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(a) What is the legal basis on which the Auctioneers rely to process your data?
On some occasions, the Auctioneers process your data with your consent (e.g., when you agree that the Auctioneers may place cookies, or if you ask, the Auctioneers, to send you information about upcoming events).
On other occasions, the Auctioneers process your data when the Auctioneers need to do this to fulfill a contract with you (e.g., for billing purposes) or where the Auctioneers are required to do this by law (e.g., where we have to fulfill anti-money laundering requirements). If it is mandatory for you to provide data for these purposes, the Auctioneers will make this clear at the time and will also explain what will happen if you do not provide the data (e.g., that the Auctioneers will not be able to process a bid at auction).
The Auctioneers also process your data when it is in the Auctioneers' legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, the Auctioneers have a legitimate interest in ensuring the security and integrity of the auctions, in learning about the interests and preferences of current and prospective clients, in developing new business opportunities, in maintaining accurate business and provenance records, and in ensuring that the Auctioneers' websites and apps operate effectively. When the Auctioneers process personal information to meet the Auctioneers' legitimate interests, the Auctioneers put in place robust safeguards to ensure that your privacy is protected and to ensure that the Auctioneers' legitimate interests are not overridden by your interests or fundamental rights and freedoms.
(b) Who gets to see your personal data?
The Auctioneers Thomas Del Mar Ltd, Matthew Barton Ltd, Olympia Auctions Ltd and auctioneers at Olympia Auctions, such as Charles Miller Ltd, will be processed by the Auctioneer that initially receives it, and may also be transferred to and processed by other companies within the group of Auctioneers. The Auctioneers use standard contractual clauses approved by the EU Commission to regulate the transfer and processing of data between the Auctioneers.
Outside the Auctioneers
The Auctioneers do not transfer your personal data to organisations who wish to use it for their own marketing promotions or other purposes. The Auctioneers only transfer your personal data to other organisations where it is necessary to enable the Auctioneers to provide you with the services you have requested (for example: the Auctioneers may transfer your data to the Auctioneers' bank, payment card acquirers, shippers, warehouses, insurers, experts who help the Auctioneers authenticate or value property, event venues, caterers, catalogue and direct marketing fulfillment and distribution). Where the Auctioneers do, it will be on the basis that these organisations are required to keep the information confidential and secure, and they will only use the information to carry out the instructed services. Some of these organisations may be located outside the EEA. The Auctioneers may also need to retain and disclose certain information about you to appropriate agencies to conduct anti-money laundering and trade sanction checks and to assist with fraud, crime prevention and detection.
When the Auctioneers receive a request for information from a government or law enforcement agency, the Auctioneers will disclose information which is the subject matter of that request, if the Auctioneers are satisfied that the government or law enforcement agency has the right to seek disclosure and the correct procedure has been followed. In all other circumstances such information will only be disclosed if the Auctioneers are ordered to do so by a court of law.
(c) How long will the Auctioneers keep your personal data?
The Auctioneers will retain your personal data for as long as is necessary to provide the relevant services, maintain business records to satisfy tax, legal and other regulatory requirements, and protect and defend against potential legal claims.
In the context of our research and records on ownership of art objects to assist with checks on authenticity, provenance and title, we will keep this data for as long as the record is relevant to our legitimate business interest and the public interest.
What steps do the Auctioneers take to keep your personal data secure?
The Auctioneers will take all reasonable and appropriate steps to protect the security and integrity of all personal information provided via our website, or by any other means.
The Auctioneers use a variety of security technologies and procedures to help protect your personal details from unauthorised physical and electronic access.
As effective as modern security practices are, we cannot guarantee the complete security of personal data held in our systems, nor that information you supply through the internet or any network is entirely safe from unauthorised intrusion, access or manipulation during transmission. Any transmission is at your own risk. We will not be liable for any resulting misuse of your personal data.
(d) Third party websites
The Auctioneers' website may contain links to other websites not operated by us, the Auctioneers. The information you provide to us will not be transmitted to other websites, but these other websites may collect personal information about you in accordance with their own privacy notice. We as the Auctioneers cannot accept any responsibility for the privacy practices or content of those websites.
(e) Your data
You have the right to request deletion of your personal data. The Auctioneers will comply with this request, subject to our legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information we hold about you. If you would like a copy of some or all of your personal information then please write to the Auctioneers or email the Auctioneers.
The Auctioneers have an obligation to ensure that your personal information is accurate and up to date. Please write to the Auctioneers or email the Auctioneers to correct or remove any information that you think is incorrect.
If you have any queries or complaints in relation to the Auctioneers processing your personal data please contact the Auctioneers.