Privacy Policy
March 2024

My contact details:
Name: Dawn Owen. I am the owner of Clebran Art and clebran.com
Address: Copley, Welland Road, Hanley Swan, Worcestershire. WR8 0DA
Phone Number: 01684 252112 E-mail: dawn@clebran.com

Your acceptance of this Privacy Notice
Dawn Owen provides this Privacy Notice as the data controller of your data. By using my website and services I will process your personal data in the ways set out in this notice. If you do not agree with me using your personal data in such ways please do not use my website or services.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases I rely on for processing this information are:
(a) Your consent. You are able to remove your consent at any time. You can do this by contacting dawn@clebran.com
(b) Clebran has a contractual obligation.
(f) Clebran has a legitimate interest. (future provenance/prevention of forgery or fraudulent copies/breach of copyright)

Personal data
Personal data is any information about a living individual that can be used to, either directly or indirectly, identify them. It includes information such as: their name, address, email address, photographs.
The type of personal information collected
I currently collect and process the following information:
• Personal identifiers, contacts and characteristics (for example, name and contact details).
• Customer financial information.
• Photographs sent to me by the person who has bought an item from me or from the recipient of an item bought from me.

How I get the personal information and why I have it
Most of the personal information I process is provided to me directly by you for one of the following reasons:
• You are buying artwork or an item from me.
• You want to be kept informed of new artworks for sale.
• You are considering commissioning an artwork from me.
• You want to provide feedback or a testimonial about one of my artworks.
I also receive personal information indirectly, from the following sources in the following scenarios:
• People who are buying art from me for another person and wish for the item to be sent directly to that person (for example, as a surprise gift).

Processing
• When I refer to processing your personal data I mean any activity I perform on or with it. This includes: collecting it; recording it; storing it; changing it; deleting or destroying it; or any other use of it. I only process your personal data consistently with my obligations under the General Data Protection Regulation and Data Protection Act 2018.
• I am the data controller of your data. This means I decide why and how I process your personal data. I will only use the information that I collect about you lawfully. I do not sell or rent your information to anyone.
I use the information that you have given me in order to:
• Communicate with you about the item you are buying from me.
• Communicate with you about commissioning an artwork from me.
• Take/receive payment for the item you are buying from me.
• Mail the item to the delivery address you have provided.
• Send you updates of new artworks/items you may be interested in.
• Display your feedback/testimonial on my website clebran.com or on my social media sites.
• Maintain a record for provenance purposes – this is the name and address of the purchaser (along with the name of the painting bought, how much they paid, the date they bought it).*
I do not share this information with any third party organisations unless legally obliged to do so or if I have your explicit consent to share.

How I store your personal information
Your information is securely stored on a password protected computer. It may also be stored on my password protected mobile device (phone or tablet) in the form of emails/texts/messages that have been exchanged between you and me.
I also store the name and address of those who buy artworks from me, this information is held in a physical logbook.

Retention periods:
With regard to general enquiries – your data is securely erased when the communication between you and I is complete. This includes name, address, email address, telephone number and/or any other personal information you share with me.
With regard to the personal data of people who buy my artwork:
Electronic/computer records:
I keep the name, address, payment details, email address, telephone number, and delivery address for a maximum of 12 months from the date the artwork/item has been paid for and delivered. The electronic records are then securely erased from my computer/phone/tablet, including email folders and back up folders.
Hard copy/paper records:
I keep the Name and Address of the purchaser for life. This is recorded in a physical logbook that is kept in a locked cabinet.

Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact me at dawn@clebran.com, 01684 252112 if you wish to make a request.

How to complain
If you have any concerns about my use of your personal information, you can make a complaint to us at dawn@clebran.com, 01684 252112.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk