Privacy Notice

Curated Auctions Limited (“we”/“us”) is a company incorporated in Wales with company number 13551604and having its registered office at 744 Sidcup Road, London, SE9 3NS, United Kingdom. We have registered with the Information Commissioner’s Office and our registration number is ZB250222. By accessing the site at www.curatedauctions.co.uk (“Site”), you acknowledge and consent to the information collection and use practices by us in our capacity as data controller as described below. Please read this Privacy Notice carefully and contact us if you have questions or concerns at info@curatedauctions.co.uk or write to us at our above registered address.

The information we collect and why

Personal information means information relating to natural persons who can be identified or who are identifiable, directly from the information in question or who can be indirectly identified from that information in combination with other information (“Personal Information”).

Most of the Personal Information we process is provided directly by you or made available when you access or use the Site. We set out below some examples of how you may provide Personal Information to us:

• registering on the Site as a buyer, seller or to request a valuation;
• bidding on lots;
• completing forms and sending enquiries on the Site;
• contacting us by phone, mail, e-mail, social media or otherwise; and
• information related to your attendance of, and interest in, our auctions and viewings.

The Personal Information that we may process includes your name, title, username or similar identifier (“Identity Information”) and contact details such as your email address, postal address, billing address, and telephone numbers (“Contact Information”) as well as records of your communications with us (including bidding instructions recorded over the telephone or online bidding logs) and information on your preferences or interests.

We may also collect financial information, such as details of your payment card or your bank account details,bank transfer receipt and other information about your usage and transactions with us (“Financial Information”)for example when you purchase a lot from us (and you need to pay us) or you sell your property through us (and we need to pay you).

We may process details of your visit to the Site such as your IP address, browser type and operating system,time zone setting and location, which type of device you are using, which pages you view and how much time you spend on the Site and any other data obtained from cookies, web logs and other similar technologies that monitor the use of the Site and deliver more appropriate advertisements on or beyond the Site (“Technical Information”).

How we may use the information

We will only process your Personal Information when we have a lawful basis for doing so, as set out below:

• Legitimate interests:
o We may process your Technical Information to present information to you in a way that is appropriate for you and for your device or to improve our products and services and customise the Site according to your interests.
o We may process your Identity Information, Contact Information and Financial Information to supply a service (such as a condition report) to you, or to consider whether we are able to accept a bid offered by you, or to process a transaction requested by you and to enable you to access information on the Site (for example, information only available to registered clients), to participate in auctions held by us online or otherwise, or to enable you to make purchases from us or consignments to us.
o We may process the Personal Information, including Identity Information and Contact Information of a previous client with whom we have worked to personalise emails, send updates about us and the material changes in the Privacy Notice, or for other purposes permitted by law.

Where we rely on our legitimate business interests to process these categories of Personal Information about you, we will balance our legitimate interests against your interests and rights (for example, responding to inquiries,  improving the Site, and enabling network and information security)these include:

• Entering into a contract with you: We may process your Identity Information, Contact Information and Financial Information that you provide when you enquire about, bid on or purchase a lot  from us or consign a lot to us. We process this Personal Information to enable us to carry out the pre-contract and contractual relationship between you and us.
• Where you have given your consent: When you subscribe to the newsletter and enable us to send it to you on a monthly basis, we may process your Contact Information and Identity Information. You have the right to withdraw consent at any time, simply click the link provided in the newsletter or contact us in writing.
• Complying with the law: We may process your Personal Information, in particular your Financial Information (such as details of your past transactions and the source of your funds) and Sensitive Personal Information (which is set out in greater detail below) to comply with our legal obligations, including legal obligations with respect to Anti-Money Laundering (“AML”) requirements if applicable.

We may also collect Personal Information to perform other functions that are not listed above, which will either be described to you when the Personal Information is collected or it may be collected if you have granted your consent for a particular purpose.

Sensitive Personal Information

For certain transactions, we may be required to fulfil some AML obligations for regulatory purposes and we may collect Personal Information about you through direct interaction, such as requesting copies of passports, proof of address and other information or through third parties/ publicly available sources, for example when we need to conduct background checks. These obligations may also require us to process more sensitive categories of Personal Information which require greater protection because it is more sensitive (“Sensitive Personal Information”). In addition, we may operate CCTV at our premises for the purposes of maintaining security of the premises and to protect the vital interests of a data subject or another person. The CCTV may capture Sensitive Personal Information.

Sensitive Personal Information may include identifiers from the following categories of information:

• Criminal Offence Information: Personal Information relating to criminal convictions and offences or related security measures and may include a wide range of information about criminal activity, allegations, investigations and proceedings; and
• Special Category Information: includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

We will process your Sensitive Personal Information in accordance with the lawful basis set out above and the additional conditions and safeguards set out in Schedule 1 of the Data Protection Act 2018.

Information passed to third parties

We use third-party platforms to support communications. We will never provide your Personal Information to any third party for them to use for their marketing purposes. We are not responsible for their privacy practices and you are encouraged to read their privacy notices to understand how they process your Personal Information (which may be outside the UK). The third-party platforms currently used include those set out below, but may change from time to time:

• Bid Path provides auction management and AML software for auction houses. We use Bid Path as our data storage and AML software. As such, Bid Path processes Personal Information on our behalf, in particular your Identity Information and Contact Information when you sign up for an account, and your Sensitive Personal Information when we perform the AML background checks. Please see their privacy notice at Bidpath.com
• Perspectives chartered accountants based in the UK and we use them for our accounting and taxation requirements. We may share Financial Information and Sensitive Personal Information in order to meet our contractual and compliance obligations mentioned above. 
• Auction Technology Group (“ATG”): ATG operates six marketplaces and proprietary auction platform technology for curated online auctions. We may advertise our lots on Saleroom and Invaluable LLC.ATG may process your Personal Information, including Sensitive Personal Information where they conduct their own KYC checks, according to their privacy notices if you place a bid on our lot through one of ATG’s marketplaces. Please see here for further information www.auctiontechnologygroup.com.  
• Live Auctioneers LLC (“Live Auctioneers”): An auction marketplace where we may advertise our lots on. Live Auctioneers may process your Personal Information, including Sensitive Personal Information where they conduct their own KYC checks, according to their privacy notices if you place a bid on our lot through its marketplace. Please see here for further information https://www.liveauctioneers.com/en-gb/.  
• Xero UK Ltd (“Xero”): Xero is a cloud-based accounting software platform. We use Xero for our bookkeeping functions and invoicing. As such, we may share Financial Information, Contact Information and Identity Information with Xero in order for us to fulfil these functions. Please see www.xero.com for further information.

We will not share your Personal Information with third parties other than as necessary for the purposes outlined above and only with third party service providers that provide business, professional or technical support functions on our behalf or as required by law.

We may pass your Personal Information to any lawful authority which has a right to require such information, to enforce our legal rights and terms of business, or to protect our clients such as by exchanging information in order to guard against fraud or credit risk.

We may aggregate information about you with information about other visitors to the Site in order to identify trends in our business. We may pass aggregated data to third parties such as advertisers and business partners to give them a better understanding of our business. However, such information will not identify you personally.

Links to Other Sites

The Site may contain links to other sites of interest. However, once you have used these links to leave the Site, you should note that we do not have any control over that other site. Therefore, we cannot be responsible for the protection and privacy of any Personal Information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and look at the privacy notices applicable to the site in question.

International Transfers

Your Personal Information may be transferred outside the UK. For example, this may be in relation to an international sale or where we are sharing information with our third party service providers who operate outside the UK. We only transfer your Personal Information outside of the EEA where we are satisfied that the transfer is in accordance with applicable data protection and privacy laws. Where third parties process yourPersonal Information outside the UK, you are advised to read their privacy notice as set out above.

Security and Retention

We are committed to ensuring that your Personal Information is secure. We have put in place suitable physical, electronic and managerial procedures to protect against unauthorised access, alteration, disclosure or destruction of your Personal Information.

We take reasonable steps to ensure that the Personal Information we hold about you is as accurate and complete as is necessary to carry out the relevant purposes described in this Privacy Notice. We will retain your Personal Information for so long as is reasonably necessary for us to fulfil the relevant purposes described in this Privacy Notice, unless a longer retention period is required or permitted by law (for example for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements or in the event of a complaint or where there is a prospect of litigation).

Personal Information shared with third party service providers is stored and deleted according to their privacy notices.

Please be aware that no electronic transmission or storage of Personal Information can be guaranteed to be 100% secure. We cannot and do not warrant the security of any Personal Information that you transmit, and all such transmissions are done at your own risk.

Your rights

You have rights under data protection legislation which may include: To request access to your Personal Information which we hold and information as to how we are processing it; to request that anything incorrect is corrected; to request that such Personal Information is deleted, where we have no legitimate interest in continuing to process it; to object to us processing your Personal Information including for direct marketing purposes, or to restrict such processing; to request that we transfer your Personal Information to a third party.

You will not generally have to pay a fee for any of the above, unless your request is unfounded or excessive, in which case we may either refuse to comply with it, or charge a reasonable fee for doing so. You may contact us using the details provided at the beginning of this Privacy Notice.

If you are unhappy with any aspect of how we handle your Personal Data you can make a complaint to the Information Commissioner’s Office (ICO) here.

Changes to this Privacy Policy

We have the discretion to update this Privacy Notice at any time. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Information we collect.If the changes are material, we will post a notice on the Site before the changes go into effect. We encourage you to periodically review this Privacy Notice to stay informed. This Privacy Notice was last updated on 8 February 2022.

Cookies

Almost every site uses cookies, which are small data files that are placed onto your computer hard drive for record-keeping purposes and sometimes to track information about them. We use “cookies” to improve the Site. For more information on the cookies that we use on the Site, please see our Cookie Policy on our Site.