Data Protection & Privacy

About this policy

This policy explains when and why A J Ludlow Ltd (the “Company”) collect personal information and how it is used; how it is kept secure and individual’s rights in relation to it. This includes on-line customers, Wednesday Watercolour Painting Club (the “Painting Club”) members and newsletter subscribers. The company will collect, use, and store personal data, as described in this Data Protection Policy.

The Company reserve the right to amend this Data Protection Policy from time to time without prior notice.  The Company will only share your personal data with Third Party organisations when booking postal services for the delivery of purchased goods.

The Company will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.gov.uk).

Responsible persons

For the purposes of the GDPR, the Company Directors will be joint “controllers” of all personal data that is held in the Company. The Company Directors are responsible for making sure the Company complies with the General Data Protection Regulation (GDPR) and review personal data every year to establish whether the Company is still entitled to process it or not.

Individual’s rights

You have rights under the GDPR:

•           To access your personal data;

•           To be provided with information about how your personal data is processed;

•           To have your personal data corrected;

•           To have your personal data erased in certain circumstances;

•           To object to or restrict how your personal data is processed in certain circumstances.

For more details, please address any questions, comments, and requests regarding the Company’s data processing practices to the Company Directors.

Lawful reasons for collecting personal data

The Company’s lawful reasons for collecting personal data are twofold:

1. Contract – the Company will enter into contract with subscribing members of the Wednesday Afternoon Watercolour Painting Club (the Painting Club), and in these circumstances will use the lawful reason of ‘contract’ to justify any necessary processing of personal data. This is also the lawful reason when entering into contracts with customers, who purchase goods from the Company’s on-line shop. The Company will keep clear records to demonstrate that ‘contract’ is a lawful reason for such processing and will continue to review its current processes and documents to ensure that lawful compliance is achieved.
2. Consent – the Company will always seek clear unambiguous ‘opt-in’ consent when requesting personal data from those subscribing to the Company’s newsletter, sent via email. This consent will not use pre-ticked opt-in boxes and it will be kept separate from other terms and conditions. The ‘opt-in’ process will make clear what type of communication the individual is opting to receive from A J Ludlow Ltd. A J Ludlow Ltd will keep clear records to demonstrate such ‘consent’ and will continue to review its processes and documents to ensure that lawful compliance is achieved.

The Company asks for personal data in three circumstances:

•     To maintain on-line customer records to ensure good service in fulfilling their purchasing orders and timely delivery of their goods;
•     To maintain membership records for the Painting Club members;
•     To supply information and news in the form of an electronic newsletter to those individuals that have subscribed.

Collection and storage of your personal data

How the Company collect and store your personal data:

• On-line customer records – in order to fulfil customer orders, via A J Ludlow Ltd’s on-line shop, customers are required to provide their name, email and address for delivery of their goods. This personal data recorded for each customer is held electronically within the on-line shop software provided by the website host contracted by the Company. There are no hard copies of these data kept. On purchasing, it is necessary for the customer to provide their financial details which goes directly to the finance company, who are contracted by the Company to take on-line payment. Similarly, when taking credit card payments in person and the issue of electronic receipts (either by text or email), the Company does not receive or record these data as it goes directly to the finance company who are contracted by the Company to take electronic payment.
• The Painting Club Membership records – the Company maintains an electronic database of subscribing members. The personal data recorded for each member are supplied on a membership application form and consists of name and contact details. Hard copies of these forms are retained for a period of five years. These data are retained until the individual ceases to be a member of the Painting Club. At this point the data are deleted unless the individual has become an on-line customer (see above) or subscribed to the electronic newsletter (in which case name and email will be retained).  In addition, when a member opts to pay subscription fees online, using either BACS or another third-party agent such as PayPal, the Company (either through its bank account or third party account) will have a record of the member's financial account details as are required to process the payment method chosen, but it will remain electronically held in the Company’s respective account.
• Newsletter Subscriber records – the Company maintains an electronic database of subscribers. This database is used to generate the circulation list and ensure that the interested individuals receive the Company’s newsletter. Each addition of the newsletter is sent out with the option for the receiver to unsubscribe at any time.

In the unlikely event of a breach of the security of data the Company Directors will notify customers, Painting Club members and newsletter subscribers promptly and they will never sell or pass on their clients’ personal data.

Request to see your personal information

If you wish to know what personal data the Company holds, please email the Company Directors at admin@ajludlow.co.uk and they will respond within 14 days of the request (depending on availability).

CCTV Images

CCTV is used in the interests of safety and crime prevention. All images are stored electronically on the recording devices’ memory. The images/data are stored for 1 month and then these are over written.

For these reasons the information processed may include visual images, personal appearance and behaviours. This information may be about club members, customers and offenders and suspected offenders, members of the public and those inside, entering or in the immediate vicinity of the area under surveillance. Where necessary or required this information is shared with the data subjects themselves, employees and agents, service providers, police forces, security organisations and persons making an enquiry.



Any complaints which rely on these CCTV data must therefore be made within 1 month of the incident otherwise the images will have been overwritten.