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We appreciate you visiting our website – wills-art.com (the "Site") owned and operated The Affordable Art Fair Ltd. (“Affordable Art Fair,” “we,” “us,” or “our”). We are committed to protecting your privacy and we’ve created this Privacy Policy to let you know what to expect when you interact with us on the Site, and use our services (collectively, “Services”). This Privacy Policy may be updated from time to time and we will notify you of any material changes by posting the new Privacy Policy on the Site. We recommend you consult this policy regularly for any changes.

By accessing or using our Services in any way, you agree that your information may be collected, stored, shared, and used as described in this Policy and our Terms of Use. This Policy applies to all of our Services, regardless of how you use them. This Policy only applies to how we collect, store, share, and use information. This Policy does not apply to any entity that we do not own or control, or to any person that we do not employ or manage.

For the purpose of the Data Protection Act 2018 (the Act), the data controller is The Affordable Art Fair Ltd., a company registered in England and Wales. Our company number is 10081430 and our registered office is Sadler’s House, 180 Lower Richmond Road, London SW15 1LY. Our Data Protection Officer (DPO) is Ellen Dewerson. If you have any requests concerning your personal data or any queries with regard to how we handle your data you can contact the DPO by phone on +44 (0)117 954 4036, email privacy@affordableartfair.comor by post using the address above.

PROCESSING YOUR PERSONAL DATA

We collect information to improve, protect and customise our Site, Services, features and content, develop new Services and to enable you and other Users to enjoy and easily navigate the Site.

We collect personal data when you:

Fill in forms on our Site, including account creation, mailing list sign-up and
Correspond with us by phone, e-mail, and social media
Enter into a competition
Complete a survey
Agree to the use of Cookies and other web tracking tools,
Report problems or make a complaint

The information you give us may include:

Name, home address, e-mail address, telephone number, credit/debit card or other payment details;
Details of your preferences, opinions and lifestyle;
Information about your use of our website, events and services;
The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media.
Location, including real-time geographic location of your computer or device through GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, if you use location-based features and turn on the Location Services settings on your device and computer.

PURPOSE OF PROCESSING YOUR PERSONAL DATA

Activity	Purpose of processing	Lawful basis
Placing an order	Dealing with an order/ reservation/booking you place	Contract
	Internal accounting processes	Legal requirement
	Provide you with further information about our similar products and services	Legitimate interest
	Adding you to our mailing list	Consent
Registering for an event	Dealing with your request to attend an event	Contract
	Internal accounting processes	Legal requirement
	Providing you with information about our products and services	Legitimate interest
	Adding you to our mailing list	Consent
Making an enquiry	Dealing with your enquiries or requests	Legitimate interest
Making an enquiry	Providing you with information about our products and services	Legitimate interest
Browsing and searching our website	Personalising your visit by using cookies to recall your preferences and previous interactions with us	Consent
Completing a survey	Providing you with more relevant offers and information about our products and services	Legitimate interest
Completing a survey	Adding you to our mailing list	Consent
Entering a competition	Dealing with your entry and administering the competition	Contract
Entering a competition	Adding you to our mailing list	Consent
Website maintenance and security	Protecting your personal data and responding to threats and incidents	Legitimate interest

THE LEGAL BASIS ON WHICH WE RELY ARE:

LEGITIMATE INTERESTS

We rely on legitimate interests as a basis for processing including intra-group transfers and some of our marketing.

For example, if you are a previous customer, we may process your personal data to personalise your emails, or to update you about significant changes to our Services.

An intra-group transfer may occur with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We carefully weigh up our legitimate interests against your rights, taking into consideration your reasonable expectations, based on your relationship us. We will inform you of the processing activity and give you the option to opt out when you give us your data, or in our first communication with you.

For more information, you can request a copy of our Legitimate Interests Assessment.

CONSENT

We rely on consent as a basis for sharing your information for other organisations to use and for some of our marketing. For example, if we have no prior direct relationship with you as a customer, we will ask your consent before we send you emails.

Consent is based on genuine choice and will always be freely given, specific and fully informed.

CONTRACT

Where processing is necessary for us to carry out the pre-contract and contractual relationship between us, our customers and the suppliers we use to deliver our contracts.

MARKETING

We would like to use your personal data to send you details of products or services that we offer that we have identified as likely to be of interest to you. We will only send you information in line with the preferences you communicate to us.

If at any point you would like to opt-out of receiving communications from us, please use the Update Preferences in your emails from us, or contact info@wills-art.com.

RETENTION PERIODS

We will keep your personal data in connection with the services/products you have bought for 7 years after the last purchase. We need to retain this data for our own accounting purposes and for legal and tax purposes.

In terms of personal data we use for marketing, we will keep this data for as long as we are able to market to you and if you withdraw your consent or opt-out of marketing communications, we will keep your contact details only to ensure that we do not contact you again for marketing purposes.

Where we use consent or legitimate interest as the basis for direct marketing, we will take this to be valid for 2 years from the time of your most recent significant interaction with us, which may include registering for an event ticket, making a purchase through our website, or opening one of our marketing emails.

DATA SUBJECT’S RIGHTS

You have rights in respect of your personal data. If you wish to exercise any of these rights, we will need to confirm your identity before we can consider the request.

THE RIGHT TO BE INFORMED

You have the right to be told about the collection and use of the personal data you provide.

This privacy policy sets out the purpose for which we process your personal data, how long we will keep your data, who we will share your data with. If you have any questions on how and why we process your data please contact the DPO. If you want to know more about this right, the ICO has more guidance on their website:https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-be-informed/

RIGHT OF ACCESS

You have the right to know whether we are processing your personal data, and to a copy of that data. We would need as much information as possible to enable us to locate your data. We will respond to your request within 28 days of receipt of your request.

If you want to exercise this right, please contact the DPO at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/

RIGHT TO RECTIFICATION

You have the right to have any incorrect personal data corrected or completed if it is incomplete. You can make this request verbally or in writing. We will need as much information as possible to enable us to locate your data. We will look at any request and inform you of our decision within 28 days of receiving the request.

RIGHT TO ERASURE

This right, often referred to as the right to be forgotten, allows you to ask us to erase personal data where there is no valid reason for us to keep it. We will look at any request and inform you of our decision within 28 days of receiving the request.

RIGHT TO RESTRICT PROCESSING

You have the right to ask us to restrict processing of your data. We will look at any request and inform you of our decision within 28 days of receiving the request.

If you want to exercise this right, please contact the DP at the contact details above. If you want to know more about this right, the ICO has more guidance on their website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-restrict-processing/

RIGHT TO DATA PORTABILITY

You have the right to move, copy or transfer your personal data from one IT environment to another.

This right applies to data that you have provided to us and that we are processing on the legal basis of consent or in the performance of a contract and that processing is by automated means. We will respond to your request within 28 days of receipt of your request.

RIGHT TO OBJECT

You have the right to object to our processing of your personal data based on (1) legitimate interests, or for the performance of a task in the public interests/exercise of official authority (including profiling); (2) direct marketing (including profiling); and (3) for purposes of scientific/historical research and statistics.

Legitimate interests/legal task – your objection should be based on your particular situation. We can continue to process the data if we can demonstrate compelling legitimate grounds which override your interests.
Direct marketing – you have an absolute right to ask us to stop processing for the purposes of direct marketing. We will action your request as soon as possible.
Scientific/historical research and statistics - your objection should be based on your particular situation. If we are conducting research where the processing is necessary for the performance of a public task, we can refuse to comply with your objection.

RIGHTS RELATING TO AUTOMATED DECISION MAKING INCLUDING PROFILING

You have the right in respect of automated decision making, including profiling.

Where we carry out solely automated decision making, including profiling, which has legal or similarly significant effects on you, we can only do this if it is in connection with a contract with you, we have a right under law or you have provided your explicit consent. We will tell you if this happens and tell you how you can request human intervention or challenge the decision.

RIGHT TO WITHDRAW CONSENT

Where we process your personal data based on your consent you have the right to withdraw that consent at any time without reason.

You can opt-out by using the unsubscribe/opt-out in any marketing we send you and you can contact the DPO at the contact details above.

THE RIGHT TO LODGE A COMPLAINT

If you are unhappy with any aspect of our handling of your data you can make a complaint to the Information Commissioner’s Office - https://ico.org.uk/concerns/

THIRD PARTY WEBSITES

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

CHANGES TO THE PRIVACY POLICY

This privacy policy is regularly reviewed and will be updated when necessary. If we make any significant changes to the policy we will communicate these to you.