Privacy Policy

Return on Art GmbH (FN 518613 t) respects your privacy and is committed to protecting your personal data. This privacy policy (Privacy Policy) will inform you as to how we look after your personal data when you visit our website (Site) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

  1. Important information and who we are

    Purpose of this Privacy Policy

    This Privacy Policy aims to give you information on how we collect and process your personal data through your use of our Site, including any data you may provide through our Site when you sign up to receive publications from us or purchase artwork.

    This Site is not intended for people under the age of 18 and we do not knowingly collect data relating to such people.

    It is important that you read this Privacy Policy together with any other privacy policy or fair processing 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 data. This Privacy Policy supplements the other notices and is not intended to override them.


    Return on Art GmbH is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this Privacy Policy).

    If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

    Contact details

    Return on Art GmbH, Liechtensteinstraße 111-115, 1090 Vienna, Austria

    Email address

    Your duty to inform us of changes

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

    Third-party links

    This Site includes 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 Site, we encourage you to read the privacy policy of every website you visit.

  2. The data we collect about you

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    We may collect, use, store and transfer different kinds of personal data about you. Below is a non-exhaustive list of the personal data we collect which we have grouped together follows:

    • (a) Identity Data includes first name, last name, title and date of birth.
    • (b) Contact Data includes billing address, delivery address, email address and telephone numbers.
    • (c) Financial Data includes bank account and payment card details.
    • (d) Transaction and Profile Data includes details about payments to and from you and other details of artwork you have purchased via our Site.
    • (e) Technical Data includes internet protocol (IP) address, your login data, 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 this Site.
    • (f) Usage Data includes information about how you use our Site, products and services.
    • (g) Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

    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 (for example, to provide you with artwork). In this case, we may have to cancel an order you have with us but we will notify you if this is the case at the time.

  3. How is your personal data collected?

    We use different methods to collect data from and about you including through:

    (a) Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • (i) order artwork;
    • (ii) create an account on our Site;
    • (iii) subscribe to our mailing list; or
    • (iv) contact us with an enquiry.

    (b) Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

    (c) Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

    • (i) Technical Data from analytics providers such as Google based outside the EUadvertising networks and search information providers.
    • (ii) Contact Data, Financial Data and Transaction Data from providers of technical, payment and delivery services.
    • (iii) Identity Data and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
  4. How we use your personal data

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    (a) where we need to perform the contract we are about to enter into or have entered into with you;

    (b) where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override such interests; or

    (c) where we need to comply with a legal or regulatory obligation.

    Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

    Purposes for which we will 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 legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Purpose/Activity Type of data Lawful basis for processing
    including basis of legitimate interest
    To register you as a new customer. (a) Identity Data
    (b) Contact Data
    Performance of a contract with you.
    To process and deliver your order including:(a) manage payments, fees and charges; and
    (b) collect and recover money owed to us.
    (a) Identity Data
    (b) Contact Data
    (c) Financial Data
    (d) Transaction and Profile Data
    (e) Marketing and Communications Data
    (a) Performance of a contract with you.
    (b) Necessary for our legitimate interests (to recover debts due to us).
    To manage our relationship with you which will include:
    (a) notifying you about changes to our Terms and Conditions, Privacy Policy, or any other policies in force from time to time; and
    (b) asking you to leave a review or take a survey.
    (a) Identity Data
    (b) Contact Data
    (c) Transaction and Profile Data
    (d) Marketing and Communications Data
    (a) Performance of a contract with you.
    (b) Necessary to comply with a legal obligation.
    (c) Necessary for our legitimate interests (to keep our records updated and to study how customers to our Site use it).
    To enable you to complete a survey. (a) Identity Data
    (b) Contact Data
    (c) Transaction and Profile Data
    (d) Usage Data
    (e) Marketing and Communications Data
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to study how customers to our Site use it, to develop and grow our business).
    To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). (a) Identity Data
    (b) Contact Data
    (c) Technical Data
    (a) Necessary for our legitimate interests to operate our business.
    (b) Necessary to comply with a legal obligation.
    To deliver relevant website content and advertisements to you via our Site and measure or understand the effectiveness of the advertising we serve to you. (a) Identity Data
    (b) Contact Data
    (c) Transaction and Profile Data
    (d) Usage Data
    (e) Marketing and Communications Data
    (f) Technical Data
    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
    To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences. (a) Technical Data
    (b) Usage Data
    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).


    You will receive marketing communications from us if you have given your express opt-in consent to receive marketing communications.

    We have established the following personal data control mechanisms:

    Relevant Marketing Material

    We may use your Identity Data, Contact Data, Technical Data, Usage Data, and Transaction and Profile Data to form a view on what we think may be of interest to you and share marketing material that we think may be relevant to you.

    Opting out

    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 contact us at any time.

    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any purchase you make via our Site.


    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly.

    Change of purpose

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  5. Disclosures of your personal data

    We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above to:

    (a) our artists whose artwork we advertise on our Site;

    (b) third parties we need to engage to provide the artwork to you such as couriers; and

    (c) third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  6. International transfers

    We may transfer your personal data outside of the European Economic Area ( EEA ) if it is absolutely necessary to do so. If we transfer your personal data outside of the EEA, we will ensure a similar degree of protection is afforded to it.

  7. Data security

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those officers, employees, artists and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  8. Data retention

    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    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 requirements.

  9. Your legal rights

    Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

    (a) Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    (b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    (c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    (d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    (e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    (f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    (g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    If you wish to exercise any of the rights set out above, please contact us.

    No fee usually required

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    What we may need from you

    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    Time limit to respond

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will endeavour to notify you and keep you updated.


Our website (Site) uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. By continuing to browse the Site you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device, if you agree. Cookies are then sent back to our Site on each subsequent visit or to another website that recognises that cookie.

Cookies are useful because they allow our site to recognise your device.

Cookies do lots of different jobs such as enabling you to navigate between pages efficiently, remembering your preferences and generally improving your experience of our Site.

The cookies used on our Site have been categorised based on the ICC UK cookie guide. A list of the types of cookies used on our Site by category is set out below along with some details of the specific cookies we use, their purpose and what to do if you do not consent to any of the cookies being used.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart, make use of e-billing services and more from page to page. Without these cookies these facilities cannot be provided.

  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it including which pages are visited most often and whether there are any error messages. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. These cookies do not collect information that identifies a visitor as all information is aggregated and therefore anonymous.

  • Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences. These cookies also allow us to enhance your experience by offering useful facilities on our Site. The information these cookies collect cannot track your browsing activities on other websites.
  • Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our site more relevant to your interests.

These are the cookies used on our Site:

Cookie name Purpose More Information
Asp.Net.Core.Session Session uses a cookie to track and identify requests from a single browser. ASP.NET Core maintains session state by providing a cookie to the client that contains a session ID, which is sent to the app with each request. The app uses the session ID to fetch the session data.

Please note that third parties (for example, Instagram) may also use cookies over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You may be able to block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.

Unless you have adjusted your browser settings so that it will refuse cookies our system will place cookies as soon as you visit our Site.

If you do not consent to cookies being placed you must notify us and set out to which cookies you do not consent.

Except for essential cookies all cookies will expire after twelve months, unless otherwise stated on the relevant website detailing specific information about any of the cookies listed above.


Questions, comments and requests regarding this privacy policy or cookie policy are welcomed and should be addressed to

Thank you for visiting our Site.

Version: August 2022