Privacy Policy
1. Who is responsible for your data
The controller of the personal data collected through heritagefineart.com is:
Luctamo Group S.L. Calle Capitán Arenas 66, 3º 1ª, 08034 Barcelona, Spain Tax ID (NIF): B88847488 Email: info@heritagefineart.com
Luctamo Group S.L. operates this website on behalf of Heritage Gallery FZE (Sharjah, United Arab Emirates), which offers the works presented on it. Together they trade as Heritage Gallery.
2. What data we collect
We only collect the data you give us:
- When you send an enquiry or use a contact form: your name, email address, telephone number (optional) and the content of your message.
- When you contact us by email or WhatsApp: the data included in that communication.
- When a purchase follows: the identification and payment data needed to complete the transaction and to meet our legal obligations (see section 3).
We also use cookies. Their use is explained in our Cookie Policy.
3. Why we use your data and on what legal basis
| Purpose | Legal basis |
|---|---|
| Answering your enquiry about a work, an artist or a service | Your request, and steps taken at your request before entering into a contract (Art. 6.1.b GDPR) |
| Managing a sale, delivery and invoicing | Performance of a contract (Art. 6.1.b GDPR) |
| Identity and source-of-funds checks required by anti-money-laundering law | Legal obligation (Art. 6.1.c GDPR) |
| Keeping accounting and tax records | Legal obligation (Art. 6.1.c GDPR) |
| Sending you information about new works, if you ask us to | Your consent (Art. 6.1.a GDPR), which you can withdraw at any time |
| Measuring use of the website, only if you accept analytics cookies | Your consent (Art. 6.1.a GDPR) |
We do not use your data for automated decision-making or profiling.
4. Who we share your data with
- Heritage Gallery FZE, which offers the works, when your enquiry concerns a work or a possible purchase.
- Service providers who act on our behalf and under contract: website hosting, email and messaging services, and, where applicable, fine art shippers and insurers.
- Public authorities, where the law requires it.
We do not sell your data or share it for advertising purposes.
5. International transfers
Heritage Gallery FZE is located in the United Arab Emirates, a country without an adequacy decision from the European Commission. When your enquiry concerns a work offered by Heritage Gallery FZE, your data is transferred to it because the transfer is necessary for the steps you have asked us to take before a contract (Art. 49.1.b GDPR), or, for a completed sale, for the performance of that contract (Art. 49.1.b GDPR).
Some of our service providers may process data outside the European Economic Area. Where they do, the transfer is covered by an adequacy decision or by the Standard Contractual Clauses approved by the European Commission.
6. How long we keep your data
- Enquiries that do not lead to a sale: up to two years from our last exchange.
- Data relating to a sale: for the period required by tax and commercial law.
- Data from anti-money-laundering checks: ten years, as required by law.
- Mailing list data: until you unsubscribe.
7. Your rights
You can at any time:
- access your data;
- ask us to correct or delete it;
- object to or ask us to restrict its processing;
- ask for it to be transferred to you or to another controller;
- withdraw any consent you have given, without affecting processing carried out before.
To exercise these rights, write to info@heritagefineart.com. We may ask you to confirm your identity.
If you consider that we have not handled your data properly, you can lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
8. Security
We apply technical and organisational measures appropriate to the risk to protect your data against loss, misuse and unauthorised access.
9. Changes
We may update this policy. The version in force is the one published on this page.
Last updated: September 2026