PRIVACY NOTICE
Effective Date: April 2025
Purpose of our Privacy Notice
This Privacy Notice aims to give you information on how REAL ASSET SERVICES UK LIMITED (“we”, “us” or “our”) collects and processes your personal data using both offline means (e.g. via phone, mail, in-person consultation and other correspondence) and online means, including through your use of our website https://gioiabonomidesigns.com/. All products and services offered for sale on this website shall be provided by us or our affiliates. “Gioia Bonomi Designs” is the trading name of Real Asset Services UK Limited.
This Privacy Notice informs you of our collection, use and disclosure of your personal data where we act as a “controller” (or the same or substantially similar terms or concepts used in applicable data protection law).
It is important that you read this Privacy Notice, together with any other Privacy Notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your personal data. This Privacy Notice supplements other notices and privacy policies and is not intended to override them.
Data Controller & Contact Information
Rohan Maxwell is the controller for your personal data under this Privacy Notice.
If you have any questions about this Privacy Notice or our privacy practices, please contact us in the following ways:
Full name of legal entity: REAL ASSET SERVICES UK LIMITED
Email address: info@gioiabonomidesigns.com
Postal address: 1 Hoopers Court, London, United Kingdom, SW3 1AF
Changes to the Privacy Notice
We keep our Privacy Notice under regular review. This version was last updated on April 2025. Historic versions can be obtained by contacting us. If we update this privacy notice, we will let you know in a manner consistent with the significance of the changes.
Cookie Policy
Please see our Cookies Policy for further information about how we use cookies and similar tracking technologies.
The Data We Collect About You
“Personal data” means any information that relates to an identified or an identifiable individual.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
– Identity Data includes first name and last name.
– Contact Data includes email address, postal addresses and telephone numbers.
– Account Data which may encompass Identity Data, Contact Data, username or similar identifier and password information.
– Technical Data includes internet protocol (“IP”) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website. We collect this information about all visitors to our website, whether or not you register an account with us.
– Profile Data includes your interests, preferences, feedback and survey responses and other communications you have with us.
– Usage Data includes information about how you use our website, products and services.
– Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We may also create, collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have requested from us, but we will use all reasonable endeavours to notify you if this is the case at the time.
Third Party Links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
How we collect and retain your personal data
We use different methods to collect personal data from and about you including through:
– Direct interactions. For example, you may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
– register for an account on our website;
– purchase a product or request a service;
– request marketing to be sent to you;
– enter a competition, promotion or survey; or
– give us feedback or contact us.
– Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.
For users that register for an account on our website, we also store the personal data you provide in your user profile. You will also be given opportunities to update your personal data in your profile. Website administrators can also see and edit the personal data in your profile.
How we use your personal data
The purposes for which we use your personal data are set out below. We are required under applicable data protection law to justify our use of your personal data by relying on a lawful basis.
We generally rely on the following lawful bases:
– where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“Legitimate Interests”);
– where we need to perform a contract we are about to enter into or have entered into with you (“Contract Performance”); and
– where we need to comply with a legal obligation (“Legal Obligations”).
Generally, we do not rely on consent as a legal basis for processing your personal data, although we may need to obtain your consent before sending direct marketing communications to you where this is required under applicable data protection law. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data where more than one basis has been set out in the table below.
TABLES TO BE INSERTED HERE
Disclosure of your personal data
We may share your personal data with the parties set out below for the purposes and lawful basis set out in the table ‘Purposes for which we will use your personal data’ above.
– External Third Parties which include our service providers, business partners, advisors and legal and regulatory authorities. These include our CRM provider (SquareSpace).
International data transfers
We will not transfer your personal data to countries outside of the UK or EU.
Data Security
We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.
Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation or similar claims in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In certain circumstances and subject to certain exemptions under applicable data protection law, you can ask us to delete your data: see ‘Your Data Protection Rights’ below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your Data Protection Rights
Under certain circumstances and subject to certain exemptions under applicable data protection law, you have rights in relation to your personal data. This includes the following rights to:
– Request access to your personal data. You can access some of this data in your account.
– Request correction of your personal data. It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes or requires updating during your relationship with us. You can correct some of this data in your account, such as your address and contact details.
– Request erasure of your personal data. You can delete some data in your account, or close the account yourself.
– Object to processing of your personal data. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.
– Request restriction of processing your personal data.
– Request transfer of your personal data to you, or a third party you have chosen. Your personal data will be provided in a structured, commonly used, machine-readable format.
– Withdraw consent (where we are relying on consent to process your personal data).
If you wish to exercise any of the rights set out above, please contact us at info@gioiabonomidesigns.com. We will consider your request and generally respond within one month.
You also have the right to make a complaint at any time to your local data protection regulator. We would, however, appreciate the chance to deal with your concerns before you approach them so please contact us in the first instance.