Maddox Gallery Limited trading as Maddox Gallery (‘We’, ‘us’ or ‘our’) takes the privacy of our website users and customers seriously. We are committed to protecting and respecting your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR).

We ask that you carefully read this Privacy Policy (the ‘Policy’), together with our terms of use and any other documents referred to in it, as these documents set out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us. For the purposes of UK data protection law, we are the ‘controller’ of the personal data you provide to us.

Who We Are

This website is owned and operated by Maddox Gallery Limited trading as Maddox Gallery, a company registered in England and Wales with Company Number 09604183 and whose registered office is at 9 Maddox Street, London, W1S 2QE. We are registered as a data controller with the UK Information Commissioner’s Office (ICO) under registration number ZB869996.

Our Privacy Policy 

Introduction

1.1 We are committed to safeguarding the privacy of our website visitors, customers and service users. In this policy we explain how we will collect, use, store and share your personal data, and your rights in relation to that data. This policy is provided in a layered format so you can easily navigate to the specific areas set out below.

1.2 This policy applies to personal data collected through our website, in the course of our business operations, and through any other interactions you may have with us. Where we rely on consent as a lawful basis for processing (including in relation to cookies), you may withdraw that consent at any time as set out in this policy. 

How we use your personal data

2.1 In this Section 2 we have set out: 

(a) the general categories of personal data that we may process; 

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; 

(c) the purposes for which we may process personal data; and 

(d) the legal bases of the processing. 

2.2 We may process data about your use of our website and services (‘usage data’). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system and cookies (see Sections 14–17 below). This usage data may be processed for the purposes of analysing the use of the website and services. The lawful basis for this processing is our legitimate interests, namely monitoring and improving our website and services.. 

2.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The lawful basis for this processing is the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, and our legitimate interests, namely the proper administration of our website and business. 

2.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, interests and hobbies, and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services, and for personalising your experience. The lawful basis for this processing is the performance of a contract and our legitimate interests, namely the proper administration of our website and business. To the extent that profile data includes special category data (such as data revealing racial or ethnic origin, political opinions, or health data), we will only process such data with your explicit consent. 

2.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include both company and personal information. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The lawful basis for this processing is the performance of a contract and our legitimate interests, namely the proper administration of our website and business.

2.6 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.7 We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The lawful basis for this processing is your consent. You may withdraw your consent at any time by contacting us using the details set out in Section 18 below. 

2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The lawful basis for this processing is your consent. You may unsubscribe from our marketing communications at any time by clicking the ‘unsubscribe’ link in any marketing email, or by contacting us using the details in Section 18 below. 

2.9 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users. 

2.10 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. 

2.11 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 

2.12 Please do not supply any other person’s personal data to us, unless we prompt you to do so. 

Automated decision-making

3.1 We may use your personal data for the purposes of automated decision-making in relation to our website and our marketing and sales processes, including profiling. 

3.2 This automated decision-making will involve marketing personalisation across our website and other marketing communications such as email. 

3.3 The significance and possible consequences of this automated decision-making are that you are likely to receive a personalised experience with content and marketing assets tailored to your browsing behaviour and expressed preferences. You have the right to object to profiling for direct marketing purposes at any time (see Section 9 below). Where any automated decision-making produces legal effects or similarly significantly affects you, you have the right to obtain human intervention, to express your point of view, and to contest the decision. 

Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy. Each group company that receives your personal data will be either a joint controller or a processor, and appropriate arrangements are in place to govern such sharing.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes. 

4.3 We may disclose personal data to our suppliers or subcontractors insofar as reasonably necessary for them to provide services on our behalf. These parties act as data processors and are bound by written contracts including obligations of confidentiality and data security. 

4.4 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4.6 We will not sell your personal data to any third party. We will only share your personal data with third parties for the purposes described in this policy or where we are required to do so by law. 

International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom.

5.2 We and our other group companies have offices and facilities in other jurisdictions. Where we transfer personal data outside the United Kingdom, we ensure that an appropriate transfer mechanism is in place, such as: (a) a transfer to a country that has been deemed to provide an adequate level of protection by the Secretary of State under Section 17A of the Data Protection Act 2018 (an ‘adequacy regulation’); (b) the use of the UK International Data Transfer Agreement (IDTA) or the International Data Transfer Addendum to the EU Standard Contractual Clauses, as approved by the ICO; or (c) another appropriate safeguard recognised under Article 46 UK GDPR.

5.3 The hosting facilities for our website are situated in the United Kingdom, Germany and the United States of America. Transfers of personal data to Germany are covered by the UK adequacy regulations for EEA countries. Transfers to the United States are covered by the UK Extension to the EU–US Data Privacy Framework, or alternatively by the UK IDTA or the UK Addendum to the EU Standard Contractual Clauses. 

5.4 Certain of our marketing and sales subcontractors may be situated outside the United Kingdom. Where this is the case, transfers will be protected by the appropriate safeguards described in paragraph 5.2 above.

5.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.  

Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data, and with the data minimisation principle.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 

6.3 Unless a longer retention period is required or permitted by law, your personal data will be retained for no longer than 3 years following the date and time of your last interaction with our website or business, at the end of which period it will be securely deleted from our systems. We will conduct periodic reviews of the data we hold to ensure that it continues to be necessary for the purposes for which it was collected. 

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria: 

(a) the period of retention of personal data will be determined based on your interaction with our website or business. 

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 

Security of personal data

7.1 We will take appropriate technical and organisational measures to secure your personal data and to prevent the unauthorised or unlawful processing of, accidental loss of, destruction of, or damage to your personal data. 

7.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems. 

7.3 The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data. 

7.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology. 

7.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. 

7.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website). 

7.7 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO without undue delay and, where feasible, within 72 hours of becoming aware of the breach. 

Amendments

8.1 We may update this policy from time to time by publishing a new version on our website. We will notify you of any significant changes to this policy by email or by a prominent notice on our website prior to the changes taking effect. 

8.2 We recommend that you check this page periodically to ensure you are informed of any changes to this policy. The date of the most recent update is noted at the top of this policy. 

8.3 Where changes to this policy materially affect the way in which we process your personal data, we may seek your consent to those changes where required by applicable law. 

Your rights

9.1 Under UK GDPR, you have a number of rights in relation to your personal data. These rights are summarised below. For detailed information, please refer to the ICO’s website at https://ico.org.uk. 

9.2 You have the right to request access to the personal data we hold about you (a ‘subject access request’). We will respond to your request without undue delay and in any event within one month of receipt. This period may be extended by a further two months where necessary, taking into account the complexity and number of requests. We will provide a copy of your personal data free of charge; however, we may charge a reasonable fee for further copies or for requests that are manifestly unfounded or excessive. 

9.3 We may request proof of your identity before responding to a subject access request, to ensure we do not disclose personal data to an unauthorised person. 

9.4 We may withhold personal information that you request to the extent permitted by law, including where disclosure would adversely affect the rights and freedoms of others. 

9.5 You may instruct us at any time not to process your personal information for marketing purposes. 

9.6 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes. 

9.7 In this Section 9, we have summarised the rights that you have under UK data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant legislation and guidance from the Information Commissioner’s Office for a full explanation of these rights. 

9.8 Your principal rights under data protection law are: 

(a) the right to access; 

(b) the right to rectification; 

(c) the right to erasure; 

(d) the right to restrict processing; 

(e) the right to object to processing; 

(f) the right to data portability; 

(g) the right to complain to a supervisory authority; and 

(h) the right to withdraw consent. 

9.9 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipients of the personal data, and the envisaged retention period. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data free of charge. Additional copies may be subject to a reasonable administrative fee. 

9.10 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. 

9.11 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. 

9.12 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. 

9.11 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. 

9.12 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. 

9.13 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest. 

9.14 To the extent that the lawful basis for our processing of your personal data is consent or the performance of a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. 

9.15 If you consider that our processing of your personal information infringes UK data protection laws, you have a legal right to lodge a complaint with the Information Commissioner’s Office (ICO). You can contact the ICO at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; or via the ICO website at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to address your concerns before you contact the ICO, so please contact us in the first instance.

9.16 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

9.17 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 9. 

Third party websites

10.1 Our website includes hyperlinks to, and details of, third party websites. 

10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties. 

Personal data of children

11.1 Our website and services are targeted at persons over the age of 18. We do not knowingly collect or process personal data from children under the age of 13 (being the age at which a child may give their own consent to the processing of their personal data under UK law.

11.2 If we have reason to believe that we hold personal data of a person under the age of 13 in our databases, we will take reasonable steps to delete that personal data without undue delay.   

Updating information

12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

Acting as a data processor

13.1 In respect of payment data we do not act as a data controller; instead, we act as a data processor.

13.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller. 

About cookies

14.1 A cookie is a small file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. We also use similar technologies such as pixels, web beacons and local storage, which function in a similar way (collectively referred to as ‘cookies’ in this section for convenience).

14.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 

14.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 

Cookies that we use

15.1  We use cookies for the following purposes: 

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website. 

(b) status – we use cookies to help us to determine if you are logged into our website; 

(d) personalisation – we use cookies to store information about your preferences and to personalise our website for you; 

(e) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally; 

(f) advertising – we use cookies to help us to display advertisements that will be relevant to you; 

(g) analysis – we use cookies to help us to analyse the use and performance of our website and services and 

(h) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Cookies used by our service providers

16.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website. 

16.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. We have configured Google Analytics to anonymise IP addresses where possible. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. Google Analytics cookies are non-essential cookies and are only placed on your device with your consent. 

16.3 We use HubSpot to report on and manage website activity. This service uses cookies for tracking activity across our site. HubSpot cookies are non-essential cookies and are only placed on your device with your consent. You can view the privacy policy of this service provider at https://legal.hubspot.com/privacy-policy. 

Managing cookies

17.1 When you first visit our website, we will ask you to consent to our use of non-essential cookies. You can manage your cookie preferences at any time using our cookie consent tool or by adjusting your browser settings. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en. (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences. (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/. (Opera); 

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies. (Internet Explorer); 

(e) https://support.apple.com/kb/PH21411. (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge). 

17.2 Blocking all cookies will have a negative impact upon the usability of many websites. If you block strictly necessary cookies, you may not be able to use all the features on our website.

Our details

18.1 This website is owned and operated by Maddox Gallery Limited.

18.2 We are registered in England and Wales under registration number 09604183, and our registered office is at Elsley Court, 20-22 Great Titchfield Street, London, W1W 8BE 

18.3 Our principal place of business is at 9 Maddox Street, London. W1S 2QE 

18.4 You can contact us: 

(a) by post, using the postal address given above; 

(b) using our website contact form; 

(c) by telephone, on the contact number published on our website from time to time; or 

(d) by email, using the email address published on our website from time to time. 

Data protection registration and supervisory authority

20.1 We are registered as a data controller with the UK Information Commissioner’s Office (ICO). The ICO is the UK’s independent supervisory authority for data protection. You can contact the ICO at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; telephone: 0303 123 1113; website: https://ico.org.uk.

20.2 Our data protection registration number is ZB869996. 

Representative within the European Union

21.1 To the extent that we are subject to the EU General Data Protection Regulation (EU GDPR) by virtue of offering goods or services to individuals in the European Union, our representative within the European Union with respect to our obligations under EU data protection law is Nick Sharp. You can contact our EU representative by email at info@maddoxgallery.com. 

Data protection officer

22.1 Our data protection officer’s contact details are: info@maddoxgallery.com. You may contact our data protection officer with any questions or concerns about our processing of your personal data, or to exercise any of your rights under this policy.