we receive from other sources
• You interact with our social media channels. We only receive personal information that you share with us voluntarily and that is comparable with your privacy settings. To find out more about how these social media companies process your personal information we recommend that you read their Privacy Policies.
• We may also receive information from our parent company The Fine Art Society plc, our division FAS Frames and Conservation, or other third parties for marketing or accounting purposes when you have given consent.

WHAT WE DO WITH THE INFORMATION WE COLLECT
Information you give to us
We may use this information:
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, goods and services you request from us
• to provide you with information about other goods and services we offer similar to those you have already purchased or enquired about
• to notify you about changes to our service
• to ensure content we present on our website or through advertising materials is presented in the most effective manner for you
• to provide marketing information to you and for the purposes of customer support, billing and for auditing services
• improve and develop our services
• protect security e.g. to check your identity when you use our services
• meet our legal and regulatory obligations

Information we collect about you
We may use this information:
• to make suggestions and recommendations to you and other clients about goods or services which may interest you or them
• to measure or understand the effectiveness of marketing we serve to you and others, and to deliver relevant marketing to you
• improve and develop our services
• protect security e.g. to check your identity when you use our services
• meet our legal and regulatory obligations

Information we receive from other sources
We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

WHEN WE MAY DISCLOSE YOUR INFORMATION TO OTHERS
We may share your personal information with any member of our group, which means our parent company The Fine Art Society Plc and our division FAS Frames and Conservation, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you. This includes shipping and postal services for the delivery of purchases.
• Subcontractors for the fulfilment of our own marketing. This includes printing and postal services to deliver our material, our website host and mailing list provider to facilitate the sending of online market for which the recipient has given express consent.
• Analytics and search engine providers who assist us in the improvement and optimisation of our website.
• Other Third Parties (including the police, law enforcement agencies, credit reference and fraud prevention agencies and other bodies) to protect our or another person’s rights, property, or safety e.g.
o To exchange information to protect against fraud against FAS Edinburgh Ltd, third parties and customers, and to reduce payment risks
o In connection with the prevention and detection of crime
For the purposes of identification
o To prevent money laundering

We may disclose your personal information to third parties:
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• 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 website’s terms of use or our terms and conditions of supply and other agreements; or to protect our rights, property, or safety or that of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
• checking details on applications for credit and credit related or other facilities
• managing credit and credit related accounts or facilities
• recovering debt
• checking details on proposals and claims for all types of insurance
• checking details of job applicants and employees

We and other organisations may access and use from other countries the information recorded by fraud prevention agencies. Please see below for details of how to contact us if you wish to access your personal information or details of relevant fraud prevention agencies.

MARKETING
You may allow FAS Edinburgh to provide you with information about products and services that we, or The Fine Art Society Plc has selected, which may be of interest to you. We will only do this where a customer has agreed to receive such information. You agree to receive marketing information:
• by requesting to be added to our mailing list by completing the form available in our gallery, by emailing us, or via the form on our website.
• by opting to receive information upon making, or negotiating for, the purchase of a product or service.
You may select the marketing channels to be used when we collect your details which may include all means of communication e.g. email, post, phone, SMS text message and other electronic means.
If you wish to change your marketing preferences, please contact us as advised below.

HOW DO WE USE COOKIES
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 website.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We may use this information to tailor future modifications to our website, and make our website more relevant to your interests.
Please note third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You may block cookies by activating the setting on your browser which allows you to refuse the placing of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

WHERE WE STORE YOUR PERSONAL DATA
The data 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 suppliers, including our website host and mailing service. Such staff maybe engaged in, among other things, the shipment of items you purchase, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure your data is treated securely and in accordance with this privacy policy. FAS Edinburgh will only retain customers’ personal information for as long as we need it to carry out a particular purpose or meet a particular obligation.

SECURITY OF YOUR INFORMATION
FAS Edinburgh Ltd is committed to keeping customers’ personal information secure to protect it from being inappropriately or accidentally accessed, used, shared or destroyed, and against it being lost. Our computer systems are professionally maintained and security is regularly updated to prevent unauthorised access to the systems. We operate CCTV coverage in the gallery for the protection of our staff. Unfortunately, as you will be aware, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

LINKS TO OTHER WEBSITES
Our website, or postal and email marketing we send, may include links to other sites. We will make every effort to provide links to high quality, reputable sites but are not responsible for their privacy practices, site content, or the services they offer. Please check these policies before you submit any personal data to these websites.

ACCURACY OF INFORMATION
FAS Edinburgh will ensure that personal information is kept accurate and up to date as far as is reasonably possible. However, we rely on our clients to ensure that some of the information we hold about them is accurate and up-to-date. We encourage clients to tell us of any changes to their information.

YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.
Under the EU General Data Protection Regulation. You have the right to revoke or amend any consent you have provided allowing us to store and use your personal data. You can also exercise your data rights at any time by contacting us at art@fasedinburgh.com

ACCESS TO INFORMATION
The Data Protection Act 1998 and the EU General Data Protection Regulation give you the right to access information held about you. Application must be made in writing and can be sent either by e-mail or post. Proof of identification is required together with sufficient details for us to be able to locate the information such as date of purchase, item bought, invoice reference.

CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our privacy 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 privacy policy. This privacy policy was last updated 25 April 2018.

CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Gallery Manger.
Please write to:
The Gallery Manager, FAS Edinburgh Ltd, 6 Dundas Street, Edinburgh EH3 6HZ
Email: art@fasedinburgh.com
Telephone: 0131 557 4050

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