Glum Tortoise Limited respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, share, and store your personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as amended by the Data Protection and Digital Information Bill (pending enactment).
Scope
This policy applies to clients, galleries, suppliers, artists, and other contacts whose personal data we process in the course of our business operations, including interactions via our website, exhibitions and communication channels.
Glum Tortoise Limited upholds the rights of the data subject to information, access, rectification, erasure (right to be forgotten), the restriction of processing, data portability, the right to withdraw consent, to lodge a complaint, and to object to automated decision making and profiling.
Controller
Glum Tortoise Limited (company no. 12550687), registered in England and Wales, is the controller responsible for your personal data. If you have any questions about this policy or your rights, please contact our Data Privacy Manager at studio@jadefadojutimi.com.
Data We Collect
We collect and process personal data such as your name and address, contact details, professional information, payment information (if necessary for payment purposes to fulfil a contractual or statutory obligation), and correspondence we have with you. We also collect a minimum of data automatically through cookies and analytics tools when you use our website.
Lawful Basis for Processing
We process your personal data under one or more of the following lawful bases: (a) to perform a contract or terms of engagement with you; (b) to comply with legal obligations; (c) for our legitimate interests in managing and promoting our business; and (d) archiving information received by Glum Tortoise Limited from third party galleries for reasons of provenance.
How We Use Your Personal Data
We use your data to manage relationships, provide services, process payments, communicate about artworks, maintain website security, and meet our legal obligations.
Cookies and Tracking Technologies
We use cookies to enhance your experience and analyse site usage. Non-essential cookies are only used with your consent, as required by the UK Privacy and Electronic Communications Regulations (PECR). You can manage your cookie preferences through our cookie banner or your browser settings.
Automated Decision-Making and Profiling
No profiling or automated decision making is undertaken by Glum Tortoise Limited
International Data Transfers
Where we transfer data outside the UK, we ensure it is protected by adequate safeguards in accordance with UK data protection law. This includes using adequacy regulations issued by the UK Government or standard contractual clauses.
Data Retention
Glum Tortoise Limited stores, retains, and disposes of personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. As a company, we work to ensure that personal data is retained only for as long as necessary and is securely deleted or anonymised when no longer required. Glum Tortoise Limited retains data to comply with legal or regulatory requirements, operational or business needs, contractual obligations and for provenance reasons.
We periodically review our retention periods to ensure compliance.
Data Security
Once we have received your information, we will store it in electronic and at times physical records maintained by us; occasionally the data will be transferred to third parties to comply with business needs. We implement appropriate technical and organisational measures to protect your personal data against loss, misuse, unauthorised access, alteration, or disclosure. These measures include access controls, password and authentication requirements, encryption of personal data in transit and at rest, and regular monitoring of our systems. Only staff who need access to your information to perform their duties are permitted to handle it. We also review our security practices regularly to ensure they remain effective and in line with UK GDPR requirements.
Your Data Protection Rights
You have the right to: (a) access and obtain a copy of your data; (b) correct inaccurate data; (c) request erasure; (d) restrict processing; (e) object to processing; (f) data portability; and (g) withdraw consent at any time. Requests can be made to studio@jadefadojutimi.com.
Complaints
If you have concerns about how we process your data, please contact us first at studio@jadefadojutimi.com.. You may also complain to the UK Information Commissioner’s Office (ICO) at www.ico.org.uk or via 0303 123 1113.
Updates to This Policy
We keep this policy under regular review and may update it to reflect changes in law or our practices.