Privacy Policy

PRIVACY POLICY

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Hartleys Auctioneers collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to receive details of our auctions, catalogues or to bid or take part in an auction.

CONTROLLER

Hartleys Auctions Ltd is the controller and responsible for your personal data (collectively referred to as “Hartleys”, “we”, “us”, or “our” in this privacy notice).

If you have any questions about this, please contact our website using the details set out below.

CONTACT DETAILS
Hartleys Auctions Ltd
Name of date privacy manager: Emma Padgett
Email address: info@hartleysauctions.co.uk
Postal Address: Hartleys Auctions Ltd, Victoria Hall Salerooms, Little Lane, Ilkley, West Yorkshire, LS29 8EA.
Telephone No: 01943 816363

You have the right to make a complaint at any time to the information Commissioner’s Office (ICO), the UK supervisory authority for date protection issues (www.ico.org.uk).  We would however appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

PLEASE KEEP US UPDATED ABOUT YOUR DETAILS

It is important that the personal date 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 website may include 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. 

THE DATE 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 which we have grouped together as follows:

Identity Data comprises first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data comprises billing address, delivery address where applicable, email address and telephone number.

Financial Data comprises bank account details.

Transaction Data comprises details about payments to and from you and other details of products and services you have bid for and/or purchased via us.

Profile Data comprises your username and password, purchases or bids made by you, your interests, preferences, feedback and survey responses.

Usage Data comprises information about how you use our website, products and services.

Marketing and Communications Data comprises your preferences in receiving marketing from us and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sec life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).  No do we collect any information about criminal convictions and offences.

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 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 goods or services).  In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

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

Direct Interactions.  You may give us your Identity, Contact and Financial Data by filling in forms or by correspondence with us by post, phone, email or otherwise.  This includes personal data you provide when you

            Create an account on our website

            Submit bids

            Submit a valuation request

            Request a condition report

            Contact us through the website or otherwise (by post, email or phone)

            Subscribe to our auction catalogues

            Request marking to be sent to you

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

Contact, Financial and Transaction Data from providers of technical, payment and delivery services (based inside or outside the EU)

Identity and Contact Data from publicly available sources

Online bidding platforms (to include but not limited to thesaleroom.com)

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:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

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.  You have the right to withdraw consent to marketing at any time by unsubscribing or updating your preferences using the opt-out link included on all of our marketing emails or by contact us at info@hartleysauctions.co.uk

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 date for more than one lawful ground depending on the specific purpose for which we are using your data.  Please see below 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/bidder	Identity	Performance of a contract with you
To process and delivery your order including: Manage payments, fees and charges Collect and recover money owed to us	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you   Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:   Notifying you about changes to our terms or privacy policy   Asking you to leave a review or take a survey	Identity   Contact   Profile   Marketing and Communications	Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restricting exercise)   Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	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 make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time at info@hartleysauctions.co.uk

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of product/service purchase, warranty registration, product/service experience or other transactions.

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 purchase, please contact us.

If we need to use your personal date 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.

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 above:

Third party consultants, contractors or other service providers including but not limited to I.T. support, software providers and website developers and banks.

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 date for their own purposes and only permit them to process your personal data for specified purposes and in accordance with their instructions.

INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA)

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 employees, agents, contractors 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.

Please be aware that communications over the internet, including via email, are not secure unless they have been encrypted.

DATA RETENTION

FOR HOW LONG WILL YOU USE MY PERSONAL DATA

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

Details of retention periods for different aspects of your personal data are available upon request from us.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data (see our glossary below)

If you wish to exercise any rights set our above please contact info@hartleysauctions.co.uk

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 for further information in relation to your request to speed up our response.

GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.  We make sure we consider and balance our potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.  We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at info@hartleysauctions.co.uk

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

YOUR LEGAL RIGHTS

You have the right to:

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.

Request correction of the personal data 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.

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, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with the 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.

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.

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.

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.

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.