What Is The Purpose Of This Policy?

This policy (together with our Website Terms of Use) describes how we collect and use personal information about you in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (Data Protection Legislation).

Please read the following carefully to understand our practices regarding how we handle information we collect from you or that you provide to us or which we otherwise learn about you from our relationships with you as a registered user, a bidder at an online auction held via our Website, a buyer of any items via our Website, and/or your use of our Website.

This Privacy Policy also explains our practices regarding how we handle information we collect from you or that you provide to us or which we otherwise learn about you from our relationships with you as a bidder at an auction held at our salerooms or a buyer of any items at our salerooms.

Nothing in this Privacy Policy prejudices any rights that you may have in relation to your personal data under Data Protection Legislation.

Who Are We?

Dreweatts is the owner and operator of the websites at www.dreweatts.com and www.bloomsburyauctions.com. We are registered in the United Kingdom under company number 10758982 and our registered office is at Donnington Priory, Oxford Road, Donnington, Newbury, England, RG14 2JE.

Our contact details are:

Address: Donnington Priory, Oxford Road, Donnington, Newbury, England, RG14 2JE

Email: info@dreweatts.com

Tel: 01635 553 553 | Fax: 01635 553 599

For the purpose of the Data Protection Legislation, we are the “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy policy.

How We Collect Your Personal Information

We obtain information about you when you use our Website, for example:

• when you become a registered user or fill in other forms on our Website;
• when you participate in an online auction, when you subscribe to receive email alerts, or when you subscribe to or participate in any other service;
• if you contact us, we will keep a record of that correspondence (for example, when you report a problem with our Website or request technical support);
• if you participate in a survey that we use for research purposes, although you do not have to respond to them; and
• details of your visits to our Website including time, traffic data, communication data, location data, your IP address and your browser type and operating system.

We may also collect and aggregate information about your computer for system administration and website analytics. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

We obtain information about you when you contact us in relation to an auction, whether an online auction or an auction to be held at our salerooms, or if you are a bidder at one of our auctions or a buyer of any items at an auction, for example:

• when you register to bid at an auction, when you inspect lots prior to an auction, and when you participate in an auction;
• if you contact us, we will keep a record of that correspondence (for example, when you submit a valuation request, request a condition report, a query, a complaint, or liaise with our customer services);
• if you participate in a survey that we use for research purposes, although you do not have to respond to them; and
• we may store information on your collecting interests so that we can inform you of relevant products and services.

The Information We Hold About You

The personal information we collect might include:

1. Identity Data (includes first name, last name, username or similar identifier, marital status, title, date of birth, gender, and image).
2. Contact Data (includes billing address, delivery address, email address and telephone numbers).
3. Financial Data includes (includes bank account, payment card details, and credit history).
4. Transaction Data (includes details about payments to and from you and other details of products and services you have purchased from or through us).
5. Technical Data (includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on devices used to access the Website).
6. Profile Data (includes username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses).
7. Usage Data (includes information about how you use the Website and our Services).
8. Marketing and Communications Data (includes your preferences in receiving marketing from us and our third parties and your communication preferences).

We may collect information about you from other sources, including through interactive applications (such as mobile devices/applications and third-party services) and from commercially available sources (such as data aggregators and public databases). For example, if you access third-party services (such as Facebook Connect) through or in connection with our Website, we may collect information available about you through those services, including personal information as well as publicly observable data, such as activities on blogs, videos, and other online postings. We may also collect personal information from you at events, from telephone calls, surveys and/or other correspondence with you.

We do not collect any special categories of personal data about you, such as details about your race or ethnicity, or about your health; nor do we collect information about criminal convictions and offences. We do operate CCTV cameras at our salerooms for safety and security purposes and these cameras may record your physical appearance and your conduct at our salerooms.

The Ways We Use Your Information

The Purposes for which we will use your personal information

We will use your information as described in this Privacy Policy and as permitted by applicable laws, including in circumstances where it is necessary: (i) to supply services requested by or for you; (ii) for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into such a contract; (iii) for compliance with a legal obligation to which we are a subject; (iv) to pursue our legitimate interests; or (v) where you have given us your express consent.

We may use your information in order to:

1. ensure that content from our Website is presented in the most effective manner for you and for your computer;
2. carry out our obligations arising from any agreements entered into between you and us;
3. allow you to participate in online auctions and other interactive features of our services, when you choose to do so;
4. allow you to participate in auctions at our salerooms;
5. provide you with information, products or services that you request from us or which we feel may interest you, where you have consented or otherwise agreed to be contacted for such purposes e.g. when you register with us, purchase items through our auctions, consign items for sale through our auctions, or as otherwise provided in this policy;
6. if you choose to provide information to us regarding your interests and/or preferences we may send you content based on the information that you have provided to us. We may use the information provided by you to display information about products and services that we believe may be of interest to you. We do not share this information with any other third party;
7. notify you about changes to our services; 
8. seek your opinions on our services;
9. for our internal business record keeping, tax, accounting and audit purposes;
10. to carry out identity and credit checks (for example, in relation to buyers and bidders); and
11. in connection with legal and regulatory matters that we need to deal with.

We use your financial information, such as credit card details only for payment purposes

We will not pass your details on to third parties for marketing purposes, full stop.

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for. 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.

In some circumstances (for example when we collect statistical data about our users' browsing actions and patterns) we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

If you fail to provide certain information when requested, we may not be able to perform any contract we have entered into with you, or we may be prevented from complying with our legal obligations.

Change of purpose

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Lawful Basis For Use Of Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data on one of the following lawful bases:

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

1. 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.
2. 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 other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw your consent to marketing at any time by contacting us (see the ‘Who Are We?’ section of this Privacy Policy)

Third Parties

Why might we share your personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so. We are not in the business of selling your personal information to third parties!

Which third-party service providers process my personal information?

Where permitted by the provisions of applicable law, Dreweatts may share such information from time to time with the following third parties:

• Our other group companies (Gurr Johns Ltd & Forum Auctions Ltd) including the employees, directors and managers of those companies who have a need to access your personal information in carrying out their responsibilities; and
• Any agent, contractor, supplier, vendor, or third party service providers who provides administration, logistics or other services to Dreweatts which are relevant to the services which we provide to you or who otherwise assist us in conducting our business, such as printers, storage facilities, communications software,  data hosting, call centre operations, and email management services.

All our third party service providers are required to take appropriate security measures to protect your personal information. We do not allow our third party service providers to use your personal data for their own purposes. We only permit them to process your personal data for our specified purposes and in accordance with our instructions, which are all as described in this privacy policy.

Who are the third-party service providers?

What about other third parties?

If you wish to sell an item which is below the value at which we would ordinarily sell lots in our auctions we may share your relevant personal data with a third party auctioneer for that auctioneer to auction that item, as described in our Auction Terms and Conditions.

We may share your personal information with other third parties, for example in the context of a possible sale, restructuring or financing of or investment in our company or any of our businesses. In this event we will take appropriate measures to ensure that the security of your personal data continues to be ensured with this Privacy Policy and the Data Protection Legislation. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We may also need to share your personal information with a regulator or to otherwise comply with the law. We may disclose your personal information in order to enforce or apply our Website Terms of Use and other agreements with you or to protect our rights or property or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.

Transferring information outside of the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA, such as USA.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times or we use service suppliers who are the EU-USA’s Privacy Shield Framework participants. If you wish for more information about this please contact us on info@dreweatts.com

Security

We have appropriate security measures in place to protect against the accidental loss, misuse, access and/or alteration of the information you provide. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Further, when you participate in an online auction or give us personal information, such as your name, address and credit card details you are automatically on our secure server. Our secure server software encrypts the information you input before it is sent to us to protect your data against unauthorised access.

CCTV

Our CCTV is used to capture, record and monitor images of what takes place at our salerooms, in real time. Depending on the type of camera, images are recorded on video tape (analogue) or as digital information. Cameras can be fixed or set to scan an area. In some circumstances they can be operated remotely by controllers.

We operate CCTV for the health and safety of our employees and other persons attending our salerooms from time to time and for the prevention and detection of crime and anti-social behaviour.

At our discretion, we may disclose personal data in response to valid requests from the police and other statutory law enforcement agencies. We may also disclose personal data to third parties, if required to by law; but we do not otherwise share any CCTV recordings or images.

We operate our CCTV systems in compliance with the CCTV Code of Practice which describes best practice standards which should be followed by organisations operating devices which view or record images of individuals.

Rights of Access, Correction, Erasure and Restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed of any changes to your personal information of which we need to be made aware.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information. This enables you to receive details of the personal information we hold about you and to check that we are processing it lawfully.
• Request the correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of the processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another person.

If you want to exercise any of the above rights, please contact us using the contact details in the ‘Who Are We?’ section of this privacy policy.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if any request made by you is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right To Withdraw Consent

In those circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing.

You can exercise this option at any time by contacting us using the contact details in the ‘Who Are We?’ section of this privacy policy. Once we have received your notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes for which you originally agreed, unless we have another legitimate basis for doing so in law.

Changes To This Policy

Any changes we may make to our privacy policy in the future will be posted on this website page. This privacy policy replaces all previous privacy policies. This privacy policy was last updated on 14^th March 2019.

Questions And Complaints Regarding This Policy

Should you have any questions regarding this Privacy Policy, you can contact us using the contact details in the ‘Who Are We?’ section of this privacy policy.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data 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.

Our contact details are:

Address: Donnington Priory, Oxford Road, Donnington, Newbury, England, RG14 2JE

Email: info@dreweatts.com

Tel: 01635 553 553 | Fax: 01635 553 599

Dreweatts' Third Party Data Processors

Dreweatts may share your personal data with the following third parties (ie. parties other than entities within the Dreweatts’ group) who assist us in providing products and services and provide us with technical services.