Privacy and Data Request Policy

This policy applies to information held about our customers, clients and prospective customers and clients, suppliers and prospective suppliers, artists, contacts, and all other persons about whom Turbare Limited holds information. By ‘information,’ we mean personal information about you that we collect, use, share and store.

In this policy, “we,” “us,” and “our” means Turbare Limited, a company registered in England and Wales with registration number 12625772, registered at 35/37 Ludgate Hill, London, EC4M 7JN and “you” means the individual to whom the information relates.

Information we collect about you:
• Your name;
• Your contact information such as your address, email address and telephone number;
• Your payment details and financial data, including your bank name, account number and sort code;
• Your IP address, browser type and language;
• Information related to your attendance of and interest in our events;
• Information about you that you give us in person at our events by filling in forms on our site www.turbare.com (e.g. to sign up to our mailing list) or by corresponding with us by phone, e-mail or otherwise;
• Information in relation to your purchase of our artwork or use of our services.

How we collect information about you:

We collect information about you when you:
• create an account on our website;
• purchase any artwork;
• browse our website;
• use any forms on our website;
• give feedback to us or contact us by phone, e-mail or otherwise;
• attend our events or participate in our marketing campaigns;
• sign up to receive updates, newsletters or marketing communication from us; or
• when you or your organisation offer to provide, or provides, products and/or services to us.

How we use your personal information:

We may use the personal information we hold about you:
• to register you as a new customer and update our customer records;
• to register you as a new supplier and update our supplier records;
• to process and deliver the agreed products and services to you, including sending you updates and managing payments, fees and charges;
• to manage your subscriptions and user accounts;
• to deal with and respond to requests, enquiries and complaints;
• to ask you to provide feedback, leave a review or take a survey;
• to provide information about our artwork and services to you;
• to send you information about and to enable you to participate in events (including online events) organised by us (with or without another party), including seminars and training; leisure, sports and/or charity events; prize draws and competitions; and surveys, marketing campaigns, market analysis or other promotional activities;
• to communicate with you and to keep you up-to-date on the latest developments, announcements, and other information about our services and solutions (including briefings, newsletters and other information), events and initiatives;
• to promote (including by delivering advertisements) and to make suggestions and recommendations to you (including by email or when you visit our website) about products and services that may be of interest to you, as well as to personalise content you see on our website, and to measure and analyse the effectiveness of the promotions and suggestions we serve you;
• to carry out our obligations arising from any agreements entered into between you and us;
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to keep our site safe and secure;
• to comply with legal and regulatory obligations;
• for managing your statutory rights;
• establishing, exercising and/or defending our legal rights; and
• for ensuring security of your personal data and to check your identity.

Legal basis for processing

Our processing of your personal information is necessary:
• For the performance of contracts to which you will be a party to and in order to take steps at your request prior to you entering into those contracts;
• For the purposes of legitimate interests pursued by us;
• In order to comply with a legal obligation to which we are subject.

We do not generally process 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). If we decide to collect this information about you, we will generally rely on obtaining specific consent from you at the time unless there is otherwise a legal requirement for us to process such information.

Legitimate interests

Where our processing is based on the legitimate interest grounds described above, those legitimate interests are:
I. collecting personal information to provide you with a smooth and efficient client experience;
II. to make sure you receive updated information about our business activities;
III. to provide the services you have requested;
IV. for our own marketing and research.

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or information about new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will not sell your personal information to or share it with other organisations for marketing purposes, except where we remain the controller of your personal information and share it with third parties who act as a data processor on our behalf and only process the personal information on our instructions and for the purposes set out above.
You have the right to opt out of receiving promotional communications at any time by:
a. contacting us at info@turbare.com;
b. using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts; or
c. updating your marketing preferences in your user profile on our website.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

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 artwork or services, respond to your inquiries or for any of the purposes described in this policy.
We may also share your personal information with:
I. credit reference agencies who may, for example, supply anti-fraud and credit-insight information to us;
II. social media companies and our advertising partners, for example, we might match your email address with Facebook and Twitter to enable us to run promotions on their platforms;
III. our professional advisors such as our lawyers, accountants or auditors when they need to give us their professional advice;
IV. law enforcement agencies, other governmental agencies or third parties if we are required by law to do so;
V. 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.

International transfers of your information

If, to deliver our services to you, it is necessary for us to share or transfer your personal information outside the European Economic Area (EEA), then some additional safeguards will apply.
Where we need to make a transfer of this nature, we will only do so if such a transfer is safe and your personal information will be secure.
This means that when we transfer your personal information outside the EEA we will only do so where (i) there are Binding Corporate rules in place; or (ii) the country where are are making the transfer to is a country deemed by the European Commission to have an adequate level of protection in place for your personal information; or (iii) if there is no adequacy decision, where we have contractual arrangement with the service provider containing protections for your personal information (the EU Commission approved Standard Contractual Clauses, for example) or (iv) where the service provider is part of an approved scheme (Privacy Shield, for example).
Please contact us if you want further information on the mechanisms used by us when transferring your personal information out of the EEA.

Your Rights

At any time, you have the right:
I. To request access to or a copy of any personal data which we hold about you;
II. To request rectification of your personal data, if you consider that the information we are holding is inaccurate;
III. To ask us to delete your personal data, if you consider that we do not have the right to hold it;
IV. To withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
V. To ask us to stop or start sending you marketing messages as described below in the marketing section;
VI. To restrict processing of your personal data;
VII. To data portability (moving some of your personal data elsewhere) in certain circumstances; and
VIII. To object to your personal data being processed in certain circumstances;
IX. To not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

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

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 info@turbare.com.

How long will we keep your 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.

Security

We have put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed unlawfully, altered or disclosed. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Links to Other Sites

Our website may contain links to other sites, including our social media buttons. 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.
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. Please check these policies before you submit any data to these websites.
Certain features of our site will allow for social networking. You should ensure when using these features that you do not submit any personal data that you do not want to be sent, collected or used by other users, such as profile details or e-mail address.

Complaints

Questions, comments and requests regarding this policy are welcomed and should be addressed to info@turbare.com
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.

Changes to this policy

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.

How to contact us

If you have any questions about this privacy policy or our privacy practices, please contact us using the contact details set out below.

Contact details:

Email address: info@turbare.com
Postal address: Turbare, 35/37 Ludgate Hill, London, EC4M 7JN, United Kingdom