Things Change Ltd trading as Testament Gallery
ICO Registration Number: ZC167638
Effective Date: 26 June 2026
1. INTRODUCTION
Things Change Ltd trading as Testament Gallery ("Testament Gallery", "we", "us" or "our") is committed to protecting and respecting your privacy.
This Privacy Policy explains how we collect, use, disclose, store and otherwise process personal data when you visit our website, enquire about artwork, subscribe to our mailing list, purchase artwork, consign artwork, submit information as an artist, or otherwise engage with our services.
We process personal data in accordance with the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018 and other applicable privacy legislation.
For the purposes of data protection law, the data controller is:
Things Change Ltd
Trading as Testament Gallery
ICO Registration Number: ZC167638
For privacy-related enquiries, please contact:
Email: hello@testament.gallery
2. PERSONAL DATA WE COLLECT
We may collect and process the following categories of personal data:
Identity Data
• Name
• Title
• Company or organisation details (where applicable)
Contact Data
• Email address
• Telephone number
• Postal address
• Delivery address
Transaction Data
• Details relating to artwork enquiries
• Purchase history
• Delivery instructions
• Payment-related records
Communications Data
• Correspondence with us
• Contact form submissions
• Artist submissions
• Customer service communications
Technical Data
• IP address
• Browser type and version
• Device information
• Operating system
• Website usage information
• Cookie identifiers
Marketing Data
• Mailing list preferences
• Event registration information
• Communication preferences
3. HOW WE COLLECT PERSONAL DATA
We collect personal data:
• Directly from you when you contact us;
• When you purchase or enquire about artwork;
• When you subscribe to newsletters or event invitations;
• When you submit information through our website;
• Through cookies and analytics technologies;
• From publicly available sources where relevant to a commercial art transaction.
4. PURPOSES OF PROCESSING
We may process personal data for the following purposes:
• Responding to enquiries;
• Managing client and collector relationships;
• Administering artwork sales and acquisitions;
• Arranging delivery, installation and logistics;
• Providing exhibition information;
• Managing artist submissions and consignments;
• Operating and improving our website;
• Detecting fraud, misuse or unlawful activity;
• Maintaining business records;
• Complying with legal, accounting and regulatory obligations.
5. LAWFUL BASIS FOR PROCESSING
We rely upon one or more of the following lawful bases:
Contract
Where processing is necessary for the performance of a contract or to take steps at your request prior to entering into a contract.
Legitimate Interests
Where processing is necessary for our legitimate interests in operating and developing our gallery business, provided those interests do not override your rights and freedoms.
Consent
Where you have given specific consent, including for electronic marketing communications where required by law.
Legal Obligation
Where processing is necessary to comply with applicable legal or regulatory obligations.
6. MARKETING COMMUNICATIONS
Where permitted by law, we may send information regarding:
• Exhibitions;
• Artists;
• New acquisitions;
• Artwork releases;
• Gallery events;
• Related gallery activities.
You may withdraw your consent or unsubscribe from marketing communications at any time by following the unsubscribe instructions included within such communications or by contacting us directly.
Withdrawal of consent does not affect the lawfulness of processing undertaken prior to withdrawal.
7. DISCLOSURE OF PERSONAL DATA
We may disclose personal data to:
• Professional advisers;
• Accountants, auditors and legal advisers;
• Shipping, logistics and installation providers;
• Website hosting providers;
• Email communication platforms;
• Technology and software providers;
• Regulatory authorities, courts, law enforcement agencies or governmental bodies where required by law.
We do not sell personal data to third parties.
8. INTERNATIONAL TRANSFERS
Certain service providers may process information outside the United Kingdom.
Where personal data is transferred internationally, we shall implement appropriate safeguards required under applicable data protection legislation, including approved contractual safeguards where appropriate.
9. DATA RETENTION
We retain personal data only for so long as reasonably necessary for the purposes described in this Policy.
Retention periods may be extended where required:
• by law;
• for accounting purposes;
• for tax compliance;
• in connection with actual or anticipated legal proceedings;
• to establish, exercise or defend legal claims.
Transaction records may be retained for up to seven years or such longer period as may be required by law.
10. SECURITY
We implement reasonable technical and organisational measures designed to safeguard personal data against accidental loss, unauthorised access, misuse, disclosure, alteration or destruction.
However, no transmission of information over the internet can be guaranteed to be completely secure and we cannot warrant the absolute security of information transmitted to our website.
11. COOKIES AND ANALYTICS
Our website may use cookies and similar technologies to:
• Enable website functionality;
• Analyse website traffic;
• Improve user experience;
• Monitor website performance;
• Assist with security and administration.
Users may control cookie preferences through browser settings and, where applicable, through our cookie consent mechanisms.
12. YOUR RIGHTS
Subject to applicable law, you may have the right to:
• Request access to your personal data;
• Request correction of inaccurate information;
• Request erasure of personal data;
• Request restriction of processing;
• Object to processing;
• Request portability of personal data;
• Withdraw consent where processing is based upon consent;
• Lodge a complaint with the Information Commissioner's Office.
Requests may be submitted using the contact details provided in this Policy.
13. THIRD-PARTY WEBSITES
Our website may contain links to third-party websites.
We have no control over such websites and accept no responsibility or liability for their privacy practices, content or security.
Users should review the privacy policies of any third-party websites they visit.
14. CHANGES TO THIS POLICY
We reserve the right to amend or update this Privacy Policy at any time.
Any changes will be published on this page together with the revised effective date.
Continued use of our website following publication of changes shall constitute acceptance of the revised Policy.
15. CONTACT
Questions regarding this Privacy Policy should be directed to:
Things Change Ltd
Trading as Testament Gallery
Email: [INSERT CONTACT EMAIL]
16. COMPLAINTS
If you are dissatisfied with our handling of personal data, we would appreciate the opportunity to address your concerns in the first instance.
You also have the right to lodge a complaint with the Information Commissioner's Office at:
https://ico.org.uk
