Haarlem Heritage

Privacy Policy

Effective Date: 10 June 2024

SCOPE
Welcome to the Haarlem Heritage Auctioneers companies. This is the Privacy Policy of Haarlem Heritage Auctioneers, details of which can be found here. From its beginnings in 1744, Haarlem Heritage Auctioneers has built its business on the trust of its customers, clients and visitors. We endeavor to understand their interests in art and design and, at the same time, protect their privacy. Those values remain essential to us even as we have grown into a global network of offices in approximately 40 countries. Haarlem Heritage Auctioneers publishes this Privacy Policy to let you know how we collect, use, and disclose your personal information in the course of operating our business. It also describes your rights in relation to this information. In some circumstances, such as for certain events, we may provide additional information regarding our data practices. This Privacy Policy applies to any Haarlem Heritage Auctioneers service, event, website, mobile application or other digital or non-digital service, and any hard copy (paper) form which provides a link to or refers to this Privacy Policy.

INFORMATION Haarlem Heritage Auctioneers COLLECTS ABOUT YOU
Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified. As described in more detail below, we collect personal information about you from a variety of sources, including information we collect from you directly, information we collect about you from other sources, and information we collect automatically from you.

Information We Collect Directly From You
We collect information that you submit to us face-to-face, over the telephone, on a paper form, by email or online or provide to us on forms available on third-party websites. The types of information that we collect directly from you include: personal details (e.g., name, date of birth, alias and/or avatar alias), contact details (e.g., phone number, email address, postal address), transaction information (e.g., bidding or purchase records, shipping details, information about items you purchase or wish to sell or consign), details about your collection, financial information (e.g., tokenized payment information in connection with your purchases, wire instructions, bank account or bank transfer details, digital wallet details and address), username and password, user ID, unique device ID, information on forms required for certain transactions (e.g social security number), insurance details, and identification information (e.g. photo ID and proof of address).
We rely on the information you provide to us or that we collect or observe about your individual interactions with us, for example, if you attend a live event, sell or consign property, participate in one of our auctions or sales, become a client, register or bid online.

Information We Collect From Other Sources
We may collect information about you from external sources, including social media sites and data supplementation services. The types of information we collect about you from other sources include your public profile information, family relationships, organizational affiliations, results of verification checks, nature of your connection to an organisation, your source of wealth, whether you are subject to sanctions, a PEP or a family member or close associate of a PEP. We may work to expand our customer base by acquiring names, contact data, financial information, affiliations, and demographic information from other sources such as private companies, public registers, and social media sites, where permitted by law. We may also generate information such as appraisals, profiles, and a history of our relationships with you based on the information you have provided or that we have obtained from other sources, as permitted under applicable law.

Information We Collect Automatically
We may make video recordings of our auctions (including for security reasons and to monitor bidding), gallery spaces, and certain live events.
Live streaming of our auctions and certain events is available on our websites and on social media for certain auctions. Cameras and microphones recording images and sounds for live streaming focus primarily on auctioneers, presenters and our specialists but it is possible that background sound and images may be captured.
We use CCTV at our sales rooms and offices for the protection of our staff, our visitors and the property we sell.
We record calls made to our customer care and telephone bidding lines for quality assurance, compliance purposes, and recordkeeping purposes.
We may use common data collection technologies as you visit our websites or apps or interact with our emails. For example:
– Our logs gather date, time, information about your browser and system or device configuration, information about how you interact with our digital properties, and an IP address for all visitors to our sites.
– If you have registered with us online, we use data collection technologies to collect information that indicates your individual interests in our websites, online platforms and apps, and your response to our emails and marketing campaigns.
– In general, our app will communicate data you provide about yourself, for example, registration, purchase, or bidding data, to our databases and systems. An app may, however, rely on other data collection technologies to recognize the device you use for viewing and to personalize your experience. If our app relies on additional data collection technologies that collect or use data about individual users, we will include additional notice either within the app or in a policy that accompanies it.
– We also use and allow certain other companies to use technologies that are similar to cookies (for example pixels and gifs) when we send you emails.

HOW Haarlem Heritage Auctioneers USES INFORMATION ABOUT YOU
Haarlem Heritage Auctioneers uses data about you for the following purposes, as permitted by applicable law:
– To provide you with the requested services. For example, bidding, selling, valuation, storage, shipping, loans and loan referral, restoration and expert advice.
– To manage and assure the integrity of our auctions.
– To on-board you as a client, verify your identity and sources of wealth and to satisfy our know your client obligations, to enter into and fulfill contracts with you, to fulfill your orders and purchases, facilitate sales or consignments, provide the publications, catalogs, and information you request, to manage your account, enquiries and requests and your relationship with us.
– To identify products, services, and offers you may be interested in based on your transactions and interactions with us, including but not limited to consignments, bidding histories, payment histories and events attended.
– To where you consign or sell property with us, advertise and sell your property on any of our international and country-specific apps, websites and digital properties.
– To send you information about upcoming auctions, events, types of property and content that you may be interested in.
– To improve and personalize based on your inferred interests from our website and services.
– To match online ads to your interests, arrange for Haarlem Heritage Auctioneers and other companies’ ads to reach you after you have left our sites, and help advertisers show you ads that are more relevant to your interests.
– To expand our online audiences.
– To provide, maintain, and protect our digital offerings.
– To monitor the performance of our websites, apps and digital properties and improve your user experience.
– To satisfy legal obligations and compliance requirements under laws and regulations applicable to Haarlem Heritage Auctioneers Inc. For example, know your client, to check and verify your identity and to protect against the risk of fraud and to detect and prevent money laundering or other financial crime.
– To carry out anti-money laundering checks, risk screening, crypto wallet and transaction screening and monitoring and blockchain analytics.
– To create and maintain records of art objects to assist us (and in the case of our public records including our online lot pages and online and printed catalogues to assist the public) with checks on authenticity, provenance, title and object value and to prevent fraud, theft or other unlawful activities.
– To provide you (where required) with a digital wallet to enable you to receive an NFT that you have purchased.
– To identify an alternative third-party auction or sale house where your property does not meet our requirements or is not suitable for consignment with or sale by us. In the event you choose to consign or sell your property with such third party auction or sale house such third party will provide us with details of any sale to enable us to confirm and audit any introductory commission that may be due to us.
– To protect and defend our rights and property, you, or third parties.
– To keep you, our staff and property on our premises secure.
– To comply with legal obligations and regulations to which Haarlem Heritage Auctioneers are subject and cooperate with regulators, other appropriate agencies or authorities and law enforcement bodies, both within your jurisdiction and internationally.
– To develop, improve and test certain of our products and services.
– To monitor the use of our services, train our staff and improve your client or your user experience. For example, through survey or market research.
– For other purposes that we tell you about specifically when you register or provide data about yourself to us.

HOW Haarlem Heritage Auctioneers DISCLOSES INFORMATION ABOUT YOU
Your personal information will be processed by the Haarlem Heritage Auctioneers entity that initially receives it. We also share information within the Haarlem Heritage Auctioneers for the purposes set out in this privacy policy.
Haarlem Heritage Auctioneers may disclose personal information to other companies or entities as follows:
– To business partners and vendors that work on our behalf to provide services such as property shipments, mailings, customer account and technology support, secure payment processing, experts who help us authenticate or value your property, fraud prevention, digital marketing management, and data and property storage or warehousing.
– To our auction or sales partners in association with auctions or sales. For example, when we offer auctions or sales with our group or third-party partners, we may share auction or sale-related data with those partners subject to the privacy policy or policies made available to you when registering for or bidding in association with the auctions or sales.
– To consigners, sellers, buyers, customs authorities and others as needed to facilitate a consignment, sale or purchase, including to arrange the collection, delivery or shipment of property.
– To organizations we partner with to host events and those who are involved in such events such as caterers and the event venues.
– To law enforcement or other entities that present valid legal process or in our discretion, unless otherwise prohibited by law, to protect human safety, our rights, or the rights of others.
– To meet certain legal compliance requirements, for example under anti-money laundering laws or customs laws and regulations.
– To US, UK, EU, Asian and other domestic and overseas regulators, law enforcement agencies and authorities and other appropriate agencies or authorities in connection with their duties, such as preventing, investigating or detecting crime or to conduct money and trade sanction checks and to meet our compliance, legal and health and safety obligations.
— To identity checking and verification, AML, fraud and risk screening services, including for sanctions and/or negative media purposes.
– To an alternative third-party auction or sale house where your property does not meet our requirements or is not suitable for sale by us to identify if you would like to consign or sell certain items with such third party.
As part of a sale, merger, liquidation, or transfer of our business assets.

· YOUR CHOICES
You have a choice about and control over:

– Receiving marketing messages from us. We may contact you by email, text, or SMS messaging. You may stop email marketing by using the “opt out” or “unsubscribe” mechanism at the bottom of our email marketing messages. In most cases, we will give you a choice about stopping just one kind of email or opting out of all email marketing from us.

– Whether cookies can be set or read on your browser. You can learn more about controlling cookies placed on your device as you visit our sites in our Cookie Policy.

– Whether your account is up to date. You may review and edit the personal information that is stored in your user account on our website (e.g., your passwords and other contact information) by visiting the “Profile” area of your account on our website or by contacting Haarlem Heritage Auctioneers via the email address at the end of this Policy. We will endeavor to respond to your request as soon as practicable. Before we are able to provide you with any information, correct any inaccuracies, or delete any information, however, we may ask you to verify your identity and to provide other details to help us to respond to your request.

· INFORMATION SECURITY AND STORAGE
Haarlem Heritage Auctioneers is a global company. We receive data collected locally by members of the Haarlem Heritage Auctioneers and collect data online directly from individuals in countries around the world. Haarlem Heritage Auctioneers may in the normal course of its business transfer your personal information internationally to Haarlem Heritage Auctioneers salesrooms, offices and representatives, and to other organisations who need to process your data in connection with the services that Haarlem Heritage Auctioneers provides. We may process that data on servers globally. Your data will also be held on our servers in the NL.
We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Please be aware, though, that no security measures are perfect or impenetrable. You remain responsible for protecting your username and password and for the security of information you transmit to us over the Internet.
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

  • – Maintain business records for analysis and/or audit purposes.

  • – Comply with record retention requirements under the law or other relevant legal or regulatory requirements.

  • – Defend or bring any existing or potential legal claims.

  • – Deal with any complaints regarding the services.

  • – Preserve historical records of transactions and property.

We will delete your personal information when it is no longer required for these purposes.

· CHILDREN’S DATA
Our websites are directed to adults. We do not accept children as clients or knowingly collect data about them.

· THIRD PARTY WEBSITES
Our websites may contain links to other websites not owned or controlled by Haarlem Heritage Auctioneers. Those websites may collect information about you. Haarlem Heritage Auctioneers is not responsible for their practices or content.
Additionally, we may work with auction partners so that you can bid on Haarlem Heritage Auctioneers items from other sites or platforms. If you participate in an online auction on another company’s site or platform, please note that those companies may transfer data about you to us to fulfill successful bids and that we may use that data in a manner consistent with this Policy. Please note that if you use another company’s auction site, you should review the posted privacy policy applicable to that site.

· Your Rights
You may ask us if you have questions about the data we hold on you. Under certain circumstances, subject to local law requirements, you may have rights under data protection laws applicable to your personal data. These may include a right to a copy of your personal information, to correct it, erase it, restrict our use of it, or to transfer it to other organizations at your request subject to local law. You may also have rights to object to some processing and, where we have asked for your consent to process your data, to withdraw this consent. Please contact us at info@haarlemheritage.nl if you wish to exercise any of the rights that apply to you and your personal data.

· HOW TO CONTACT US
For questions about this Privacy Policy please email us at info@haarlemheritage.nl or contact:
Haarlem Heritage Auctioneers
Department of Law and Technology
Paltsstraat 106, 2033 JV, Haarlem
The Netherlands