WHITE CUBE PRIVACY NOTICE
INTRODUCTION
Direct Interactions
Most of the personal data we process about you comes directly from you (whether face to face, over the telephone, on a paper form, by email or online).
For example, we collect data from you directly:
Your image may be collected by White Cube if you attend our premises; in particular, we use CCTV on our premises, including in our gallery spaces, for the security of our staff, our visitors and the artworks that we exhibit and sell. We may also have staff photographers documenting events.
Collection from other sources
We may also obtain information about you and/or the artworks that you own or wish to buy or sell or collect from other third party sources; for example:
We may receive:
We also collect, use and share aggregated data, such as statistical or demographic data, for any purpose (Aggregated Data). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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.
Automated Interactions
As you interact with our website, we may automatically collect technical data about your equipment, browser type, time zone settings, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We use this information for our internal system administration, to administer our website, and to monitor and improve the user experience.
We will only use your personal data when the law allows us to do so.
Most commonly, we will use your personal data in the following circumstances:
The Glossary contains more information about the legal grounds for processing.
We have set out below the types of personal data that we process, the reason for doing so and the legal grounds for processing.
Purpose: To add you to our database or register you as a new client
Type of data: Name, title, and contact details (including email address, postal address, telephone numbers)
Legal grounds for processing:
Performance of a contract (e.g. where performing the contract we are about to enter into with you (upon a sale) will require your contact data to be added to our records)
Legitimate Interests (in the event that you provide us with a business card at an event such that you want us to record your details on our database)
Consent (in the event that you express an interest in White Cube or one of our artists’ artworks and agree to being added to our database)
Purpose: To provide you with requested goods or services (for example, sales, storage, shipping, loans, insurance)
Type of data:
Name, title, and contact details (including email address, postal address, telephone numbers)
Your bank account details (if we need to pay you) or payment card details or bank transfer receipt (if you need to pay us)
Information about the person or organisation who has introduced you, and any fee they receive
Details of the artwork to which a transaction relates
Details of the nature of the services including contractual terms
Legal grounds for processing: Performance of a contract
Purpose: To evidence our compliance with legal requirements (for example, knowing our clients and preventing money-laundering, payment of taxation and customs duties, anti-discrimination)
Type of data:
Your date of birth, identification documents (including photo) and the results of identification verification checks
Records of your past transactions (including any tax paid or tax withheld) and/or shipments (including any permits obtained or duties paid)
Information about any requirements relating to White Cube’s obligation to make reasonable adjustments to accommodate a disability or otherwise meet your specific needs
Any information relating to a dispute or legal proceedings
Legal grounds for processing: Compliance with a legal obligation
Purpose: To photograph and film White Cube’s exhibitions and artist performances
Type of data: Images and footage of you
Legal grounds for processing: Legitimate Interests
Purpose: To keep you, our staff, and artworks on our premises secure
Type of data: CCTV images
Legal grounds for processing: Legitimate Interests
Purpose: To provide you with details about White Cube, its upcoming exhibitions, other events or works that may interest you
Type of data:
Name, title, and contact details (including email address, postal address, telephone numbers)
Artistic data such as information about artistic preferences and collections;
Your marketing and communication preferences
Legal grounds for processing:
Legitimate Interests (for clients who have previously requested or received services)
Consent (for clients who have not previously requested or received services but have asked online, at an event, or when talking to a member of staff, to receive information from White Cube)
Purpose: To create and maintain records on artworks to assist with checks on authenticity, provenance and title and to prevent fraud, theft or other unlawful activities
Type of data:
Information about your interest in, possession of, or ownership (historic or current) of any relevant artwork
Allegations of fraud, theft or other unlawful activities relating to an artwork connected to you
Communications with the police, courts, regulators or other government or law enforcement authorities in relation to you or your artwork
Legal grounds for processing:
Legitimate Interests
Compliance with a legal obligation
Public interest
Purpose: To collect and recover money owed to us
Type of data:
Name, title, and contact details (including email address, postal address, telephone numbers)
Details of the property to which the debt relates
Financial data
Legal grounds for processing: Legitimate Interests (in recovering debts due to us) and performance of a contract
Purpose: To monitor your use of our services, train our staff and improve your client experience and to manage and develop our relationship with you
Type of data:
Name, title, and contact details (including email address, postal address, telephone numbers)
Your expressions of interest in artists and artworks
Offers of artworks made and your responses
Details of purchases you have made
Information relevant to your opinions and preferences and your collecting habits, which may inform what works to offer to you
Legal grounds for processing: Legitimate Interests. As a business, we have a legitimate interest in holding information about clients as relationships often develop over many years and your experience with us is improved if we retain records which help us to understand you and your preferences, including how those may have developed over time.
Purpose: To host and entertain you at our events
Type of data:
Name, title, and contact details (including email address, postal address, telephone numbers)
Information about those you wish to accompany you to White Cube events
Any dietary requirements (allowing us to ensure that our events are tailored to your needs)
Any details which require us to make specific arrangements for your comfort and enjoyment of our events
Your personal preferences
Your expressions of interest in artists and artworks
Any offers of artworks made and your responses
Details of purchases you have made
Records of invites issued to you and details of your attendance at other events
Legal grounds for processing:
Legitimate Interests. As a business, we have a legitimate interest in holding information about clients to ensure that you have the very best experience possible at our events.
Purpose: To arrange your attendance at external events, such as art fairs and events which we host / co host
Type of data:
Name, title, and contact details (including email address, postal address, telephone numbers)
Information about those you wish to accompany you
Any dietary requirements
Legal grounds for processing:
Legitimate Interests (where you have indicated that you wish to attend an external event, such as an art fair, we have a legitimate interest in sharing your name and contact details with the organiser of that event)
Purpose: To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting)
Type of data: Information about your computer and your usage of our website
Legal grounds for processing:
Legitimate Interests (in running our business, provision and administration of IT services, network security)
Within the White Cube Group
Your personal data will be processed by the company within the White Cube group that initially receives it, and may also be transferred to and processed by other companies within the White Cube group. White Cube uses EU Commission approved standard contractual clauses to regulate the transfer and processing of data between group companies
Outside the White Cube Group
We do not transfer your personal data to organisations who wish to use it for their own marketing promotions or other purposes.
We will transfer your personal data to other organisations where it is necessary to enable us to provide you with the services you have requested. For example, we may transfer your data to our bank, payment card acquirers, shippers, warehouses, insurers, experts who help us with artworks (such as conservators), photographers, professional advisers, regulatory bodies, event venues, including art fairs (where you wish to have a pass), and caterers and direct marketing fulfilment and distribution. Where we do so it will be on the basis that these organisations are required to keep the information confidential and secure, and they will only use the information to carry out the instructed services. Some of these organisations may be located outside the EEA and you should refer to the section “Is your personal information transferred out of the EEA?” for more information.
We may also need to keep and disclose certain information about you to appropriate agencies to conduct anti-money laundering and trade sanction checks and to assist with fraud and crime prevention and detection.
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 third parties 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.
In the case of clients, we may share a copy of your invoice for a particular artwork with the artist who made it for their provenance records.
In the course of our normal business, White Cube may transfer your personal data outside of the EEA to White Cube offices and representatives and to other organisations who need to process your data in connection with the services that White Cube provides to you (see the section “Who sees your personal information?”).
Non-EEA countries offer varying standards for the protection of personal data and your privacy rights and in some cases these standards are lower than equivalent EEA standards. When we send your personal data outside the EEA, we seek to put in place the EU Commission-approved standard contractual clauses in the form of an appropriate data transfer agreement. If you have any questions or would like further information about how we make personal data available to non-EEA countries please contact us.
We use appropriate technical and organisational measures to protect the security and integrity of your personal information.
Although we have in place modern security systems and procedures, we cannot guarantee the complete security of personal data held in our systems, nor that that information you supply through the internet or any computer network is entirely safe from unauthorised intrusion, access or manipulation during transmission. Any transmission is at your own risk and we will not be liable for any resulting misuse of your personal data.
As well as your subject access right, you may have the right to have your personal data rectified or deleted, to object to its processing or have its processing restricted. You may also 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 commonly used, machine-readable format.
You may withdraw consent at any time where we are relying on consent to process your personal data.
Please contact us at dataprivacy@whitecube.com if you would like to exercise any of the rights set out above in relation to your personal data.
No fee usually required
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.
What we may need from you
Should you want to exercise your right to access your personal data (or to exercise any of your other rights) we may need to request specific information from you to help us confirm your identity. 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 you for further information in relation to your request to speed up our response.
Time limit to respond
We try 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.
If you have a query or complaint in relation to White Cube’s processing of your personal data, please contact us at dataprivacy@whitecube.com. You may raise a complaint with the UK Information Commissioner (https://ico.org.uk/) or your local regulator if you consider that we have infringed applicable data privacy laws when processing your personal data. However, we would appreciate the chance to deal with your concerns before you approach the ICO or your local regulator, so please contact us in the first instance.
Compliance with a legal obligation - processing is necessary to ensure we comply with our legal and regulatory obligations.
Consent – you have given specific consent to the processing of your personal data.
Data Controller – the person who determines the purposes and means of processing personal data.
EEA – the European Economic Area which comprises countries that are members of the European Union and Norway, Iceland and Liechtenstein.
Legitimate Interests - processing is necessary for our legitimate interests in carrying on, managing and administering our business effectively and properly and giving our clients the best service possible. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of a contract – processing is necessary to carry out our contractual duties, exercise our contractual rights or otherwise perform our contract with you, or to take steps at your request to enter a contract.
Personal Data - any data relating to an identified or identifiable natural person.
Processing - any operation performed on personal data, such as collection, recording, storage, retrieval, use, combining it with other data, transmission, disclosure or deletion.
Public Interest – processing is necessary for the performance of a task carried out in the public interest.