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PRIVACY POLICY
Sixteen Online is committed to protecting your privacy and security. This policy explains how and why we use your personal data so that you understand and remain in control of the data we process and the information we hold about you. To find out more about the General Data Protection Regulation (GDPR) in the UK and what this means for you, then click here.
About Us
​Sixteen Online is an online artist database that helps, emerging and established artists, connect directly with art buyers by creating a searchable community of personalised profiles. Sixteen Online is a trading name operating under Sixteen Gallery Ltd which is a private limited company registered in England & Wales Number 13411912. The official address of Sixteen Gallery Ltd is 16 Rotunda Terrace, Montpellier Street, Cheltenham, Gloucestershire GL50 1SW.
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Policy Overview
​When we talk about “we” or “us” in this privacy policy we mean Sixteen Online. When we talk about “you” or “you’re” in this policy we mean any living person whose personal data we collect. When we talk about “Members” we are referring to those persons or bodies of artists who have a fully paid membership and use the site to display their artworks.
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1. Defining "personal data"
​The definition of “personal data” is information that identifies a living person, or which can be identified as relating to a living person.
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1.1 The personal data we hold.
​We hold the following categories of personal data:
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2. Personal data you provide.
We collect data you provide to us. This includes information you give when you communicate with us, subscribe to our newsletter, purchase services, for employment or are members of Sixteen Online. For example, we may hold:
- personal details (name, email, address, telephone etc.).
- family and spouse/partner or next of kin details if you are employed by us.
- financial information (such as credit/debit card or direct debit details).
- your response to a Sixteen Online event or your intention to use the site to display your work and how you wish to be contacted.
- your Bio or information about you, your history, your practice, methods and approach
2.1 Personal data generated by your involvement with the Sixteen Online database
Your activities and involvement with Sixteen Online will result in personal data being generated.
This could include:​
- details of your areas of interest in the work online.
- your attendance at special events e.g., Private Viewings.
- where you have asked us for information or emailed us.
- links to our websites.
- your purchasing history.
- where you have applied for a job with us.
2.2 Personal data from third parties
We sometimes receive personal data about you from third parties, for example, if we are partnering with another organisation or where we may use third parties to help us conduct research and analysis about you to determine the success of our marketing and to help us provide you or exhibitors with a better experience which can sometimes mean new personal data is created. We may collect information from social media about you, or if you post on any of our social media pages.
​3. How personal data is used.
Information about the legal basis for using personal data under current regulation
is consent, contract, legal obligation, and legitimate interest.
3.1 General use
We only ever use your personal data with your consent, or where it is necessary in order to:
- enter, or perform, a contract with you.
- comply with a legal duty.
- protect your vital interests.
- for our own (or for a third party’s) legitimate interests, provided your rights do not override these interests.
We will only use your personal data for the purpose or purposes for which it was obtained.
​3.2 Marketing
We use your personal data to promote our activities and events. This includes keeping you up
to date with, events and products available at Sixteen Gallery or as a member of Sixteen
Online.
3.3 Administration
We use your personal data for administrative purposes including:
- processing enquiries and requesting information.
- managing feedback, comments and complaints we receive.
- fulfilling orders for services (whether placed online, over the phone or in person).
- helping us respect your choices and preferences.
- recruitment and staff management including pay, tax and pensions administration.
- management of suppliers of goods and services.
- managing your use of Sixteen Online.
3.4 Internal research and profiling
We may evaluate, categorise and profile your personal data in order to tailor materials, services and communications (including targeted advertising) to your needs and your preferences and to help us to better understand our audiences.
​4. How personal data is shared
​4.1 Sale of data
We will never sell your personal data.
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4.2 Selected Partners
If you have opted-in to marketing, we may contact you with information about our selected partners. These communications will always come from us and will usually be incorporated into our own marketing (e.g., Information about local Picture Framing companies).
​4.3 Suppliers of services
We may share your personal data with contractors or suppliers who provide us with services. For example, we use Direct Debit processors for the handling of payments and email providers for our marketing communications. Information is transferred to data processors securely, and we retain full responsibility for your personal data as the data controller.
​4.4 Sharing of data (other)
Occasionally we share data when we arrange events with other organisations, for example when you register an interest or would like to attend a private viewing, we will share your data with the exhibitor. We will only share information when necessary.
​4.5 Sharing data with regulators or other legal bodies
We may share your personal data where required to do so for prevention of crime or for taxation purposes (for example, with the police, HMRC) or where otherwise required to do so by other regulators or by law.
​5. How we use personal data for marketing
5.1 Consent
Unless you have given us your email address or telephone number so that we can tell you about the events and services we provide we will ask you to “opt-in” to receive marketing emails from us. You have the choice as to whether you want to receive or continue to receive these messages. You can change your preferences at any time by emailing enquiries@sixteengallery.com. When you receive a communication from us, we may collect information about your response to be more effective about how we communicate with you in the future.
5.2 Newsletters
We will use your personal data to send you the Sixteen Gallery newsletter (unless you specifically ask us not to) and you can choose to unsubscribe from this and other general marketing communications by emailing enquiries@sixteengallery.com.
​6. How your personal data is protected
​6.1. Protection
​We employ a variety of physical and technical measures to protect information we hold and to prevent unauthorised access to or use or the disclosure of your personal data. Electronic data and databases are stored on secure computer systems, and we control who has access to information (using both physical and electronic means).
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6.2 Payment security
All electronic payments to Sixteen Gallery Ltd are securely processed.
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7. Where we store your personal data
​7.1 Location of storage
We are wholly based in the UK and store data within the European Economic Area. Some organisations which provide data processing services to us do so under contract and may be based outside of the EEA. We will only allow them to do so if your data is adequately protected.
​7.2 Retention of your personal data
We will only retain your personal data for as long as it is required for the purposes for which we collected it (e.g., we have a genuine and legitimate reason and we’re not harming any of your rights and interests). This will depend on our legal obligations and the nature and type of information and the reason for which we collected it. For example, should you ask us not to send you our newsletter, we will stop storing your email address for marketing purposes; however, we may keep a record of your preference.
We will regularly review what information we hold and will delete personal data which is no longer required.
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8. If you would you like to change how we handle your personal data
8.1 Your rights
​We want to ensure you remain in control of your personal data and that you understand your legal rights, which are:
- the right to know whether we hold your personal data and, if we do so, to be sent a copy of the personal data that we hold about you (a “subject access request”) within one month.
- the right to have your personal data erased (unless we need to continue storing your data for a lawful reason).
- the right to have inaccurate personal data rectified.
- the right to object to your personal data being used for marketing or profiling; and
- the right to be given a copy of personal data that you have provided to us.
There are some exceptions to the rights above and, although we will always try to respond to any instructions you may give us about our handling of your personal data, there may be situations where we are unable to meet your requirements in full. Should you wish to make a "subject access request" you can do so by emailing enquiries@sixteengallery.com. Please also use this address if you would like to make a request for your data to be erased.
9. If you have a complaint
9.1 Where to send your complaint.
Should you have a complaint about how we have used (‘processed’) your personal data, you can complain to us directly by ailing enquiries@sixteengallery.com.
9.2 Where to escalate your complaint.
If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK.
​10. How we manage cookies
Our websites use local storage (such as cookies) in order to provide you with the best possible experience and to allow you to make use of certain functionality. Before accessing the site, we will always ask you to accept or reject the use of cookies for any other use e.g., for the purpose of marketing analytics.
11. Links to other sites on our website
11.1 Links
Our website contains links to other external websites. We are not responsible for the content or functionality of any such websites.
​11.2 Third Parties
If a third-party website requests personal data from you (e.g. in connection with membership fees or services), the information you provide will not be covered by this privacy policy. We suggest you read the privacy notice of any other website before providing any personal information.
​12. Changes to Sixteen Online's privacy policy
12.1 Updates
We may amend this privacy policy from time to time to ensure it remains up-to-date and continues to reflect how and why we use your personal data. The current version of our privacy policy will always be posted on our website.
12.2 Questions about our policy
Any questions you may have in relation to this privacy policy or how we use your personal data should be sent to Sixteen Gallery Ltd T/A Sixteen Online, 16 Rotunda Terrace, Montpellier Street, Cheltenham, Gloucestershire GL50 1SW.
13. Specific Use of Personal Data
​13.1 Membership of Sixteen Online
We store the personal data you join as a member of Sixteen Online. Data is accessible via password protection to Sixteen Gallery. The legal basis for this is to fulfil a contract, to ensure that you correctly receive the service you have requested. We will use your data to ensure that we continue to provide the service and sales analysis, using legitimate interest as a legal basis. With your consent we will email you regarding special promotions.
​​13.2 Signing up to an e-newsletter.
If you choose to subscribe to our newsletters, we store the personal data you provide in this transaction. The legal basis for this data storage is consent, which you provide by checking the tick box when going through the sign-up process. Once this is completed, your personal data is accessible to a limited number of Sixteen Online staff responsible for the newsletter, is password-protected. You have the right to withdraw your consent by unsubscribing, with opt-out offered in each email. Sixteen Online will keep your data unless you unsubscribe.
13.3 Completing an exit survey.
Occasionally we may request members not choosing to renew to complete an exit survey. Responses to questions collated by Sixteen Online are then used by Sixteen Online and Sixteen Gallery Ltd to improve the services provided. The data will be only used for this purpose and then deleted when the review is concluded.
13.4 Working for Sixteen Online.
The personal data you provide to become employed by Sixteen Online (and during your
employment) includes special category data such as health records. It is stored in a restricted access physical filing system. It is used for the purpose of administration, management and compliance with applicable laws and regulations. The information will be held for as long as you are employed and for 6 years afterwards.
13.5 Applying for a job.
The personal data you provide in order to apply for a job is stored in a restricted access physical filing system and used for the purposes of shortlisting and interviewing. The information will be deleted six months after the deadline for that job. The legal basis for this is to fulfil a contract.
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