HOLTS PRIVACY POLICY

Introduction

This privacy notice sets out the way we process your information and details. We’ll keep this policy updated to show you how we use your personal information so that you can be confident when sharing your information with us that it will only be used for what we say here.

Who we are

We are Holts Auctioneers a UK based privately owned auction company running quarterly live auctions in London accessible online. We are also registered as a company in England and Wales under registration number 04096596.

Legal basis and legitimate interest

When Holts Auctioneers collects and processes your personal information we will do this according to at least one of the legal grounds permitted in Data Protection law. The typical methods we will be relying on are:

• Where you have given your consent. This may have been consent provided by you when you signed up to take part in one of our auctions or joined our "My Holts" community.
• Where we are fulfilling a contract. For example, you have bought an item in one of our auctions.
• Where we have a legal obligation. For example, if you have bought a registered firearm in one of our auctions we are then obliged to record the transaction in our gunbook and make this available for inspection by the appropriate governing authority. Namely the Police Firearms Department/Officer.

In all cases, we balance our legitimate interests and legal requirements against your rights as an individual and make sure we only use personal information in a way or for a purpose that you would reasonably expect in accordance with this policy and that does not intrude on your privacy or previously expressed marketing preferences.

What information do we generally collect?

Holts will collect only that detail required to complete the administrative, financial and logistical consequences of purchasing at a Holts auction:

• Name
• Contact details – postal address, telephone number
• Email address
• Copy of valid firearms licence as per UK statutory requirements
• Financial details – Only when you are entering into an agreement to make a purchase after bidding in a Holts auction we will need your payment details to complete the transaction. Where we ask you to make a payment Holts Auctioneers does not record this information and it is not stored on our systems.

Payment processing online of debit and credit card payments are managed externally by WorldPay on behalf of Holts Auctioneers.

To bid live online, customers are required to register with Holts live online bidding platform provider Invaluable. Registration information is retained by Invaluable and only passed to Holts in the event of a successful bid. Please read the privacy policy on the Invaluable website before registering any personal data with Invaluable.

What do we do with the information you supply?

We use the information you supply to:

• Administer the purchase and shipment of items bought at a Holts auction
• Communicate with you via email about auctions and events organised by Holts that we think may be of interest to you
• Comply with a legal duty

We want to provide a positive experience for you as well as use our resources effectively. Therefore we may also:

• Analyse your personal information to build a picture of your interests and preferences so that we can contact you with details of items in forthcoming auctions most relevant to you.
• Contact you if you complete but don’t submit an online form to see if we can assist with any problems you may be having with our website.
• Analyse how visitors use our website to improve the user experience of website visitors.
• Use publicly available sources to keep your records up to date; for example, the Post Office’s National Change of Address database.

If you do not wish to receive emails from Holts, just click the unsubscribe link provided at the foot of each marketing email sent by Holts.

Who do we share information with?

Holts Auctioneers will not disclose any of your personally identifiable information, except:

• When are legally obliged to provide access to our gunbook for inspection by the appropriate governing authority. Namely the Police Firearms Department/Officer.

We will hold your information only as long as necessary for each purpose we use it. For example, under current UK Firearms rules we will need to retain your details for five years after the date of your last purchase from Holts Auctioneers.

For marketing purposes we would balance Holts legitimate interest to contact you about forthcoming auctions and events based on your level of engagement with Holts with your rights as an individual to be forgotten.

If you request that we stop sending you marketing materials we may still keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us as well as our legal duty to maintain records of firearms sales at auction.

Marketing

You are in control and you can change your preferences at any time, but we hope that you will find our communications useful and informative. You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact Holts Auctioneers by emailing info@holtsauctioneers.com or by writing to Holts Auctioneers, Church Farm Barns, Wolferton, Norfolk PE31 6HA or telephoning +44 (0)1485 542 822 (Lines open 9am – 5:30pm, Mon – Fri).

What do we mean by marketing?

Marketing includes news and information about:

• Forthcoming auction dates
• Closing times and dates of auctions currently running
• Free valuation dates
• Social events & activities organised by Holts
• Holts presence at trade and gamefairs
• Fundraising events such as the annual charity clay shoot

We will keep your information safe

We are committed to keeping your personal data safe and secure and we take all necessary steps to make sure your details are held securely. We will never sell or swap your information with other organisations.

Holts Auctioneers, in conjunction with our IT support company, uses industry standard efforts to safeguard the confidentiality of your personally identifiable information on our website, such as firewalls and Secure Socket Layers. We make every effort to protect the loss, misuse, and alteration of the information under our control. In addition, we always use a secure connection when collecting personal financial information from you. However, no data transmission over the Internet can be guaranteed to be 100 per cent secure.

If you use a "My Holts" user account on our website your account is password-protected so that only you and those you designate can access it and view the member information relevant to your account. Ultimately, you are responsible for maintaining the secrecy of your passwords and any account information. We also do everything in our power to protect your information off-line, and only authorised personnel can view your data.

We may need to disclose your details if required to the police, regulatory bodies.

Website links to third parties

We cannot be held responsible for the privacy policies of third party websites and we advise users to read the privacy policies of other websites before registering any personal data.

Keeping your information up to date

The accuracy of your information is really important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest. If you wish to change how we communicate with you, or update the information we hold, then please contact us:

• Email us at: info@holtsauctioneers.com
• Write to us at: Holts Auctioneers, Church Farm Barns, Wolferton, Norfolk, PE31 6HA
• Call us on: +44(0)1485 542 822(Mon-Fri 9am-5:30pm)

You may also choose to stop receiving further emails at any time by clicking the unsubscribe link at the foot of marketing emails from Holts Auctioneers.

Right of access and correction of your information

You have a right to ask for a copy of the information we hold about you. If you spot any mistakes, please let us know and we will correct them.

If you want to access your information, send a description of the information you want to see and proof of your identity by post to Holts Auctioneers, Church Farm Barns, Wolferton, Norfolk, PE31 6HA.

For further information see the Information Commissioner’s guidance

Changes to this Policy

We may change this Privacy Policy from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on the Holts Auctioneers Website.

This policy was last updated on 26th April 2018.