This policy explains how Attesian (“Attesian”, “we”, “us”) processes personal data when you use our registry, certificates, and verification tools (the “Service”). We are committed to the principle that privacy should be enforced by how the system is built, not merely promised in a document like this one.
1. Who we are
Attesian is a provenance registry and trust infrastructure operated as a venture of Ubuntu Capital. For the purposes of UK data protection law (the UK GDPR and the Data Protection Act 2018), Attesian is the data controller for personal data processed through the Service, except where we act as a processor for a white-label partner (see Sharing & contributors).
Our company registration details and registered office will be published here on incorporation. Data protection enquiries can be sent to privacy@attesian.com.
2. Data we collect
We process the following categories of personal data:
- Account data — name, email address, and authentication details when you register.
- Artist and record data — biographical and professional details you add to a record, such as an exhibition and works history, education, and contact information.
- Work and artwork data — titles, dates, materials, images, and the digital fingerprints we create from those images.
- Provenance events — sales, gifts, loans, transfers, consignments, and exhibitions, together with the parties to them.
- Attestation data — confirmations you make or receive, and the method and identity-verification level of each.
- Communications — messages you send us, and the delivery of one-time confirmation links by email, text, or WhatsApp.
- Technical data — limited log and device information necessary to operate and secure the Service (see the Cookie Policy).
3. Sensitive data
Some artists choose to record heritage or identity information — for example, describing their cultural background. This may count as special-category (sensitive) data under Article 9 UK GDPR. We only use it where you have given clear, specific permission, and it is shown — including on certificates and in partner versions of the Service — only while that permission stands. It is always something you volunteer; we never guess it. You can withdraw permission at any time, after which it stops being shown.
4. How we use data
- To create and maintain artist-owned records.
- To create and check tamper-evident certificates of authenticity.
- To run confirmation requests, including sending one-time confirmation links.
- To work out reputation and price ranges from private information, always following the privacy rules in section 6.
- To keep the Service secure and prevent misuse.
- To meet our legal obligations.
We do not sell personal data, and we take no cut of any sale — what we earn is never tied to the values we show.
5. Why we're allowed to use your data
Under UK GDPR, we rely on:
- Contract — to provide the Service you signed up for.
- Your permission— for sensitive heritage information, optional messages, and showing your name against an entry in a work's history.
- Legitimate interests — to keep the Service secure, prevent fraud and false claims about who made a work, and keep the records trustworthy, balanced against your rights.
- Legal obligation — where the law requires us to keep or share data.
6. How the history works
A history in Attesian is only ever added to: entries are never quietly edited, and corrections are new, visible entries that replace older ones. This is central to the trust the Service provides. It also shapes how your rights work, so we want to be clear about it:
- The history is built around private codes, not names, so your personal details can be removed without breaking anyone's ability to check the record.
- Sale prices are kept private and are only ever seen by the people involved in that sale.
- Any public price or reputation information is shown only as broad ranges, and never in a way that could reveal what a single work sold for.
7. Sharing & contributors
The record belongs to the artist. Galleries, venues, and other contributors may add to that record and are credited for doing so — that is credit, not ownership. In public, a work's ownership is shown only in outline (for example, “owned by three people over time; first owner: the artist”), and names appear only where someone has chosen to be named.
We share personal data with:
- Branded partners, where you use a gallery or venue's branded version of the Service — there, we handle the data on their behalf under a written data agreement.
- Service providers (hosting, messaging, timestamping) who handle data under contract and only on our instructions.
- An independent timestamp service— each day we publish a timestamp that proves the records haven't been changed. It contains only anonymous codes and no personal data.
8. International transfers
We aim to keep personal data hosted within the UK or EEA. Where a provider processes data outside the UK, we rely on adequacy regulations or the UK International Data Transfer Agreement (or equivalent safeguards). Contact us for details of the safeguards applicable to a specific transfer.
9. Retention
We keep personal data for as long as needed to maintain the record you own and to meet our legal obligations. Because a work's history is meant to be a lasting, lifelong record, artist and history data stays by design — but you keep the rights below, including having your details removed, at any time.
10. Your rights
Under UK GDPR you have the right to:
- access the personal data we hold about you;
- rectify inaccurate data;
- erase data (subject to the mechanism in section 11);
- restrict or object to certain processing;
- data portability — your record is designed to be portable;
- withdraw consent at any time, without affecting prior lawful processing.
To exercise any right, email privacy@attesian.com. We respond within one month.
11. Deleting your data
We can remove your personal details without breaking the trust in the record. Because the history is built around private codes rather than names, we handle a deletion request by taking your personal details out while leaving the record's trustworthiness untouched. The fact that a sale or transfer happened may remain as an anonymous entry; the personal details attached to it do not. This is a deliberate way of respecting your right to be forgotten while keeping the record honest.
12. Security
We protect data with secure digital signatures, encryption in transit and storage, strict access controls, and an independent daily timestamp, so that any unauthorised change would show — including one by us. No system is ever perfectly secure, but being tamper-evident is built into ours from the start.
13. Contact & complaints
Questions or concerns: privacy@attesian.com. If you are not satisfied with our response, you have the right to complain to the UK Information Commissioner's Office (ICO) at ico.org.uk. We would appreciate the chance to address your concern first.