Privacy Policy
Introduction
ÉPOQUE Privacy Policy
CONTENTS
- Important information and who we are
- The types of personal data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
- Contact details
- Complaints
- Changes to the privacy policy and your duty to inform us of changes
- Third-party links
Important information and who we are
ÉPOQUE Privacy Policy
This privacy policy gives you information about how ÉPOQUE collects and uses your personal data through your use of this website, including any data you may provide when you register with us, sign up to our newsletter, and/or purchase/subscribe to a product or service.
This website is not intended for children, and we do not knowingly collect data relating to children.
Controller
ÉPOQUE, through Contemporary Art Services Limited, is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the information set out in the contact details section.
The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data: includes first name, last name, username or similar identifier, title, date of birth, and gender.
- Contact Data: includes billing address, delivery address, email address, and telephone numbers.
- Financial Data: includes bank account and payment card details.
- Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data: includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID, and other technology on the devices you use to access this website.
- Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data: includes information about how you interact with and use our website, products, and services.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use, and share aggregated data such as statistical or demographic data, which is not personal data as it does not directly (or indirectly) reveal your identity.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Your interactions with us: You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion, or survey; or
- give us feedback or contact us.
- Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
- Third parties or publicly available sources: We will receive personal data about you from various third parties as set out below:
- Technical Data is collected from:
- analytics providers such as Google;
- advertising networks;
- search information providers.
- Contact, Financial, and Transaction Data is collected from providers of technical, payment, and delivery services.
- Technical Data is collected from:
How we use your personal data
Legal basis: The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and give you the best and most secure customer experience.
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.
Purposes for which we will use your personal data: We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so.
| Purpose/Use | Type of Data | Legal Basis [and Retention Period] |
|---|---|---|
| To register you as a new customer | Identity, Contact | Performance of a contract with you |
| To process and deliver your order | Identity, Contact, Financial, Transaction, Marketing and Communications | Performance of a contract, necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you | Identity, Contact, Profile, Marketing and Communications | Performance of a contract, necessary to comply with a legal obligation, necessary for our legitimate interests |
| To enable you to partake in a prize draw, competition, or survey | Identity, Contact, Profile, Usage, Marketing and Communications | Performance of a contract, necessary for our legitimate interests (to study how customers use our products/services) |
| To administer and protect our business and this website | Identity, Contact, Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security), necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity, Contact, Profile, Usage, Marketing and Communications, Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences | Technical, Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Service providers: Third parties who provide IT and system administration services, payment processing services, and other administrative services.
- Professional advisers: Third parties including lawyers, bankers, auditors, and insurers.
- Regulators and other authorities: Third parties including HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data within the ÉPOQUE Group, including the COMPANY. This may involve transferring your data outside the UK to our overseas offices in Gibraltar.
We may also transfer your personal data to service providers that perform certain functions on our behalf. This may involve transferring personal data outside the UK to countries that have laws which do not provide the same level of data protection as UK law.
Whenever we transfer your personal data outside of the UK to service providers, we ensure a similar degree of protection by implementing the following safeguards:
- We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We also limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have procedures in place to handle any suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes for which we collected it, including for legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period if we believe there is a prospect of litigation related to our relationship with you.
To determine the appropriate retention period for personal data, we consider factors such as the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your data, and whether we can achieve those purposes through other means, as well as applicable legal, regulatory, tax, accounting, or other requirements.
In some circumstances, you can ask us to delete your data; see paragraph 9 below for further information.
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "subject access request"). This allows you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data we hold about you. This allows 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 in certain circumstances. This allows you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to request deletion or removal of your personal data where you have successfully exercised your right to object to processing (see below), where we 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 for erasure due to specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for processing your data (including profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your right to object.
- You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 4 for details on how to object to receiving direct marketing communications).
- Request the transfer of your personal data to you or to a third party. We will provide your personal data in a structured, commonly used, machine-readable format to you or a third party you have chosen. 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.
- Request restriction of the processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- 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
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to continue processing it.
If you wish to exercise any of the rights set out above, please contact us using the details in paragraph 10.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it. We may also contact you to request further information to expedite our response.
Time limit to respond
We aim to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made several requests. In such cases, we will notify you and keep you updated.
If you have any questions about this privacy policy, the use of your personal data, or if you wish to exercise your privacy rights, please contact us using the following methods:
- Email address: support@epoque.club
- Postal address:
30/3 Cornwalls Lane
Gibraltar
GX11 1AA
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to address your concerns before you approach the ICO, so please contact us first.
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, such as a new address or email address.
This website may include links to third-party websites, plug-ins, and applications. Clicking on these links or enabling these connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.