PRIVACY POLICY

Introduction

The privacy of the data of our clients, employees and third parties is a priority to Adam’s Auctioneers and we strive to maintain its security. This privacy policy was created to alert data subjects to the collection of their data, how it is collected, how it is used and how you can make a subject access request. This policy was created in order to comply with the current Data Protection Legislation, including the Data Protection Bill 2018 and the EU General Data Protection Regulation (‘GDPR’) and all other relevant legislation.

Who is Adam’s Auctioneers?

Adam’s Auctioneers (James Adam and Sons Ltd, trading as Adam’s) is a Fine Art Auctioneers and Valuers situated in 26 St. Stephen’s Green, Dublin 2, D02 X665. The organisation was established in 1887 and currently offers specialist sales ranging from Important Irish Art, Fine Period Furniture, Fine Jewellery & Watches, Silver & Objects of Vertu, Contemporary & Modern Art, Militaria & Memorabilia as well as varying other valuation services. Adam's is proud of its relationship with its clientele and is a privately held company. Today, Adam’s Auctioneers is one of the fastest growing companies in its field, offering a service of distinction as Ireland's principal auction house. In relation to the current Data Protection Legislation, both European and National, Adam’s Auctioneers acts as both a controller and a processor. All this processing is done with all relevant Data Protection Legislation strictly applied

How we collect your data?

Direct Data Collection

Adam’s Auctioneers is required to collect information that you voluntarily submit to us in order to achieve the best user experience and respond to your requests efficiently. Adam’s Auctioneers may collect your data in several ways through several mediums. Data may be collected via phone, email, physical & digital forms and our website. Adam’s Auctioneers is the sole owner of this information. Adam’s Auctioneers only collects data that you voluntarily submit to us. We do not sell this information. Adam’s Auctioneers does not collect any further information regarding the data subject without further consent and does not create any further personal information from the information provided.

Automatic Data Collection

When you visit our website (www.adams.ie), your data will be automatically collected. This includes your computer and devices (including your internet address and browser type) to facilitate and personalise your experience, for security and analytical purposes (including trend analysis) and system administration.

Your data may also be automatically collected when you visit the premises of Adam’s Auctioneers on St. Stephen’s Green due to the presence of CCTV. Our CCTV monitors the property 24 hours, 7 days a week and may store your image for up to 40 days. Our CCTV is in place for the purpose of security and the health and safety of staff.

Our website also uses Google Analytics to monitor the number of visits to our website at any one time. Google Analytics collects information about your device, your browser and your location. This information is deemed as personal information and is retained under strict security measures. Google Analytics may collect your IP address, email, username, etc. In the case of a Subject Access Request, this information is also in scope.

What data do we collect and why?

Adam’s Auctioneers collects data about you which we place in our secure systems. We often collect information about our clients. This includes names, addresses, emails, phone numbers, etc. We may also collect your credit card data & bank particulars. This information is stored securely in our applications. This information is required in order to fulfil the contractual agreements between Adam’s and the client.

Data Retention

Adam’s Auctioneers may need to retain your data for several reasons.

• Completion of contract/service
• Statutory Requirements
• Completion of purpose

The retention period for each of these varies with completion of purpose, services and contracts varying per customer. The retention of data for statutory requirements is the current year plus 6 years. More information regarding the retention of data can be found in the data retention policy which can be retrieved by emailing dataprotection@adams.ie

Our legal basis

When users sign up to the ‘My Adam’s’ online account, this is your opt-in consent for your data to be processed in relation to this account. Upon the creation of this account, the user’s e-mail address will be used for marketing purposes and the user can amend their e-mail category preferences by logging into their account and amending their preferences at any time.

If you complete our physical forms when registering and provide us with your e-mail address, you will be invited to sign up for a ‘My Adam’s’ account. Upon receiving your welcome email, you can decide to create a ‘My Adam’s’ account and avail of its full functionality. By logging in to your account you can amend your e-mail marketing preferences or unsubscribe at any time or simply email our Data Protection Lead at dataprotection@adams.ie

The principles of data protection1. Lawfulness, Fairness and Transparency

The first principle of the Data Protection Legislation is the basis of all the processing of personal data within Adam’s Auctioneers. All Adam’s Auctioneers employees have been trained on the meanings of these principles. The data collection procedures within Adam’s Auctioneers have been altered to ensure the lawfulness, fairness and transparency of data processing and to ensure the data subjects are fully informed at all times. In order to comply with this Data Protection Principle, Adam’s Auctioneers has created this Privacy Policy, and has updated various other policies that relay information regarding lawful, fair and transparent processing.

2. Adequate, relevant and not excessive

All data held about data subjects must be adequate, relevant and not excessive. To ensure this, Adam’s Auctioneers has updated their forms both physical and electronic to ensure adequate information is collected on data subjects. A review has been done to ensure that all the information we collect is relevant to the reason for collection.

3. Accurate and up to date

Adam’s Auctioneers strives to ensure that all information held about the data subject is accurate and kept up to date. This is often a difficult task due to the number of data subjects in contact with the organisation. In order to comply with this principle, an Adam’s Auctioneers employee may ask you to verify the information we hold about you to ensure it is up to date. You can also contact us if you have changed any information and would like it corrected on our system. This can be done by emailing info@adams.ie or by phoning the Adam’s Auctioneers office.

4. Purpose Limitation

Personal data may only be collected for specified, explicit and legitimate purposes and must not be further processed in a manner that is incompatible with those purposes. In Adam’s, we will not use your data for any process that may fall outside our legal basis of consent and legitimate interest. You can opt out of communications from Adam’s Auctioneers at any time.

5. Storage Limitation

We have implemented a Data Retention policy which details the periods of retention for each category of data held by Adam’s Auctioneers. Personal data will not be retained by Adam’s Auctioneers for longer than stated in the data retention unless there is a legal reason.

6. Data Minimisation

Adam’s Auctioneers will only collect the information it needs about you in order to process your purchases or the services you require from us. The forms on the Adam’s Auctioneers website and our physical forms have been updated to reflect this.

7. Accountability

Adam’s Auctioneers is doing its utmost to prove its accountability for the processing of personal data within the organisation. Eamon O’Connor has been appointed as our Data Protection Lead. All staff who process personal data have received GDPR training. All policies and procedures have been updated to clarify the steps staff have to take to ensure maximum security of personal data.

Your rights

In compliance with the data protection regulations, both National and European, data subjects have rights to their data and Adam’s Auctioneers strives to facilitate the easy exercising of these rights. To exercise any of the rights listed below this request should be made in writing to our Data Protection Lead by emailing dataprotection@adams.ie or by sending a letter to 26 St.Stephen’s Green, Dublin 2, D02 X665. In order to process any of the below requests, you will be requested to verify your identity through the provision of a passport/driver’s licence and proof of address. All of these requests will be completed in the mandatory period of time set out in the data protection legislation, which is one month. This may be extended by 2 months but you will be notified in writing via email or post by our Data Protection Lead.

Right to be informed

Under data protection legislation, a data subject has the right to contact the organisation and determine whether the organisation has data on them.

Right to Access

Under data protection legislation, a data subject has the right to obtain a copy of the personal data an organisation holds on them. This data is supplied in a commonly used electronic form and is given in clear, concise and intelligible language.

Right to Erasure

Under data protection legislation, a data subject has the right to request the erasure of their data but this is not a complete right. The erasure of data can only occur under certain circumstances, where there are no legal obligations or statutory requirement to retain the data.

Right to Rectification

Under data protection legislation, a data subject has the right to rectify any data held on them by Adam’s Auctioneers. This is not an absolute right. The organisation can refuse to rectify the data if it has reason to believe that the data held about you is correct. If you feel this is incorrect, you have the right to lodge a complaint with the Office of the Data Protection Commissioner.

Right to Object

Article 21 of the GDPR gives individuals the right to object to the processing of their personal data. This effectively allows individuals to ask you to stop processing their personal data.

The right to object only applies in certain circumstances. Whether it applies depends on your purposes for processing and your lawful basis for processing.

Refusal to process Subject Access Request

Adam’s Auctioneers has the right to refuse the completion of a Subject Access Request on the grounds of excessiveness or if the request is deemed to be unfounded. If a request is deemed to be excessive or unfounded, you will be notified in writing of this and the reasons it has been classed as this. If you feel this is incorrect, you have the right to lodge a complaint with the Office of the Data Protection Commissioner.

Subject Access Request Fees

Adam’s Auctioneers has the right to charge for the completion of a Subject Access Request on the grounds of excessiveness or if the request is deemed to be unfounded. If a request is deemed to be excessive or unfounded, you will be notified in writing of this and the reasons it has been classed as this. If you feel this is incorrect, you have the right to lodge a complaint with the Office of the Data Protection Commissioner. The cost will be calculated by determining the administration cost of fulfilling the request by calculating the number of hours spent on the request by the Adam’s Auctioneers’ resources.

Third party access

Adam’s Auctioneers will not transfer your personal information to third parties unless you have been provided with an opportunity to opt into this disclosure. Adam’s Auctioneers may disclose your personal information without your opt-in with selected third party service providers, including:

• Business partners, suppliers and sub-contractors for the performance of any contract that we enter into with them or you;
• Advertisers and search engine providers that assist us in the improvement and optimisation of our website

It is our practice to require such third party service providers to keep your personal information confidential and to use your personal information only to perform functions for Adam’s and in accordance with our instructions.

We further reserve the right to disclose your personal information to respond to authorised information requests from government authorities or when otherwise required by law.

The security of your data

The security of your data is priority to Adam’s Auctioneers and we strive to maintain that it is kept in a manner that retains the data’s confidentiality, integrity and availability. Adam’s Auctioneers have put technical and organisational measures in place to ensure maximum protection. All staff within Adam’s Auctioneers have been trained on data protection legislation and their associated principles and concepts. Refresher courses are offered for employees on a yearly basis. Adam’s Auctioneers also works with several IT providers to ensure the implementation of sufficient security on all applications and websites that collect and store data. We review policies on a yearly basis with updates needed as required.

External links

This website contains links to other sites which are outside the control of Adam’s Auctioneers. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Cookies

A cookie is a text file sent by a web server - a device where one or more websites are stored - to a web browser, and stored by the browser. The text file is then sent back to the web server each time the web browser requests a page from the web server. This enables the web server to identify and track the web browser and provide richer user experiences for visitors to a website.

Our website is powered by the Joomla Web Content Management System (CMS). By default this automatically installs a cookie into your web browser as soon as you visit this website. Below, this cookie is referred to as a "session" cookie; that means, the cookie lasts only as long as your current session when using our website.

Currently, we use cookies to count the numbers of visitors and understand how to serve our visitors and customers better. We may install and use various plugins or extensions that help enrich the experience of using this website, and which may also use additional cookies, to, for example, monitor how successful each plugin or extension is, or further count the number of times a plugin or extension is used. In this way, those providers can measure the effectiveness of their solutions and make changes to improve their products.

We use Google Analytics to analyse the use of this website. Google Analytics generates anonymous statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google's privacy policy is available at: http://www.google.com/privacypolicy.html

Below is a full list of cookies that we currently use on this website at the time of writing this update:

• __utma, __utmb, __utmc, __utmz = from Google Analytics. These cookies are installed in a visitor's web browser when they agree to have cookies stored on their web access device. These cookies are used to collect information about how visitors use our website. We can then use the resulting data to generate reports that can help us improve the website experience. These cookies collect data anonymously; the resulting information allows us to identify the number of visitors who have come to the website, where visitors have come from, and which web pages visitors viewed while on our website.
• Joomla session cookies (for example: ddfd5b8e2eb21abeda21d8f744ea3c4a) = cookies that are part of Joomla website Content management System (CMS) for this installation, normally automatically installed into a visitor's web browser when visiting this website. The cookies are active only for the current session, and are deleted when the web browser is closed.

If you choose not to accept cookies, then only the standard Joomla session cookie will load and be active until you close your web browser, the website will not function as intended and some facilities will be unavailable.

Most browsers allow you to refuse to accept cookies. This choice will, however, have a negative impact upon the usability of many websites, including www.adams.ie

Most browser companies provide instructions on disabling cookies on their web sites. The most popular browser companies are listed below:

• Google Chrome
• Microsoft Internet Explorer
• Firefox
• Safari

You can learn more about cookies at AboutCookies.org

How to raise a concern or a complaint

If you have any concerns regarding the processing of your personal data by Adam’s Auctioneers, you have a right to raise a concern with our Data Protection Lead. This concern can be raised in any form; phone, email or writing through the information listed below. If a concern is raised via phone, a written confirmation of the concern may be sent to the data subject for our records.

If you have a complaint regarding the processing of your personal data, this concern can be raised in any form; phone, email or writing through the information listed below. If a concern is raised via phone, a written confirmation of the complaint may be sent to the data subject for our records. You may also send your complaint to the Office of the Data Protection Commissioner.

Contact our Data Protection Officer at:

Email: dataprotection@adams.ie

Tel: +353 (0) 1 676 0261

Address: 26 St Stephen’s Green, Dublin 2, D02 X665