Privacy

POLICY STATEMENT CONCERNING THE PROCESSING OF PERSONAL DATA – GDPR 2016/679

This policy statement is made pursuant to the GENERAL DATA PROTECTIONREGULATION (EU) 2016/679 of the European Parliament and of the Council of 27 April2016.
PANDOLFINI CASA D’ASTE S.R.L. reserves the right to update this policy statement,publishing the new applicable version, each time, on this web page, where necessary. Allamendments shall enter into effect immediately.

DATA CONTROLLER
The Data Controller shall be PANDOLFINI CASA D’ASTE S.R.L. – VAT number:04195730488, with head office in Florence, Borgo Albizi, 26.
Any requests for information concerning the processing of your personal data, as well asto exercise your rights as per the points listed below should be directly addressed to theData Controller by sending a formal registered letter with Advice of Receipt, or by e-mail tothe following address: privacy@pandolfini.it

TYPE OF INFORMATION

INFORMATION PROVIDED BY USERS
The Data controller shall process the data it receives, for example, when someoneregisters as a User or when a services request form is used and/or on the occasion ofparticipation in auctions/awarding of lots.
Information regarding registration for an auction that is held in a hall, by telephoneor on-line: in these cases, it is necessary to present a valid identity document which isessential for registration.
With regard to on-line registration for taking part in live auctions and to be able to makeoffers, clients upload a scanned file of their document to the web server of the pandolfini.itdomain or send it by fax. The IP address is registered at the moment of the firstregistration.

ACCOUNT INFORMATION
Users who wish to register on the www.pandolfini.it website should fill in an initial form withthe following data: first name, last name, e-mail, password, city, the wish to subscribe tothe newsletter and authorization for the processing of their personal data.
At this point they receive an e-mail with a link to confirm their registration on the website.Once the registration is confirmed, in order to make offers on the website or take part inthe live auction they have to enter the following data: title, nationality, complete address ofresidence, tax code, telephone, fax, invoicing address if necessary, bank and currentaccount details. After the registration of the data the user should upload to the server orfax a copy of a valid identity document.
The user’s IP will be stored at the time of the first request for registration on the website.

INFORMATION FOR REQUESTING SERVICES:
for each services request it is necessary to provideyour particulars (first and last name, e-mail address) which will be managed together withthe request by the Data controller (in this case legitimate interest takes over).
Information necessary for providing the services requested – executing a contract:
your personal/company data will be acquired (first and last name, postal address, e-mailaddress, bank account details, details of your identity document, tax code/VAT number,documentation regarding the Assets put up for sale and/or of the services rendered,documentation concerning any communication that has occurred, etc.) and, more ingeneral, all the “personal/company information” necessary for correctly fulfilling fiscalobligations that are not currently in force including money laundering regulations (fulfilmentof legal/contractual obligations).
To provide information on the next auctions, other events or specific typologies ofassets, as well as on the other services offered by PANDOLFINI CASA D’ASTES.R.L., your personal/company data will be acquired (first and last name, postal address,e-mail address, communication preferences) through the internet website and/or in anyparticipation form, paper or digital – (legitimate interest).

INFORMATION THAT IS AUTOMATICALLY COLLECTED
When you use the online platform your browser sends navigation information such as, forexample, clicks, information about the device used and IP address to Google Analytics.
The result of the Google Analytics processing is used in a purely statistical manner inorder to improve use of the website.
Cookies. The platform also uses cookies (small files of texts sent by the computer everytime you visit our online platform). These techniques make it possible, for example, torecognize you, to store your language preferences and settings and to accelerate youraccess to the online platform and the application. For more information visit the privacystatement page regarding to the use of Cookies.

ADDITIONAL PURPOSES OF DATA UTILIZATION

1. ONLINE PLATFORM SUPPLY
We use your data to guarantee that the service is provided in the best possible way. Inthis regard we use your data to:
- Allow you access to and the use of our online platform, including the online auctionfunctions
- view the online platform in a format that corresponds to that of your internet browserand of the device you are using
- send you status updates, a summary of the information or services you haverequested with the data entered
- send you periodical messages about our sales activities
- keep our online platform safe and reliable, process and store your data in order tocomply with legal obligations.
- Prevent, trace and hamper fraud or any other illegal use of the online platform or theservice
- Register, mediate and resolve any disputes or irregularities
- Apply our terms and conditions of use and other guidelines

2. ACTIVITIES CONNECTED WITH THE EXECUTION OF THECONTRACT FOLLOWING THE AWARDING OF LOTS
The data you provide will be utilized to conclude and execute the contract and to fulfil thelegal obligations. It shall, therefore, be processed:
- for the correct issuing of the necessary accounting documents resulting from theaward;
- for managing any contractual variations related to personal data records, formanaging payment collections;
- for managing any requests for information, assistance, complaints, disputes.The provision of personal/company data for these purposes shall be compulsory and thefailure to provide the same could jeopardize the sale.

3. PURPOSES: PROMOTIONAL, COMMERCIAL AND MARKETING
Subject to specific consent, your information may also be utilized, using either electronic ortraditional methods, for the following purposes:
- sending of advertising, informative, promotional material regarding the activities ofthe Auction House using either electronic (newsletters, e-mails, etc.) or traditionalmethods (ordinary mail, telephone, etc.);
With regard to the processing as per points 1. and 2., this is of mutual interest in order tocomply with the respective legal obligations and in order to fulfill the contract.We need your consent for the processing as per point 3.

PROTECTION AND STORAGE OF DATA
In addition to the normal legal obligations, the protection of your data is of particularinterest to us in order to guarantee our mutual safety. Along with the safety measuresadopted by us such as, for example, the encryption of the data, we advise that youchoose your password carefully and keep you access data safe.
PANDOLFINI CASA D’ASTE S.R.L. uses the best systems available on the market todayto guarantee the safety of your data. Despite the effectiveness of these safety measures,it is not possible to guarantee the absolute safety of the personal data stored in ourarchives and on our systems, nor the complete protection of the information supplied to usvia internet from unauthorized interference, access or manipulation during transmission.
The transmission of the personal data shall always be at your own risk.
The information acquired by us shall be stored for the period of time necessary to supplyyou with the services requested, to fulfill the contractual, fiscal, legal obligations and fordefense purposes in the event of any legal actions.
With regard to our research and the documentation concerning the ownership rights ofobjets d’art, the personal data will be stored in order to comply with checks regarding theauthenticity, provenance and title of ownership for the time necessary to protect thecommercial legitimate interests.

CONTROL OF INFORMATION
It is possible to amend your information through your account settings or by putting in arequest for the same. In the event that there should be a variation to your data for reasonsnot attributable to PANDOLFINI CASA D’ASTE S.R.L., you should undertake to notify thisthrough the normal official channels or through your account.
In the event that you want to know about your data that is in our possession, we invite youto send an e-mail to the following address: privacy@pandolfini.it.

AMENDMENTS TO THE POLICY STATEMENT
PANDOLFINI CASA D’ASTE S.R.L. may decide to amend or integrate this policystatement at any time, publishing the amended and updated statement on the onlineplatform.

ACCESS TO YOUR DATA
Your personal data shall be processed by PANDOLFINI CASA D’ASTE S.R.L. and/orCompanies associated with the same also resident in the European Community; the sameshall be processed in full compliance with European regulations and Regulation (EU)2016/679.

EXERCISING OF YOUR RIGHTS
In relation to the personal data subject to the processing as per this policy statement, youshall – in application of European Regulation (EU) 2016/679 – have the right at any time:a) to access the data in our possession (art. 15); b) to rectify the data in our possession(art. 16); c) to erase the data in our possession (art. 17); d) to restrict the use of the data inour possession (art. 18); e) to the portability of the data in our possession (art. 20); f) toobject to the processing of the data in our possession (art. 21); g) to withdraw from thedata processing without affecting the lawfulness of the processing based on consentbefore its withdrawal (art. 7); h) to lodge a complaint with the Information Commissioner forthe protection of personal data.
The exercising of the rights indicated above may be carried out by means of a writtennotification to be sent by e-mail to the address of the Data controller: privacy@pandolfini.it,or by means of a registered letter with Advice of Receipt c/o the head office of theaforementioned Data controller.

CONTACTS
If you have any questions regarding this Data Processing Policy Statement you cancontact us at any time using the following contact details:

PANDOLFINI CASA D’ASTE S.R.L. Borgo Albizi, 26 -50122-Florence
Telephone: + 39 055 2340888
Fax: + 39 055 244343
E-mail: privacy@pandolfini.it