REDC UK LIMITED

WEBSITE PRIVACY POLICY

This document outlines REDC UK Limited's (we/us/our/the Company) Privacy Policy for visitors to our website (the Website).

We have developed this Privacy Policy so that you may feel confident about the privacy and security of your personal information. This Privacy Policy (together with the Terms and Conditions of Use of the Website and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, the purpose of our collection of it and how we protect the information. We are responsible for the processing of your personal data and we are the data controller for all such information.

Countries in the European Economic Area (EEA) are required to have a similar standard of protection of personal data. This is not always the case outside that area. We may transfer data outside the EEA and before doing so take steps to ensure that there is adequate protection, as required by the Data Protection Act 1998 (the Act).

It is possible that your information will be transferred to the USA where our parent company is based, in which case we will ensure compliance with the Act.

1. Information collection and use

Visitors to Our Website

1.1 The Website does not collect personally identifying information from your computer when you browse this website and request pages from our servers. This means that, unless you specifically and knowingly provide us with personally identifiable information, we will not know your name, your email address, or any other personally identifiable information. Information is collected through the completion of on-line forms and is of the type listed in paragraph 1.11 below. We do collect aggregate information such as pages visited, which is necessary for us to be sure that our site functions correctly.

1.2 As data controller, we take all necessary steps to comply with the Act (as amended, restated or re-enacted from time to time) and its relevant subordinate legislation when handling any personal information.

1.3 When you supply any personal information to us we will meet our legal obligations to you in the way that we deal with that information.

1.4 In accordance with the Act we are required to collect the information fairly and to let you know how we will use it (see paragraph 1.12 for details of our proposed use) and whether we will pass the information on to anyone else (see further paragraph 2 below on Disclosure).

1.5 We will comply with the Principles set out in the Act.

1.6 We will take reasonable precautions to safeguard your personal data against loss and unauthorised disclosure or access (see paragraph 2).

Cookies

1.7 We may work with third parties to research certain usage and activities on the Website on our behalf. No personal information about you is shared; however, in the course of conducting this research these third parties may place a unique "cookie" on your browser.

1.8 A cookie is a small file which is sent to your browser and stored on your computer's hard disc and helps us understand and track your use of the Website and where we can improve the information and services provided.

1.9 We use cookies solely to gather information on IP addresses, to analyse trends, administer the Website, track users’ movements on the Website and gather broad demographic information for aggregate use. IP addresses are not linked to other personally identifiable information and will not be used to deliver targeted marketing messages.

1.10  For information about blocking the use of cookies on our website, please refer to the instructions/help screen on your internet browser. For information about cookies generally, please visit www.allaboutcookies.org. Please note that you may not be able to use or access certain parts of the Website or online services if you block the use of cookies.

Collection

1.11 We may collect and process personal information about you, including but not limited to your full name and contact details such as email address, home address and telephone number, user names, passwords or any other personal information deemed necessary:

1.11.1 when you register, log in or complete other online forms;

1.11.2 when you respond to requests to submit personal information about yourself (if any);

1.11.3 when you otherwise contact us and we may keep a record of that correspondence; or

1.11.4 based on any other information we receive about your transactions from our files, our affiliates or another source whether involved in your transactions or otherwise.

Use

1.12 This Website generally uses information supplied by you for the following purposes, to

1.12.1 allow you to create your own user specific area in which you can save property listings;

1.12.2 offer a tailored profile service, which you can access and edit;

1.12.3 deliver to you services and information which you have requested;

1.12.4 faciliate you registering your attendance at our auctions online;

1.12.5 ensure that content from the Website is presented in the most effective manner for you and for your computer;

1.12.6 carry out our obligations arising from any contracts entered into between you and us and any third party which impacts on the provision of our services, including, but not limited to, anti-money laundering check performed by third-parties on our behalf;

1.12.7 market or promote the services we, our affiliates and other connected sources offer to you, for example by telephone, email or post, subject to your rights contained in paragraph 1.17 below; and

1.12.8 contact you for your views on our services and events, for example by email or post and to notify you occasionally about important changes or developments to the Website or our services, subject to your rights contained in paragraph 1.17 below.

1.13 We may also keep a record of those parts of the Website that you use most often to enable us to monitor, support, improve and develop our service and to know which parts are of the most interest to you.

1.14 We also use this information to better understand how visitors use our website and how we can enhance and improve your experience, its contents and functionality to meet your needs and personal interests. We will also log the webpage visitors were on before visiting us, and use that data to formulate statistical models.

1.15 By using the Website you consent to our collection and use of this information. If you do not agree to us acquiring or using your personal information in accordance with this policy you should not submit information to us through the Website.

1.16 The information you supply to us will be held on our computers in the US and the UK.

1.17 You can at any time send an email to privacyuk@redcgroup.com or write to us at REDC UK Limited, 2nd Floor Union House, 182-194 Union Street, London, SE1 OLH if you decide that you no longer wish to receive any particular information, updates or notifications we may send to you.

2. Disclosure of personal information

2.1 We take all reasonable care to prevent any unauthorised access to your personal data.

2.2 We may disclose your personal information to:

2.2.1 any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 1985;

2.2.2 our affiliates; or

2.2.3 where we need to send the information to persons or organisations who work on our behalf to provide a product or services to you but such persons or organisations may only use this information in order to provide such product or service and not for any other purpose.

2.3 Further to paragraph 2.2 above, we will only supply your personal information to any third party for the following purposes:

2.3.1 to enhance our service and the services we can offer you, where we have your consent to share the information;

2.3.2 to provide a product or service you have requested;

2.3.3 n the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or

2.3.4 to comply with a regulatory or legal process.

2.4 We may also share or sell, as permitted by law, information to other companies who we believe may have products and services of interest to you. If you do not wish to receive information from us or other sources, please follow the instructions at paragraph 8 below.

2.5 We may also share this information about our visitors, customers or former customers to companies that perform marketing services on our behalf or with whom we have joint marketing agreements.

3. LINKS to other websites

3.1 This Website may contain links to other sites. This Privacy Policy extends only to this Website and therefore does not extend to your use of, provision of data to, and collection of data on any website not connected to us to which you may link by using the hypertext links * within the Website.

3.2 We recommend that you check the policy of each Website that you visit and contact the owner or operator of such website if you have any questions or concerns.

* Hypertext links are a means by which visitors can skip from one website to another or from one page to another within the same site.

4. SECURITY

4.1 The information you provide to us is treated as confidential information and accordingly is subject to our security policies regarding protection and use of confidential information. When we ask you for personal data on our website (for example, when you register as a buyer or make an enquiry), it is transferred over a Secure Sockets Layer (SSL Line), providing you are using an SSL enabled browser such as Microsoft Internet Explorer or Netscape Navigator. We also use SSL on other selected pages where you would enter personally identifiable information. This ensures that your information is encrypted when it travels over the Internet. This secure mode is enabled before any such information is transmitted from your computer. You will know you are in secure mode when the padlock or key icon in the lower right-hand or left-hand corner of the computer screen appears in the locked position. In addition, when accessing a secure server, the first characters of the site address will change from "http" to "https." After information reaches the Site, it is stored on a secure server that resides behind firewalls designed to block unauthorized access from outside of the Site. If you are interested in learning more about our security measures please contact us at the address provided at paragraph 10 below.

5. Data quality, access and updating personal information

5.1 We will take reasonable steps to ensure that the information and data on the Website are complete, accurate, and timely for the desired purposes. If your personally identifiable information changes (such as phone number), is inaccurate, or if you no longer desire the services, you should contact the Company at REDC UK Limited, 2nd Floor Union House, 182-194 Union Street, London, SE1 OLH to correct or update the information.

6. Right of access to your information

6.1 Should you wish to obtain a copy of the personal data we hold on you please write to the Company at REDC UK Limited, 2nd Floor Union House, 182-194 Union Street, London, SE1 OLH. Please note that a small fee will be payable.

6.2 As soon as we are satisfied as to your identity we will send you within 40 days a copy of all the data we hold concerning you.

6.3 If it transpires that the information held is inaccurate, we will make the necessary amendments and confirm to you that these have been made.

7. How we protect your data

7.1 The internet is not a secure medium, however we take great care to ensure the security of the Website and of your personal information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage by the use of hardware firewalls and SSL Line transmission of personal information. [Please see further Terms and Conditions for Use of Website]

7.2 After you registered your e-mail address we will send you a confirmation e-mail containing your log-in details. As a member, it is your responsibility to protect log-in details. You must treat these as confidential and must not share or disclose your log-in details to any other party.

7.3 We will retain your information for a reasonable period or for as long as the law requires.

8. OPT- OUT

8.1 From time to time, we may send you e-mails, e-mail newsletters, or website news updates alerting you to new features, products, promotions, or services pertaining to the Website. If you no longer wish to receive materials from us, you may opt-out of receiving these communications by writing to us at REDC UK Limited, 2nd Floor Union House, 182-194 Union Street, London, SE1 OLH or emailing us your request to 'unsubscribe' at unsubscribe@auctiontoday.co.uk. We will gladly comply with all requests for removal.

8.2 All requests to opt out of future emails will be respected.

9. CHANGES

9.1 We may edit or amend this Privacy Policy from time to time. If we make any substantial changes to the Privacy Policy, we will notify you by using a prominent notice on the home page of the Website.

9.2  As a result of improvements we make to our services, amendments to laws or regulation or developments in the technology or processes we use, we may change the information we hold about you and/or the way in which or the purposes for which we process such information. If we make any substantial change in the way in which we use your personal information we will notify you by email.

10. CONTACT INFORMATION

10.1 Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to privacyuk@redcgroup.com. REDC UK Limited is registered with the Information Commissioner under Number Z1648322.