Introduction
Like most businesses, Royal Estate Auctions Ltd. holds and processes a wide range of information about its clients and other persons who may be interested in Royal Estate Auctions Ltd. services.
This privacy notice applies to all Royal Estate Auctions Ltd. operations in Canada and other global locations and explains the type of information that we process, why we are processing it and how that processing may affect you. This policy, as modified or amended from time to time, as well as the Terms and Conditions, form a binding contract between you and Royal Estate Auctions Ltd.
The privacy notice is split into the sections listed below. The Definitions section explains what we mean by “personal data”, “processing”, and other terms used in this notice.
We may update this privacy notice from time to time, and will post any revised notice on this webpage. Where appropriate we may notify you by email or by a notice on our website that our privacy notice has changed but we recommend that you check this page regularly. Any changes will be immediately effective on posting.
This policy does not apply to the practices of companies that we do not own or control, or to people that we do not employ or manage. Companies such as our Internet access and website and email hosting company, our shipping companies, UPS, FedEx and Canada Post, and others have their own privacy statements which can be viewed on their respective websites.
We will occasionally send e-mails to you. This is required for certain uses of the Website such as user registration and the making of purchases. We may also send information to you regarding your account activity and purchases as well as updates about our products and promotional offers. You may elect to opt-out of receiving promotional emails at any time after registering by e-mailing This email address is being protected from spambots. You need JavaScript enabled to view it. and including your name, address, email address, and what emails you do not want to receive.
Who we are
Royal Estate Auctions Ltd. is an online Auction and Art Gallery focussing on fine art, antiques and collectibles. Head office is at 12-16715 Yonge St, Newmarket, Ontario, Canada, L3X 1X4.
How and when we collect your personal data
Collection directly from you in response to our request
Most of the personal data we process about you comes directly from you (whether face to face, over the telephone, on a paper form, by email or online) for example:
- when you register to bid in an auction, agree to sell your property through Royal Estate Auctions Ltd. or ask us to perform a valuation;
- when you express an interest in buying or selling certain types of property to one of our staff or representatives;
- when you subscribe to Royal Estate Auctions Ltd. Catalogues;
- when you sign up on RoyalEstateAuctions.com to receive news about upcoming auctions and events relating to particular areas of interest;
- when you attend a Royal Estate Auctions Ltd. event.
Automatic collection when you telephone bid, call Client Services, visit our premises or our website
Your voice will be recorded when you call our client service team, and when you use our telephone bidding service.
Your image may be collected by Royal Estate Auctions Ltd. if you attend our premises. We use CCTV at our salerooms and offices for the protection of our staff, our visitors and the property that we sell. We also video our auctions for security reasons and to monitor bidding practices. Live streaming of our auctions is available on www.RoyalEstateAuctions.com (and is also available on social media for certain auctions).
We collect data about your computer when you visit our website, which includes your internet address, your operating system and browser type. We use this information for our internal system administration, to help diagnose problems with our servers, to administer our website and monitor and improve the user experience.
We also collect data about you through cookies. A cookie is a simple text file that is stored on your computer or mobile device by our website’s server which allows our website to remember your preferences or transactions that are in progress. You can see more detail on cookies in our Cookies Policy.
Collection of data from other sources
We may also obtain information about you and/or the property you own or wish to collect from other sources, for example:
- When someone informs us that you are authorized to bid on their behalf at Royal Estate Auctions Ltd. or collect your property;
- When someone introduces you to us (including when they use a lot finder service to email you details of a lot that they believe may interest you);
- When we research artwork or other objects and we find information about you in sources such as newspaper articles, exhibition catalogues, public auction results, or one of our contacts gives us feedback in relation to objects or persons they have been told about.
What personal data do we process and why?
We have set out below the types of personal data that we process, the purposes for which we use it and the legal grounds on which we process it. The Glossary contains more information about the legal grounds for processing.
|
Purpose |
Examples of personal data (please note that the list is not exhaustive) |
Legal grounds for processing |
|
To provide you with requested services (for example, bidding, selling, valuations, storage, shipping, loan referral, catalogue subscription, restoration, expertise) |
· name, title, and contact details (including email address, postal address, telephone numbers) · your bank account details (if we need to pay you) or payment card details or bank transfer receipt (if you need to pay us) · the person or organisation who has introduced you, and any fee they receive · details of the property to which the services relate · nature of the services including contractual terms · details of your insurance if your property remains at your risk · records of your communications with us (including bidding instructions recorded over the telephone or online bidding logs) |
Performance of a contract |
|
To evidence our compliance with legal requirements, (for example, knowing our clients and preventing money-laundering, payment of taxation and customs duties, anti-discrimination) |
· your date of birth, identification documents (including photo) and the results of identification verification checks · details of your past transactions (including any tax paid or tax withheld) and/or shipments (including any permits obtained or duties paid) · any requirements relating to Royal Estate Auctions Ltd. obligation to make reasonable adjustments to accommodate a disability or otherwise meet your specific needs · any information relating to a dispute or legal proceeding |
Compliance with a legal obligation |
|
To keep you, our staff, and property on our premises secure |
· CCTV images |
Legitimate Interests |
|
To provide you with details about upcoming auctions, other events or types of property that interest you, and Royal Estate Auctions Ltd. wider services |
· your name, email address and/or postal address · your marketing and communication preferences (in your account, Royal Estate Auctions Ltd. online preference centre, or any hard copy or digital sign up) |
Legitimate Interests (for clients who have previously requested or received services) Consent (for clients who have not requested or received services but have signed up to receive Royal Estate Auctions Ltd. news online, at an event, by talking to a member of staff) |
|
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 |
· your interest in, possession of, or ownership (historic or current) of any relevant art object, or similar object · allegations of fraud, theft or other unlawful activities relating to an object connected to you · communications with the police, courts, regulators or other government or law enforcement authorities in relation to you or your object |
Legitimate interests Public interest |
|
To monitor the performance of our website and make your user experience better |
· your internet address · your browser type and operating system · the resources you access on your account and our wider website · the data obtained from cookies, web logs and other similar technologies that monitor the use of our website and deliver more appropriate advertisements on or beyond our website |
Legitimate Interests |
|
To monitor your use of our services, train our staff and improve your client or user experience |
· your complaints, opinions, responses to our surveys or market research · your voice when you call Royal Estate Auctions Ltd. Client Services or use our telephone bidding services |
Legitimate Interests |
Who gets to see your personal data?
Royal Estate Auctions Ltd.
Your personal data will be processed by Royal Estate Auctions Ltd. and may also be transferred to and processed by other companies within the Royal Estate Auctions Ltd. group.
Outside the Royal Estate Auctions Ltd. Group
We do not transfer your personal data to organisations who wish to use it for their own marketing promotions or other purposes. We only transfer your personal data to other organisations where it is necessary to enable us to provide you with the services you have requested (for example: we may transfer your data to our bank, payment card acquirers, shippers, warehouses, insurers, experts who help us authenticate or value property, event venues, caterers, catalogue and direct marketing fulfillment and distribution). Where we do so it will be on the basis that these organisations are required to keep the information confidential and secure, and they will only use the information to carry out the instructed services. Some of these organisations may be located outside of Canada and you should refer to the section Is your personal data transferred out of Canada? for more information.
We may also need to retain and disclose certain information about you to appropriate agencies to conduct anti-money laundering and trade sanction checks and to assist with fraud and crime prevention and detection.
No government entity has direct access to your data. Where we receive a request from a government or law enforcement authority to provide your data, we will only disclose such information where we are ordered to do so by a court or we are otherwise satisfied after internal review that the body making the request has both the right to seek disclosure and has followed the correct process.
Is your personal data transferred out of Canada?
Royal Estate Auctions Ltd. may in the normal course of its business transfer your personal data outside of Canada to other organisations who need to process your data in connection with the services that Royal Estate Auctions Ltd. provides to you (see Who gets to see my data?). Your data will also be held on Royal Estate Auctions Ltd. servers located in Canada.
Other countries offer varying standards for the protection of personal data and your privacy rights and in some cases, these standards are lower than equivalent Canadian standards.
If you have any questions or would like further information about how we make personal data available outside of Canada please contact us (see Contact Information below).
How long will we keep your personal data?
We will retain your personal data for as long as is necessary to provide the relevant services, maintain business records to satisfy tax, legal and other regulatory requirements, and protect and defend against potential legal claims.
In the context of our research and records on ownership of art objects to assist with checks on authenticity, provenance and title, we will keep this data for as long as the record is relevant to our legitimate business interest and the public interest.
What steps do we take to keep your personal data secure?
We will take all reasonable and appropriate steps to protect the security and integrity of all personal information provided via our website, or by any other means electronic or otherwise.
We use a variety of security technologies and procedures to help protect your personal details from unauthorized physical and electronic access.
As effective as modern security practices are, we cannot guarantee the complete security of personal data held in our systems, nor that the information you supply through the internet or any computer network is entirely safe from unauthorized intrusion, access or manipulation during transmission. Any transmission is at your own risk. We will not be liable for any resulting misuse of your personal data.
Third party websites
Royal Estate Auctions Ltd. websites may contain links to other websites not operated by Royal Estate Auctions Ltd.. The information you provide to us will not be transmitted to other websites, but these other websites may collect personal information about you in accordance with their own privacy notice. Royal Estate Auctions Ltd. cannot accept any responsibility for the privacy practices or content of those websites.
Access to your data and other rights
We try to be as open as we can about the data that we process and recommend you ask us if you have questions about the data we hold on you.
Subject Access Requests
If you are a resident of Canada, you have the legal right to make a “subject access request”. If you exercise this right and we process personal data about you by automated means or as part of a Filing System, we are required to provide you with a description and copy of that personal data, and tell you why we are processing it.
Other rights for Canadian residents
As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing, or have its processing restricted.
If you have provided us with data about yourself and the grounds for processing is Contract or Consent (see What personal data do we process and why?), you have the right to be given the data in machine readable format for transmitting to another data controller.
If we are relying on Consent as the grounds for processing your data (see What personal data do we process and why?), you may withdraw consent at any time. This will not affect the lawfulness of Royal Estate Auctions Ltd. processing of your data prior to your withdrawal.
Rights for California residents
If you are a resident of California you may have a right pursuant to Section 1798.83 of the California Civil Code to obtain certain information about the types of personal data that we have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties.
Please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it. if you would like to exercise any of your rights explained above in relation to your personal data.
Children
Royal Estate Auctions does not design any part of its website to attract anyone under age 18. We will not knowingly contact children under age 18 without a parent's permission. We do not knowingly ask a child under age 18 for any personal information.
Contact Information
If you have any queries in relation to Royal Estate Auctions Ltd. processing of your personal data please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it.. You can also phone or email our Client Service team.
Complaints
If you have any complaints relating to the processing of your personal data, please contact us at This email address is being protected from spambots. You need JavaScript enabled to view it.. You can also phone or email our Client Service team.
Definitions:
Compliance with a legal obligation - processing is necessary to ensure we comply with our legal and regulatory obligations.
Consent – you have given specific consent to the processing of your personal data.
Data Controller – the person who determines the purposes and means of processing personal data.
EEA – the European Economic Area which comprises countries that are members of the European Union and Norway, Iceland and Liechtenstein.
Filing System – a structured set of personal data that is accessible according to specific criteria.
Legitimate Interests - processing is necessary for our or a third party’s legitimate interests in carrying on, managing and administering our respective businesses effectively and properly (except where our or the third party’s interests are overridden by your own interests, rights and freedoms).
Performance of a contract – processing is necessary to carry out our contractual duties, exercise our contractual rights or otherwise perform our contract with you, or to take steps at your request to enter a contract.
Personal Data - any data relating to an identified or identifiable natural person. This can include names, user ID, location data, email addresses, photographs, job applications, purchase history, user account information, opinions, and correspondence to and from an individual.
Processing - any operation performed on personal data, such as collection, recording, storage, retrieval, use, combining it with other data, transmission, disclosure or deletion.
Public Interest – processing is necessary for the performance of a task carried out in the public interest.