|1.0||17th May 2022||Rachel Goode||Alan Newman||Approved policy|
|Date||17th May 2022|
This document has been prepared using the following ISO27001:2013 standard controls as reference:
|A18.1.1||Identification of applicable legislation and contractual requirements|
|A18.1.4||Protection of PII|
Sensible Development Ltd (we, “Sensible”) is located at Cornelius House, 178/180 Church Road, Hove, BN3 2DJ operates primarily in the head office of Vantage Point, New England Road, Brighton, BN1 4GW.
Information Security Policy Statement
Address: Units 4-8 Vantage Point, New England Road, Brighton, BN1 4GW
Phone Number: 01273 621110
The type of personal information we collect
When you register as a user of our sites we currently collect and process the following information:
- First name, Last Name, Email Address, Company Name, Website, Telephone Number, Postal Address including Country.
Whether we may contact you about future sales.
You may also optionally provide us with:
- Company VAT number,
- Mobile Number
When you apply to bid on an auction or purchase samples we may ask for further information:
- Credit card details (card number, expiry date and security code) NB. Card details will not be stored on the Website. They will be passed through to Stripe or Paypal (a payment processing platform) maintaining PCI compliance.
- Billing address (including 1st line of address, postcode and country)
- Delivery address (including 1st line of address, postcode and country)
How we get the personal information
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- You have visited our website.
- You have signed up to our newsletter.
- You have registered as a user of our website.
- You have applied to bid in an auction.
- You have placed bids in an auction.
- You have purchased samples.
- You have won lots
- You have put a lot in your watchlist
We also receive personal information indirectly, from the following sources in the following scenarios:
- You have informed us that you are bidding as a group through Whatsapp, Email or Telephone.
- Correspondence or surveys about what types of lots you are interested in purchasing.
- Records of payments through Stripe or Paypal payment processing
When you use our website we will automatically collect:
- Details of transactions you carry out through our Website and of the bids (successful or otherwise) you may make during any auction(a)/(b);
- Your IP address, operating system and browser type, for systems administration and to report aggregate information internally and to our vendors (d).
How we use the information you have given us
We use the information that you have given us in order to:
- Allow you to log in to the Website and use our services (b) (d);
- Track your browsing habits and interests on our Website (d);
- Email you with suggested lots or auctions that you may be interested in based on your browsing habits and interests and to remind you about lots that you have watch-listed, if you have opted-in to receiving these emails(a)(d);
- Text you via SMS or email you with updates on bids that you have placed (a) (d);
- Allow you to register and bid at auctions listed on the Website (d) ; and
- General analytics (d).
- to investigate, detect and prevent fraud and any other crimes(c)/(d); and
- to create statistics, analyses and profiles to develop and improve our services (d).
We may share this information with:
- Our vendors to allow them to enter into a contract with you for the purchase and delivery of goods (b)
- Where agreed, partners who provide services such as delivery of goods (b) (d).
Our Website allows us or our vendors to accept or reject users who have applied to bid based on some or all of the following criteria:
- whether the bidder has registered a valid payment card which passes payment security processes (AVS or 3D Secure);
- whether the bidder has registered using a valid email and/or telephone number;
- the country where the bidder is located.
Lawful bases for processing this information
- Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
(a) Your consent. You are able to remove your consent at any time. You can do this by unsubscribing from emails, changing your preferences on the website or by contacting us using the contact details above.
(b) We have a contractual obligation.
(c) We have a legal obligation.
(d) We have a legitimate interest.
How we store your personal information
Your information is securely stored on our Website and backups are stored on a secure server.
We keep your personal information for up to 5 years from when you were last active on the site. We will then dispose of your information by removing your personal information and depersonalising your auction activity.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at firstname.lastname@example.org, +441273 621110 or Sensible Development, Vantage Point, New England Road, BN1 4GW, if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at email@example.com, +441273 621110 or Sensible Development, Vantage Point, New England Road, BN1 4GW.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk