Privacy Policy

Glum Tortoise Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you. 


This policy applies to information held about clients and prospective clients, suppliers and prospective suppliers, artists, contacts and all other persons about whom Glum Tortoise Limited holds information. By 'information,' we mean personal information about you that we collect, use, share and store.


It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. 


This policy aims to give you information on how Glum Tortoise Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you visit the website, purchase a product, give us your details at our events, art fairs and exhibitions, provide a service to us, correspond with us by phone, email or other means, or apply to work with us.


This website is not intended for children and we do not knowingly collect data relating to children. 



Glum Tortoise Limited is the controller and responsible for your personal data.


In this policy, 'we', 'us' and 'our' means Glum Tortoise Limited, a company registered in England and Wales with No. 12550687 and 'you' means the individual to whom the information relates.


We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out in the Complaints section below.  


What we collect and Purposes for Which We Will Use Your Personal Data 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 


We may collect, use, store and transfer different kinds of personal data about you, as follows:


Type of data


Lawful basis for processing including basis of legitimate interest

Personal data such as name, address, email address and telephone number

To communicate with you generally, for example, regarding events or via marketing emails and newsletters

Necessary for our legitimate interests, i.e., to make sure you receive updated information on our business activities, and for our own marketing and research

Storing choices visitors make about how it should function

To improve our site's functionality and to keep it safe and secure 


Necessary for our legitimate interests, i.e., to collect personal information to provide you with a smooth and efficient client experience





To process and deliver your order including:

  • Manage payments, fees and charges

  • Collect and recover money owed to us

Performance of a contract with you

Necessary for our legitimate interests, i.e. to recover debts due to us


  • your name;

  • your contact information such as your address, email address and telephone number;

  • information about you that you give us in person at our events, art fairs and exhibitions, or by corresponding with us by phone, e-mail or otherwise;

  • information in relation to your interest in artworks displayed on the website

  • Information from applications submitted to Glum Tortoise Limited

  • anonymous data that can improve the user experience

  • storing choices visitors make about how it should function


We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.


How we collect information about you 

  • we collect information you provide to us in person, or in writing or via email;

  • we collect information you give us when you purchase any art work

  • through cookie notifications banners on our website


What we do with the information we collect

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • provide information to you about works sold through Glum Tortoise Ltd. 

  • to carry out our obligations arising from any agreements entered into between you and us;

  • to communicate with you generally

  • keep our site safe and secure;

  • comply with legal and regulatory obligations


Legal basis for processing

We process your personal information:

  • where we need to perform the contract we are about to enter into or have entered into with you; 

  • for the purposes of legitimate interest pursued by us (or those of a third party), and your interests and fundamental rights do not override those interests; or

  • in order to comply with a legal obligation to which we are subject.


Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.


Legitimate interests 

Where our processing is based on the legitimate interest grounds described above, those legitimate interests are: 

  • collecting personal information to provide you with a smooth and efficient client experience; 

  • to make sure you receive updated information on our business activities; 

  • to provide the services you have requested; and

  • for our own marketing and research.


Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.


Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.


If You Fail to Provide Personal Data 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.


Change of Purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.


If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


Sharing Your information 

Except as expressly set out in this policy we will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.


The personal information you provide to us may be shared with third-party companies, agents, contractors, service providers or affiliated companies if this is necessary to provide you with our services, respond to your inquiries or for any of the purposes described in this policy.


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 third-party 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.


There are playlists embedded on our website provided by Spotify. A direct link will be created between your browser and Spotify’s servers if you access a page on our website that contains a Spotify plug-in. If you do so, Spotify will receive information that you accessed our website from your IP address. If you have a Spotify account, these data could be linked to your account. If you do not wish these data to be linked to your Spotify account, you must log out of Spotify before visiting our website. Interactions will also be forwarded to Spotify. Please see Spotify’s Privacy Policy for more information:


There are also videos provided by on our website, which belongs to Google. These videos are stored at and can be played directly from our website. These videos are all embedded such that no data relating to you as a user will be transmitted to YouTube if you do not play the videos. Only if you play the videos will the data be transmitted and YouTube will receive information that you visited the corresponding webpage. This will take place irrespective of whether YouTube provides a user account to which you are logged in or no such user account exists. If you are logged into Google, your data will be directly linked to your account. If you do not wish the information to be linked to your YouTube profile, you must log out of YouTube before visiting the corresponding page on our website. YouTube stores the data relating to you as usage profiles and uses them for advertising, market research and/or needs-based design purposes. This kind of analysis is conducted in particular in order to provide needs-based advertising (even for users who are not logged in) and in order to inform other users of the social network of your activities on our website. For more information on the purpose and scope of data collection and its processing by YouTube, please see Google’s Privacy Policy:


We may also share your personal information with:

  • law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and

  • other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.


Transferring your information outside the UK

Your personal information may be transferred to, and stored at, a destination outside the UK or the European Economic Area ("EEA") including the US and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers.


When we, or our permitted third parties, transfer your information outside the UK/EEA, we/they will impose obligations on the recipients of that data to protect your information to the standard required in the UK and EEA or otherwise require the recipient to subscribe to international frameworks intended to enable secure data sharing. 


In the case of transfers by us, we may also transfer your information where: (i) the transfer is to a country deemed to provide adequate protection of your information by the UK European Commission; or (ii) where you have consented to the transfer.


Should you wish to have further information on international transfers, please contact us on the details provided in the Complaints section below.


Your Rights

You have the following rights under data protection laws in relation to your personal data: 

  • to request access to or a copy of any personal data which we hold about you;

  • to request erasure of your personal data if certain conditions apply;

  • to rectification of your personal data, if you consider that the information we are holding is inaccurate;

  • to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);

  • to ask us to stop or start sending you marketing messages as described below in the marketing section;

  • to request the transfer of your personal data to you or to a third party;

  • to request the restriction of processing of your personal data;

  • and to object to your personal data being processed in certain circumstances.


Any request from you for access to/a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.


How long we will keep the information

We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject.


This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.


Where we are permitted to send you direct marketing communications we may retain your contact information necessary for this purpose, for as long as you do not unsubscribe from receiving the same from us. If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.



We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.


Links to Other Sites

Our website may contain links to other websites, plug-ins and applications, including via our social media buttons. Clicking on those links or enabling those 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. Once you link to another website from our website you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices, so we encourage you to read the privacy policy of every website you visit. 


While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website.



Questions, comments and requests regarding this policy are welcomed and should be addressed to


If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner's Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113 or via their website at ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 


Changes to This Policy and Your Duty to Inform Us of Changes 

We keep our privacy policy under regular review. This policy was last updated on: 06/05/2022


Any changes we make to our policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our policy.


We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change at the following email address



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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.


A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.


Glum Tortoise uses cookies to facilitate and improve your experience of our website and to provide and improve our products and services. By using the Glum Tortoise website users may also receive certain third-party cookies on their computer or device. Third party cookies are those placed by websites, services, and/or parties. Glum Tortoise uses third party cookies on the website. In addition, our website uses analytics services provided by Google, YouTube and Spotify, which also use cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, to have a better understanding of the people using the website. 


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