OUR PRIVACY POLICY 

1                   This Site
This website (our “Site”) is operated by Exhibit Auctions Ltd, a company registered in Scotland with registered number SC664937 and having its registered office c/o Defacto Fd, Merlin House, Mossland Road, Glasgow, G52 5XZ (“we”, “our”, “us”).
2                   This Privacy Policy
2.1               This privacy policy (our “Privacy Policy”) sets out the personal information we collect about you or from you and you give to us (your “personal data”), why we collect it, how we use it and when we may share or disclose it. It also sets out how to contact us and supervisory authorities for further information, and/or in the event you have a complaint that we cannot resolve with you.
2.2               We collect, use and are responsible for certain personal data concerning you. When we do so we are regulated under various laws, including the Data Protection Act 2018, and the EU General Data Protection Regulation now incorporated into the laws of the United Kingdom. We are responsible as “controller” of that personal data for the purposes of those laws.
3                   Contacting us
3.1               If you have any questions about our Site or this Privacy Policy, including if you don’t understand any part of this Privacy Policy, please contact us:
3.1.1          by e-mail at info@exhibitauctions.co.uk;
3.1.2          by telephone at +44 7780563915; or
3.1.3          by post c/o Defacto Fd, Merlin House, Mossland Road, Glasgow, G52 5XZ.
3.2               Please note that our email and telephone facilities are not constantly monitored. However,  we will endeavour to respond to you promptly.

3.3               Please also note that we may keep a record of correspondence to enable us to properly manage our Site, to deal with your query, and for quality and training purposes.

4                   Our Site
4.1               This Privacy Policy relates to your use of our Site. The Site include the websites linked to the following domain names and all associated webpages:
www.exhibitauctions.co.uk
4.2               Please note that this Privacy Policy applies also to our social media accounts at Facebook, Instagram and Twitter.
5                   Third Party Sites
Throughout our Site we may link to other websites owned and operated by third parties, including payment service providers and exhibitors on our Site. These third party websites may also gather information about you. For privacy information relating to these other third party websites, and for information as to how they collect and use your personal data, please consult their privacy policies.
6                   How We Collect Personal Data
6.1               We collect personal data about you when you access our Site, register with us, contact us, send us feedback, purchase lots at auctions via our Site, telephone or write to us, post material to our Site, sign up to receive marketing information from us, compete customer surveys or visit our social media accounts.
6.2               We collect this personal data from you either directly, such as when you register with us, contact us or bid during our live auctions via our Site or indirectly, when you are browsing our Site, or via the providers of the facilities to us and to you, for example social media and payment service providers.
7                   Personal Data Collected
7.1               The personal data we collect depends on the particular activities carried out through our Site or our social media profiles. Personal data may include:
7.1.1          your name, address and contact details;
7.1.2          the location and/or device from which you are visiting our Site;
7.1.3          your date of birth;
7.1.4          your social media profile information;
7.1.5          your bank account and payment details;
7.1.6          details of any feedback you give us by phone, email, post or via social media;
7.1.7          your account details, such as username, login details; and/or
7.1.8          information concerning the elements of our Site that you visit, read, interact with, and information concerning the manner of that interaction.
8                   Uses of your Personal Data
8.1               We may use your personal data to:
8.1.1          create and manage your account with us;
8.1.2          verify your identity;
8.1.3          verify any registrations you hold;
8.1.4          verify your ability to buy any lot lawfully via our Site, including with regulatory authorities;
8.1.5          enable you to buy lots at auctions via our Site;
8.1.6          notify you of any changes to our Site or to our services that may affect you;
8.1.7          improve our business, for example through product feedback, or via training our staff;
8.1.8          to protect the rights, property or safety of others; and
8.1.9          to operate our Site and our business.
8.2               This Site is not intended for use by, and is not available to, persons under eighteen (18) and we do not knowingly collect or use personal data relating to such persons.
9                   Our legal basis for processing your personal data
9.1               When we use personal data we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal data we process and why.
9.2               The legal bases we may rely on include:
9.2.1          consent – where you have given us clear consent for us to process your personal data for a specific purpose;
9.2.2          contract – where our use of your personal data is necessary for a contract we have with you, for example to enable you to use the facilities provided by our Site, or because you have asked us to take specific steps before entering into a contract;
9.2.3          legal obligation – where our use of your personal data is necessary for us to comply with the law; and
9.2.4          legitimate interests – where our use of your personal data is necessary for our legitimate interests, your legitimate interests, or the legitimate interests of a third party, for example to prevent fraud (unless there is a good reason to protect your personal data which overrides those legitimate interests).
10                Further Information
For further details on when we collect personal data, what we collect as well as how we use it, please read the following sections:

When information is collectedWhat information we collectHow and why we use your information 
When you register to receive information from us on our services and business including notifications of upcoming auctions and email or SMS updates.Your name, telephone number and email address.We collect this personal data directly from you.We will use this personal data to provide you with information on our products and business, including information on the availability of new services. We may do this by post, email, telephone, or text message (SMS).Our basis for processing this personal data is consent, which you give to us when you input your details into our Site.We will retain this personal data until you withdraw it. Please note unsubscribe links are included at the bottom of all of our marketing emails, or you can ask us to cease processing your personal data for these purposes by using the contact means set out in this Privacy Policy.
When you purchase any lots at one of our live auctions.Your name, address, email address. Please note that your payment details are collected by our third party payment services provider “Sagepay” whose website (and privacy policy) can be found at www.opayo.co.ukWe collect this personal data directly from you.We will use this personal data to enable the fulfillment of contracts for the purchase and sale of lots at auctions between you and us as agents of the relevant sellers of those lots. We may also use this personal data, in conjunction with our third party payment services provider or regulatory authorities, to prevent fraud or the breach of laws or regulations.Our basis for processing this personal data is to perform our contract with you for the provision of the purchase facilities provided by our Site.We may also disclose this information to regulatory authorities and our payment services providers, to prevent fraud or the breach of laws or regulations. This is pursuant to our legitimate interests.We will retain this personal data until you withdraw it. Please note unsubscribe links are included at the bottom of all of our marketing emails, or you can ask us to cease processing your personal data for these purposes by using the contact means set out in this Privacy Policy.

11                   Personal Data Sharing
11.1               If you submit someone else’s personal data you must have consent from them to do this.
11.2               We routinely share personal data as follows:
11.2.1          with our providers, who assist with enabling the operation of our Site, for example hosting providers, and email service providers. This sharing enables the provision of our Site to you; and
11.2.2          we will share personal data with law enforcement or other authorities, and/or our payment services providers, if required by applicable law, to check that you are not breaching applicable law or regulation, or to check that you are able to lawfully use our Site. Where we know you have breached, or where we suspect you may be breaching any obligations owed to us, for example the terms relating to the use of our Site, we may share your personal data with third parties to the enable us to help protect their rights, property or safety. This is includes sharing to prevent the risk of fraud.
11.3               Some of these persons with whom we share personal data may be based outside the United Kingdom or the European Economic Area (“EEA”), in locations which do not provide the same level of protection as regards personal data under applicable law as that to which you are entitled in the United Kingdom and EEA.
11.4               Our providers currently include the following:

AuctionaryAuctionary is the trading name for Bidpath Ltd which provides us with software to enable you to bid for lots through our Site. Visit www.auctionary.com.
SagepaySagepay is our payment services provider. Visit www.opayo.co.uk.
Social MediaWe use Facebook, Twitter and Instagram to interact with you. Please see these sites’ privacy policies for further information, located at:https://en-gb.facebook.com/policy.phphttps://twitter.com/en/privacyhttps://help.instagram.com/519522125107875 
EmailOctopusWe disclose personal data to EmailOctopus to allow the dispatch of marketing communications to data subjects. Please see https://emailoctopus.com/legal/privacy for more information

12                   Cookies
Our Site does not currently use Cookies.
13                   Your Rights
13.1               Under applicable law you have a number of important rights. In summary, those include rights to:
13.1.1          fair processing of your personal data and transparency over how we use your use personal data;
13.1.2          access to your personal data;
13.1.3          require us to correct any mistakes in your personal data which we hold;
13.1.4          require the erasure of personal data concerning you in certain situations;
13.1.5          receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and to have us transmit that personal data to a third party in certain situations;
13.1.6          object at any time to processing of personal data concerning you for direct marketing;
13.1.7          object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; and
13.1.8          object in certain other situations to our continued processing of your personal data.
13.1.9          For further information on each of those rights, including the circumstances in which they apply, see the Information Commissioner’s guidance located at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
13.2               If you would like to exercise any of those rights, please email, call or write to us using the contact means set out in this Privacy Policy, and remember to let us have enough information to identify you, and the matter to which your correspondence relates. Please note we may require you to provide proof of your identity and address.
14                   Keeping your Personal Data Secure
14.1               We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
14.2               We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
14.3               We do not have access to your payment information. Our payment services providers Sagepay is compliant with PCI standards (see http://www.pcisecuritystandards.org).
14.4               If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org.
15                  How to Complain
We hope that we can resolve any query or concern you raise about our use of your personal data. Please contact us using the means set out above if you have any query or concern.
16                   Changes to this Policy
Please note that we may update this policy from time to time, so if you revisit our Site at a later date you should check this policy again at that time to make sure you have seen the current version. This policy was last updated on March 9th, 2021.  


OUR ANTI-MONEY LAUNDERING POLICY

 

1                   This Site
This website (our “Site”) is operated by Exhibit Auctions Ltd, a company registered in Scotland with registered number SC664937 and having its registered office c/o Defacto Fd, Merlin House, Mossland Road, Glasgow, G52 5XZ (“we”, “our”, “us”).
2                   Contacting us
2.1               If you have any questions about our Site or this Anti Money Laundering and Tax Evasion Policy, including if you don’t understand any part of this Anti Money Laundering and Tax Evasion Policy, please contact us:
2.1.1          by e-mail at info@exhibitauctions.co.uk;
2.1.2          by telephone on +44 7780563915; or
2.1.3          by post c/o Defacto Fd, Merlin House, Mossland Road, Glasgow, G52 5XZ.
2.2               Please note that our email and telephone facilities are not constantly monitored. However,  we will endeavour to respond to you promptly.

2.3               Please also note that we may keep a record of any correspondence, for the purposes set out in this Anti Money Laundering and Tax Evasion Policy.

3                   Our Site
3.1               This Anti Money Laundering and Tax Evasion Policy relates to your use of our Site. The Site include the websites linked to the following domain names and all associated webpages:
www.exhibitauctions.co.uk
4                   This Policy
4.1               We are committed to the prevention of money laundering, tax evasion and abusive tax avoidance.
4.2               Our commitment includes complying with laws designed to prevent money laundering, tax evasion and abusive tax avoidance. These laws include the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002, and the Criminal Finances Act 2017.
5                   Our rights
5.1               We may collect information concerning you, including, identification documentation, bank account, payer and payee information, and registration information.
5.2               We may collect information relating to particular transactions effected, or sought to be effected, via our Site, including as a condition of allowing a transaction to be completed.
5.3               We may disclose this information to third parties to verify your identity.
5.4               We may disclose this information to regulatory authorities, where we suspect there is a breach of applicable laws or regulations.
5.5               We may disclose this information pursuant to our own legal obligations.
5.6               We may retain this information for as long as is reasonably required to allow us to meet our legal obligations.
5.7               Where we suspect a transaction being (or to be) effected via our Site may cause us, or other persons, to breach applicable law or regulation, we may suspend or cancel that transaction and/or report that transaction to relevant regulatory authorities, or seek further information to allow that transaction to proceed.
6                   Your obligations
6.1               When we ask you for information, you must provide this information when we require.
6.2               All information provided to us must be true, accurate, complete and correct.
6.3               You must inform us of any changes to information you provide to us, when those changes occur, or (if earlier) when you become aware changes may take place.
6.4               You must cooperate with any investigation organised by a regulatory authority, including by providing any information, assistance, or access to people, products or premises that we or that regulatory authority may require.
6.5               You must not use our Site in any way connected with the laundering of monies, or evading or abusively avoiding tax (“Offences”). These are Offences for which you, or us, may be liable. If you are in any doubt about what may constitute these Offences please take professional legal advice.
6.6               If you suspect that our Site is being used for the conduct of an Offence, you must let us know. Please contact us using the details set out above.
7                   Liability
7.1               If you use our Site to conduct any Offence, you shall be liable to us for any loss, cost, expense, damage or claim, whether direct or indirect, that we may suffer. You indemnify and shall keep us indemnified against any and all such loss, cost expense, damage and claims.
7.2               This liability and indemnity shall include the costs and expenses incurred by us in connection with any investigation or potential investigation, or advice procured by us in connection with any investigation or potential investigation, or in relation to applicable laws and regulations.
7.3               Where we take action under or pursuant to this policy, we shall not be liable to you in any manner in respect of that action, including as regards any disclosure of information, suspension or cancellation of transactions, or otherwise, or for any direct or indirect, secondary consequential loss, cost, damage, expense or claim arising therefrom.
8                   Changes to this policy
Please note that we may update this policy from time to time, so if you revisit our Site at a later date you should check this policy again at that time to make sure you have seen the current version. This policy was last updated on March 9th, 2021.