Privacy and Cookies Policy

Secret Trading Company Limited, trading as ‘Rastall Art’ (“We”) are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Secret Trading Company Limited, Manor Lane, Cheltenham, GL52 9QX.

Information we may collect from you

We may collect and process the following data about you:

  • Information you give us. You may give us information about you by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, search for a product, place an order on our site, and if you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information.

  • Information we collect about you.  For each of your visits to our site we may automatically collect the following information:

    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Anti-Money Laundering Legislation

On 10th January 2020 the UK government introduced a new Anti-Money Laundering legislation which requires art galleries to conduct stricter due diligence on buyers who purchase works of art above a threshold of €10,000 (about £8,500).

We are legally obliged to carry out identification checks before the conclusion of any sale over this threshold. We will also request identification on collection and delivery of the works.

For individual buyers, we are required to verify the buyer’s full name, date of birth, nationality and permanent address; we will need to hold copy of a valid government-issued photo ID such as a passport or driving license.

The information you provide will be processed by us in accordance with Global Data Protection Regulations.

Cookies

This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser.

For detailed information on the cookies we use and the purposes for which we use them, in relation to our hosting provider Squarespace, please refer to our Cookie Information Sheet.

  • Cookies deployed by our website:

    • ensure that functionality operates as intended

    • remember your choices and preferences during and between visits

    • allow you to share pages via popular social media networks including Facebook and Instagram

    • allow you to interact with our website by leaving comments or opinions

    • post enquiries via online forms

    • track your visit for statistical analysis, allowing us to improve the usability, speed and security of our website

  • Cookies are not deployed to:

    • collect any personal identifiable information (without your express permission)

    • collect any sensitive information (without your express permission)

    • pass data to advertising networks

    • pass personally identifiable data to third parties

Your consent for cookie deployment by our website.

Upon your first visit to our website, you may have noticed our banner alerting you to the use of cookies by our website. In compliance with the 2011 EU Cookie Law, our website operates on an ‘Implied Consent’ basis. This means that we have assumed that you have ‘opted-in’ for our website to deploy cookies until you choose to deactivate them within your browser settings or via the instructions below. For more information on the EU Cookie Law in the UK, you can visit the Information Commissioner’s Office (ICO) website where you can find the latest information, guidelines and advice on the EU Cookie Law.

How to disable cookies

Most modern browsers allow you to control your cookie settings for all websites that you browse. You can disable cookie deployment completely by editing your browser settings, however in doing this you may be limiting the functionality that is displayed on our website. We suggest consulting the help section of your browser.

Uses made of the information

We use information held about you in the following ways:

  • Information you give to us. We will use this information:

    • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and products that you request from us;

    • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;

    • to provide you with information about art and exhibitions that we feel may interest you. If you do not want us to use your data in this way, please contact us;

    • to ensure that content from our site is presented in the most effective manner for you and for your computer.

  • Information we collect about you. We will use this information:

    • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

    • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

    • to allow you to participate in interactive features of our service, when you choose to do so;

    • as part of our efforts to keep our site safe and secure;

    • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

    • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Disclosure of your information

Who may we disclose your personal information to:

  • You agree that we may share your personal information with:

    • our business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, for example we engage third parties to process card payments, deliver our products, provide our Website, to send you marketing and surveys (through our use of third parties such as Survey Monkey) and for data analysis;

    • other professional advisers (including accountants and lawyers) that assist us in carrying out our business activities;

    • police and other law enforcement agencies in connection with the prevention and detection of crime;

    • other external agencies and organisations (including the National Crime Agency) for the purpose of preventing and detecting fraud (including fraudulent transactions), money laundering and criminal activity; and

    • third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or instructions of a regulatory body (including in connection with a court order), or in order to enforce or apply the terms of any agreements we have with or otherwise concerning you (including agreements between you and us) or to protect our rights, property or safety of our clients or other third parties.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

How long will we keep your personal information

  • We will keep your personal information for a period of up to 7 years after you provide your information to us, subject to the following exceptions:

    • records of any incidents, injuries or accidents when visiting us: 4 years from the date of the accident, injury or incident is recorded by us; and

    • we will keep your marketing preferences for as long as you wish to receive marketing communications from us.

For further information as to our retention periods, please contact us.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

You can exercise your right to prevent such processing by contacting us at simon@rastall.art.

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.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

Changes to our privacy and cookies policy

Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcome and should be addressed to simon@rastall.art.

Effective 01 February 2023