SOMLO (“WE/US/OUR”) ARE COMMITTED TO PROTECTING AND RESPECTING YOUR PRIVACY.
This policy (together with any privacy notice displayed on www.somlo.com (“our site”) or otherwise notified to you) sets out the basis on which we will process any personal data we collect from you or that you provide to 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 General Data Protection Regulation (2016/679) (“GDPR”) the data controller is Somlo Antiques Limited, 20 Harcourt Street, London, W1H 4HG.
We will, in processing your data, comply with the GDPR and all other data protection and privacy laws applied in England from time to time.
Data Protection Registration Number ZA4484095
INFORMATION WE MAY COLLECT FROM OR ABOUT YOU
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.
- We may collect and process the following data about you: Information that you provide by filling in enquiry forms on our site or other electronic means, by telephone or by visiting our store or attending our events. This includes information provided at the time of registering to use our site, subscribing to our service or requesting further services or searching for a product. We may also keep the information you give us, as well as other information, which include your name, address, e-mail address, phone number, financial and credit card information.
- The website is not intended for children and we do not knowingly collect or store any personal information relating to minors, aged 16 years or under.
- Details of transactions you carry out through our site, at our store or by other means, the fulfilment of your orders and any subsequent communications regarding your purchase.
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Closed circuit television recordings within our stores for safety and security purposes.
To understand how we use these types of data, please see “How We Use Data About You” below.
We do not routinely collect any “special categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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. If we need to process any such data for a particular purpose, we will explain this to you at the time and will gain your consent to such processing.
We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration and to analyse our customer base by aggregating such data into anonymised reports. We may report this aggregated information to our advertisers as statistical data about our users’ browsing actions and patterns, but this anonymised data does not identify any individual. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
HOW WE PROCESS DATA ABOUT YOU
The Company will only process your personal data in accordance with legal obligations in each instance. We will use your personal data in the following circumstances, relying on the basis of processing as indicated:
Where we need to perform the contract, we are about to enter into or have entered into with you.
- To provide you with information, products or services that you request from us (contact details).
- To carry out our obligations arising from any contracts entered into between you and us (contact details, payment information and any information relating to personalisation or relationship status).
Where it is necessary for our legitimate interests (or those of a third party) and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.
- To ensure that content from our site is presented in the most effective manner for you and for your computer (online identifiers (including cookies), location data and other technical information).
- To provide you with information, products or services that we feel may interest you, (where you have consented to be contacted for such purposes to the extent consent is required by law) (contact details and any information relating to personalisation preferences or relationship status).
- To allow you to participate in interactive features of our service, when you choose to do so (online identifiers(including cookies), location data and other technical information).
- To notify you about changes to our service (contact details).
- To maintain a basic amount of information about you and your purchase history, in order to provide you customer service tailored to your tastes and any special occasions/anniversaries of which we may be aware (contact details, payment history and any information relating to personalisation or relationship status).
Where we need to comply with a legal or regulatory obligation.
- To retain basic transaction details for the purpose of tax reporting (contact details and transaction history).
Where you have consented to the processing.
- To send you direct marketing communications via email or fax (contact details). You have the right to withdraw consent to any such use at any time by contacting us.
WHAT DATA WE COLLECT
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis, we are relying on to process your personal data. 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. Please contact us if you would like further details of any additional purposes of processing. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
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). If this happens, we may have to cancel any order you have placed to buy goods and we may be unable to offer any services.
Please note that we may process your personal data without your knowledge or consent where required or permitted by law.
If you provide us with any personal data relating to relatives, partners or other individuals it is your duty to make such persons aware that their personal data may be shared with us and to provide them with appropriate information about how their personal data may be processed by us.
We will not retain your data for longer than necessary for the purposes set out in this policy. We generally keep your data so we can:
- Respond to any questions, complaints or claims by you or on your behalf;
- Show you are treated fairly;
- Keep records required by law;
- Prevent fraud;
- Comply with our regulatory requirements;
All information you provide to us is stored on our secure servers or, where purchases are made over the counter, in hard copy at our stores until electronic records can be made (when hard copies will then be securely destroyed). Any online payment transactions will be encrypted and carried out through our appointed agent through a secure site. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site on a secure basis, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
In summary your data will be retained as follows:
- Enquiries will be retained for 12 months
- Customer information for up to 7 years as/or required to meet our legal obligations
DATA SECURITY AND SAFEGUARDS
Information may be held at our offices and third-party agencies, service providers, representatives and agents.
We have put in place appropriate security measures intended to prevent your personal data from being lost or from being altered, disclosed, used or accessed in an unauthorised way. In addition, we 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 they are subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features designed to prevent unauthorised access.
We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will also keep a record of your name and email address on our suppression list if you request that we do not send you direct marketing. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, whilst we retain transaction details only for so long as legally required, we may retain certain basic details on a longer-term basis to ensure we can offer you a consistent level of customer service tailored to your preferences when you start thinking about your next investment. Other enquiries and CV applications will be stored for six months after which they will be securely destroyed. Details of retention periods for different aspects of your personal data are available on request. In some circumstances you can ask us to delete your data: see below for further information.
We may sometimes anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
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 or the security of these websites. Please check the relevant policy before you submit any personal data to these websites.
Under current legislation you may be entitled to the listed rights in certain circumstances, you have rights under data protection laws in relation to your personal data, as summarised below.
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables 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. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may 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 for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (of our own or of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our data representative as shown below. 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 you have made a number of requests. In this case, we will notify you and keep you updated.
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.
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 has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.
QUERIES AND COMPLAINTS
We have appointed a "Data Protection Officer" who is responsible for overseeing questions in relation to this privacy notice. If you have any questions or comments about this privacy notice, including any requests to exercise your legal rights, they should be addressed to :
Name: Mr Paul Symons
Address: Somlo Antiques Limited, 35 – 36 Burlington Arcade, London, W1J 0QB
Telephone: 020 7499 6526
If you feel we have failed to address your concerns appropriately, you can contact the Information Commissioner at www.ico.org/concerns or by telephone: 0303 123 1113 to obtain further information about your rights and how to make a complaint.
This Policy was last updated on the 17th November 2020