PRIVACY POLICY

We take your privacy very seriously. Please read this privacy policy, our website terms of use and any other documents referred therein carefully, as it contains important information on who we are and how and why we collect, store, use, and shares your personal information. It also explains your rights concerning your personal information and how to contact us or supervisory authorities in case you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so, we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom). We are responsible as a ‘controller’ and ‘processor’ of that personal information for those laws.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our

Elstob and Elstob Limited (t/a Elstob & Elstob)

Personal information

Any information relating to an identified or identifiable individual

Special category personal information

Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic and biometric data

Data concerning health, sex life or sexual orientation

 

Personal information we collect about you

We may collect and use the following personal information about you:

  • your name and contact information, including email address and telephone number
  • Information to enable us to check and verify your identity, e.g. your date of birth
  • your billing information, transaction and payment card information where necessary
  • your personal or professional interests
  • your contact and purchase history
  • information to enable us to undertake credit or other financial checks on you where necessary
  • Information about how you use our website, IT, communication and other systems
  • your marketing preferences

This personal information is required to provide services to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing services to you.

How your personal information is collected

We collect most of this personal information directly from you—in person, by telephone, text or email and via our website when you register an account, sign up to receive news about forthcoming auctions and events, or when you express an interest in buying or selling certain types of property to one of our staff or representatives. However, we may also collect information:

  • from publicly accessible sources, e.g. Companies House or HM Land Registry;
  • directly from a third party, e.g.:
    • When you create an account with a third party for live bidding purposes;
    • When someone requests that you bid on their behalf or collect your property;
    • When someone introduces you to us
  • from a third party with your consent, e.g. your bank or building society
  • from cookies on our website—for more information on our use of cookies, please see our cookies policy below.

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

  • to comply with our legal and regulatory obligations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as your rights and interests do not override this.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

Our reasons

To provide services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or us

For our legitimate interests or those of a third party, i.e. to minimise fraud that could damage you and us.

Conducting checks to identify our customers and verify their identity

Screening for financial and other sanctions or embargoes

Further processing is necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulations or rules issued by our professional regulator

To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g. policies covering security and internet use

For our legitimate interests or those of a third party, i.e. to ensure we are following our internal procedures to deliver the best service to you.

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. about our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and us

To comply with our legal and regulatory obligations

Updating and enhancing customer records

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments and ensuring you, our staff and property on our premises are kept secure

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. to make sure we are following our internal procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of selected third parties to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts

For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

To create and maintain records on art objects to assist with checks on authenticity, provenance and title and prevent fraud, theft or other unlawful activities

To maintain our legitimate business interests and public interest.

To monitor the performance of our website and make your user experience better

To maintain our legitimate business interests.

 

The above table does not apply to special category personal information, which we will only process with your explicit consent.

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). We do not usually need your consent to send you promotional communications. However, we will ask for this consent separately and clearly where support is required.

We will always treat your personal information with the utmost respect and never sell it to other organisations for marketing purposes without your consent.

You have the right to opt-out of receiving promotional communications at any time by:

  • contacting us at info@elstobandelstob.co.uk
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future or if there are changes in the law, regulation, or structure of our business.

Whom we share your personal information with

We routinely share personal information with:

  • third parties we use to help deliver our services to you, e.g. payment service providers, our agents or contractors to enable us to process transactions, administer events or communicate with you;
  • other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
  • third parties approved by you, e.g. third-party payment providers;
  • our insurers and brokers;
  • our banks;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your data and can only use it to provide services for us. We may also share personal information with external auditors, e.g. about ISO or Investors in People accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised, but this may not always be possible. Confidentiality obligations will bind the recipient of the data.

We will not share your personal information with any other third party.

Where your personal information is held

Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

How long your personal information will be kept

We will keep your personal information while you have an account with us or we provide services to you. After that, we will keep your personal information for as long as necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information

When having your personal information is no longer required, we will delete or anonymise it.

Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • with your and our service providers located outside the EEA;
  • if you are based outside the EEA;
  • where there is an international dimension to the services we provide.

These transfers are subject to particular European and UK data protection laws.

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure that the transfer complies with data protection law and that all personal information will be secure. Our standard practice uses standard data protection contract clauses that the European Commission has approved. To obtain a copy of those clauses [insert details of where they have been made available (where possible, providing a link to the mechanism or information].

Please get in touch with us if you want further information (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

Access

The right to be provided with a copy of your personal information (the right of access)

Rectification

The right to require us to correct any mistakes in your personal information

To be forgotten

The right to require us to delete your personal information—in certain situations

Restriction of processing

The right to require us to restrict the processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Data portability

In certain situations, you have the right to receive the personal information you provided in a structured, commonly used and machine-readable format and transmit that data to a third party.

To object

The right to object:

—at any time to your personal information being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal information, e.g. processing carried out for our legitimate interests.

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

For further information on each of those rights, including the circumstances in which they apply, please get in touch with us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to us—see below: ‘How to contact us’; and
  • let us have enough information to identify you (e.g. your full name, address and customer or matter reference number);
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let us know what right you want to exercise and the information your request relates to.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, used, or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

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

The measures used to protect your personal information include an electronic firewall and various other protection measures that involve virus scanning, installation of security patches, vulnerability testing, backup and recovery planning, employee training, security audits and other steps designed constantly to improve the data protection posture. Please note, however, that we cannot guarantee that information during transmisthroughhough the internet or any computer network is inherently safe from unauthorised intrusion, access or manipulation. We exclude all liability to the fullest extent permitted by law for disclosure of information due to errors or unauthorised acts of third parties.

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. Get Safe Online is supported by HM Government and leading businesses.

How to complain

We hope we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, particularly in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner, who may be contacted at https://ico.org.uk/concerns or by telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published and last updated in December 2018.

We may change this privacy notice from time to time—when we do, we will inform you via our website or other means of contact, such as email.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our contact details

Ripon Business Park, Charter Road, Ripon, North Yorkshire, HG4 1AJ

01765 699200

info@elstobandelstob.co.uk

 

Do you need extra help?

If you would like this notice in another format (for example, audio, large print, braille), please get in touch with us (see ‘How to contact us’ above).

 

Use of cookies

A cookie is a small text file placed onto your computer (or another electronic device) when you access our website. We use cookies and other online tracking devices on this website to:

  • recognise you whenever you visit this website (this speeds up your access to the website as you do not have to log in each time);
  • obtain information about your preferences, online movements and use of the internet;
  • carry out research and statistical analysis to help improve our content and services and to help us better understand our visitor and customer requirements and interests;
  • target our marketing and advertising campaigns and those of our partners more effectively by providing interest-based advertisements that are personalised to your interests; and
  • make your online experience more efficient and enjoyable.

The information we obtain from cookies will not usually contain your data. Although we may get information about your computer or another electronic device, such as your IP address, browser and other internet log information, this will not usually identify you personally. In certain circumstances, we may collect personal information about you—but only where you voluntarily provide it (e.g. by completing an online form) or where you purchase goods or services from us.

In most cases, we will need your consent to use cookies on this website. The exception is where the cookie is essential for us to provide you with a service you have requested (e.g. to enable you to put items in your shopping basket and use our check-out process).

Consent— notification on home page

We will ask for your permission (consent) to place cookies or other similar technologies on your device, except where these are essential for us to provide you with a service that you have requested (e.g. to enable you to put items in your shopping basket and use our check-out process).

There is a notice on our home page describing how we use cookies and requests your consent via a checkbox you will need to click and accept if you agree to cookies being placed on your device.

If you accept our request for permission or use this website after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in this policy.

Third-party cookies

We work with third-party suppliers who may also set cookies on our website. These third-party suppliers are responsible for the cookies they set on our site. Please go to the website for the relevant third party if you want further information. You will find additional information in the table below.

Description of cookies

The table below provides more information about the cookies we use and why:

Name of cookie

Owner

The purpose of the cookie

Google Analytics

 

This web analytics service provided by Google Inc uses cookies to show us how visitors found and explored our site and how we can enhance their experience. It provides us with information about the behaviour of our visitors (e.g. how long they stayed on the site, the average number of pages viewed) and how many visitors we have had.

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and disabling them, please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.