Privacy Notice – ODA ART LIMITED

1. INTRODUCTION AND GENERAL TERMS

ODA ART LIMITED NIGERIA, a company registered under company number 1855597 (“ODA ART GALLERY ”, “we”, “us” or “our” in this notice), forms part of an international commercial gallery which operates in Lagos Nigera. Where we decide the purpose or means for which personal information you supply is processed, we are the “data controller” i.e. the entity responsible for handling your personal information in line with the requirements of Nigeria data protection law.

If you have any questions or comments about this privacy notice, please contact us via:

Telephone: +234 9061816077 Email: info@odaartgallery.com:

ODA Art is committed to protecting and respecting your privacy. This privacy notice aims to make all those who interact with us, visitors, customers, supporters and suppliers, aware of the information that ODA Art Gallery may hold about you, how it uses it, and what associated legal rights you have.

We comply with General Data Protection Regulations (GDPR) when dealing with your personal data. Further details on GDPR can be found on the website of the Information Commission (www.ico.org.uk).

2. WHAT PERSONAL INFORMATION DOES ODA ART GALLERY COLLECT ABOUT ME?

We collect and process the following data from you which may include your personal information.

a. Information provided by you when using our Services

You may give us information about you by filling in forms when using or purchasing our Services, attending events and exhibitions, signing up to our newsletter or contacting us with enquiries. Such information may include any of the following:

1. Identity and contact data:including your name, username, address, telephone number and e-mail address; and

2. Profile Data: including artwork information, artworks owned, requested, offered, reserved, purchased, consigned and details of artwork invoices.

b. Payment Information

In order for you to use all the functions of our Services we may collect payment information from you including your credit card number and bank account details.

c. 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 information 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. For further details, please see more on cookies below.

ODA Art Gallery will collect information about you only insofar as this is lawful and appropriate for one or more of the purposes described in section 3 below.

3. WHERE DOES ODA ART GALLERY GET MY PERSONAL INFORMATION FROM?

ODA Art Gallery typically obtains the information directly from you for example:

• when you express an interest in buying or selling an artwork to one of our staff or representatives; • when you attend an event;
• when you purchase an artwork;
• when you subscribe to receive news about upcoming events;

• when you follow us on social media; or
• when you ask us to send you information including about artists and their works.

However, depending on your circumstances and relationship with the ODA Art Gallery, we may obtain it from a broad range of sources including:

• word of mouth
• when someone introduces you to us (e.g. because they believe an artist or work
may interest you)
• websites where you have made information about yourself publicly accessible e.g. Instagram and LinkedIn, art platforms, publicly available resources such as newspaper articles, exhibition catalogues, public auction results.

4. DOES ODA ART GALLERY USE YOUR PERSONAL INFORMATION FOR MARKETING PURPOSES?

We use various forms of marketing to provide you with promotional materials about our Services either because it is in our legitimate interests to do so e.g. where you have previously requested/received Services, or consent where you have not previously requested or received Services but have provided your details or asked to be contacted by the ODA ART Gallery.

ODA ART Gallery does not sell or rent your personal information to third parties for their own marketing purposes.

5. DOES ODA ART GALLERY DISCLOSE MY PERSONAL INFORMATION TO THIRD PARTIES?

We will share your personal information with ODA ART Gallery’s Nigerian affiliates e.g. for administrative ease and because they offer similar products and services to us so that you do not miss out on our global offerings and Services.

We also share your personal information with third parties “Data Processors” to carry work out on our behalf, such as to provide logistical support and payment processing services. Where relevant, we have and will put in place, appropriate contracts with them to require them to comply with data protection laws, to process only for the purposes we specify, and ensure they implement appropriate controls to keep your personal information secure. If you would like to find out more about how the third parties listed in this notice use your information, please refer to their respective privacy notices.

Campaign Monitor to assist with marketing emails.

6. COOKIES

We process cookies to understand how visitors use our website and to compile reports on website activity.

This processing is necessary for us to pursue our legitimate interest in improving our website and providing a more relevant service to our customers. This information is not used to develop a personal profile of you.

7. WHAT RIGHTS DO I HAVE CONCERNING MY PERSONAL INFORMATION?

You have the right to ask ODA ART gallery to:

(1) provide a copy of your personal information (subject to the data protection rights of other people), as well as the type of information provided in this privacy notice;

(2) correct any inaccuracies or incompleteness in your personal information;

(3) modify or withdraw your consent for the collection, use and disclosure of your personal information (see section 3e above);

(4) delete your personal information where there is no lawful justification for ODA ART Gallery to retain it;

(5) put the processing of your personal information on hold until ODA ART Gallery responds to a claim by you that the data is inaccurate or that ODA ART Gallery’s legitimate interests in processing it are outweighed by your interests in the information not being processed; and

(6) transfer your personal information to you or another company in a commonly used electronic format (known as the right to data portability).

You also have the right to object to the processing of your information, including for profiling purposes, where ODA ART Gallery does this:

(7) for the purposes of its legitimate interests or those of a third party; or (8) on the basis that it is acting in the public interest; or
(9) for direct marketing purposes.

If you lodge an objection on the last of these three grounds ODA ART Gallery will simply stop processing your personal information for marketing purposes (and any associated profiling). In the other two cases ODA ART Gallery will stop processing the relevant information unless it identifies compelling legitimate grounds for the processing which override your rights and interests or else ODA ART Gallery needs to process the information in connection with a legal claim.

8. MAKING A COMPLAINT TO THE ICO

If you are unhappy with the way ODA ART Gallery is processing your Personal information, please let us know. Alternatively, if you do not agree with the way we have processed your information or responded to your concerns, you have a right to submit a complaint to Nigerian’s Information Commissioner (the ICO).

9. DATA RETENTION

We will hold your personal information on our systems for as long as is necessary for the relevant service or as required by law, or for accounting or regulatory purposes.

10. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. All our staff and data processors who have access to, and are associated with the processing of, personal information are legally obliged to respect the confidentiality of the personal information of our visitors, email subscribers, members, shoppers, supporters, and all those who engage with us.

11. CHANGES TO THIS NOTICE

We will update this privacy notice from time-to-time to take account of ODA ART Gallery’s evolving needs and developments in the law. We will notify you of any significant changes to this privacy notice by email, a prominent notice on the website or account message.

This privacy notice was last updated on 28 March 2021.