GENERAL STATEMENT OF POLICY
This policy together with our Personal Information Collection Statements set out the basis on which we will collect, use and process your personal data.
PERSONAL DATA COLLECTION AND RETENTION
In general, it is voluntary for you to provide your personal data. However, if you do not provide sufficient information, we may not be able to provide auction services to you.
It is our policy to retain your personal data only for as long as is necessary for the relevant purpose that it is held for.
PURPOSE OF USE OF PERSONAL DATAWe may use your personal data for the purposes of:
- enabling you to participate in our auction process;
- carrying out our obligations arising from any contracts entered into between you and us;
- communicating with you;
- verifying your identity;
- with your consent providing you with direct marketing information in relation to our previews, auctions and other events , which relate to our auction business;
- notifying you about changes to our services;
- analysing market trends and individual preferences to improve our services;
- liaising with third parties on your behalf, including your counterparty or counterparties to an auction transaction, and associated third party service providers for web hosting and other IT services, freight and logistics, insurance, testing laboratories, appraisers and experts; and
- ensuring that our website is presented in the most effective manner for users and their computers and their mobile devices.
We will treat your personal data as confidential, and shall not disclose it to third parties, save to the extent that:
- your counterparty or counterparties in an auction sale may require; or
- our appointed third party service providers (e.g. freight and logistics, insurance, testing laboratories, appraisers and experts) reasonably require to enable them to provide the applicable services to us, our client, or you; or Apr 2013
- we may be required to do so by a valid court order; at the lawful request of regulatory, government or law enforcement authorities; or pursuant to other legal processes, or if it becomes necessary to protect our rights or property.
RIGHTS OF ACCESS AND CORRECTION
You have the right to request access to and correction of your personal data held by us. A small fee of HK$50 may be charged towards administration expenses in complying with data access requests but any requests for correction of your personal data will be free of charge.
We will take all reasonable and appropriate steps to protect the security and integrity of all personal data provided to us by electronic means or otherwise. We will ensure that your personal data is suitably protected against both unauthorised physical and electronic access. These measures 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 data protection. However, we cannot guarantee that information during transmission through the internet or any computer network is entirely safe from unauthorised intrusion, access or manipulation. We will have no liability for disclosure of information due to errors or unauthorised acts of third parties. In any event, where we believe personal data has been compromised, we will notify you of this.
If you wish to exercise your rights to access or correct your personal data held by us, or opt-out of our direct marketing activities, you should addressed your correspondence to the Client Services Department which is contactable by e-mail at email@example.com" or by mail to 30/F Bank of China Tower, 1 Garden Road, Central, Hong Kong.
You have a right (without charge) to opt out from receiving direct marketing from us at any time. If at any time you no longer wish to receive our direct marketing, please let us know by contacting our Client Services Department, listed above.
We will not sell or transfer your personal data to third parties for direct marketing.
We intend to use your name, email address, correspondence address and telephone number to directly market our previews, auctions and other events, which relate to our auction business to you but we cannot so use your personal data without your consent.
CHANGES TO THIS POLICY