INTRODUCTION

Bamboo Auctions Ltd is committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) describes how we collect, use, store and share your data. This policy applies to Bamboo Auctions’ online property auction marketplace platform, that may be accessed either through www.bambooauctions.com (the “Website”) or by visiting one of our partner agents’ websites, where Bamboo Auctions’ technology is being used to power an online auction (“Partner Websites”) (the “Services”).

If you do not agree to the terms of this privacy policy, do not access or use the Services and please do not continue to use the Website or Partner Websites. If you already have an account and no longer agree to these terms, please contact us using the contact details provided.

This policy does not apply to data processing carried out by third party applications or software that are used as part of the Services (“Third Party Services”), nor does it apply to any elements or functions of a Partner Website that fall outside the provision of the Services.

WHAT WE COLLECT FROM YOU

Personal data is any information relating to an identifiable person who can be directly or indirectly identified (“Personal Data”). We may collect and process your Personal Data at specific points in time during your use of the Services, the Website, and the Partner Websites. These specific points in time include information being processed as part of registration to use the Services, verifying your identity to fulfil our legal obligations and taking payment to fulfil the performance of a contract.

We may collect and process the following data:

Information you give to us. You may give us information about you by filling in forms on our Website, our Partner Websites or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use the Services, search for a property, place bids on properties on our website, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.

Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We may also work closely with third parties (including, for example, business partners, sub- contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

Cookies: Our Website and Partner Websites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

HOW WE USE YOUR INFORMATION

We use information held about you in the following ways:

Information you give to us

to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;

to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those, which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this;

to notify you about changes to our service;

to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you

to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

to improve our site to ensure that content is presented in the most effective manner for you and for your computer;

to allow you to participate in interactive features of our service, when you choose to do so;

as part of our efforts to keep our site safe and secure;

to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Information we receive from other sources

We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

You can control whether you receive marketing messages through your own notifications dashboard.

GROUNDS FOR PROCESSING PERSONAL DATA

Generally we will process your Personal Data as follows:

Explicit Consent: Where you have provided explicit consent so that we may process your Personal Data. This may involve sending you updates, marketing and other information. Please see the section below on your rights, to see how you can access, amend, edit and remove this consent.

Legal Obligations: Where processing your data is required in order to fulfill our obligations under law. This includes carrying out an electronic ID verification check, which will leave a soft check on your credit report (this should not affect your rating). This is to ensure that we comply with Money Laundering Regulations, which are mandatory in the provision of the Services and prior to entering into a contract. You cannot withdraw consent if you proceed with the ID verification check.

Performance of a Contract: Where processing is necessary for the performance of, or taking steps in order to enter into a contract. Entering your payment details and solicitor details in order to place a bid is an example of this. You cannot withdraw consent if you choose to place a bid.

DISCLOSURE OF INFORMATION

We may share your personal information with:

Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

Selected third parties including:

Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.

Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose Personal Data to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the Personal Data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

Analytics and search engine providers that assist us in the improvement and optimization of our site.

Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

We may also disclose your personal information to third parties in the following circumstances:

In 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.

If Bamboo Auctions Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Bamboo Auctions Ltd, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

WHERE WE STORE YOUR PERSONAL DATA

Transfers and Storage of Personal Data

Some Personal Data that you provide to Bamboo Auctions will need to be transferred and stored outside the EEA. An example of this are payment details, in order to perform your contractual obligations.

We have ensured that where your Personal Data is being transferred outside the EU, the recipient of the Personal Data (whether us or a third party) is self-certified under the E.U.-U.S. Privacy Shield. This was developed to enable companies to comply with data protection requirements when transferring personal data from the European Union to the United States. To learn more about the Privacy Shield Program, please see http://www.privacyshield.gov/welcome.

Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, including us.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

PAYMENT INFORMATION

Payment information provided through our website is not held by us, but instead held by Stripe, a third party payments processor. For details of their privacy policy, please see https://stripe.com/gb/privacy.

RETENTION

We will generally keep your information in accordance with your instructions. We may retain certain information relating to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your information after you have removed your account for the period of time needed for us to comply with our legal obligations, conduct audits, resolve disputes and enforce contracts entered into using our Services. Examples of this include legal or business requirements for us to maintain ID records or to keep a record of contracts entered into.

YOUR RIGHTS

You have the right to:

be informed - this is demonstrated by this policy and various just in time notices throughout the Website and Partner Websites

access you data - you can do this through your dashboard

rectify your data - you can do this through your dashboard

remove your data - you can do this through your dashboard

restrict your data - contact us if you believe you have grounds to restrict the processing of your Personal Data using the details below

data portability - contact us if you believe you have a right to Personal Data portability using the details below

object - contact us if you object to any of your Personal Data being processed and you have exhausted the options available to you above

You also have rights in relation to automated decision making and profiling. We will inform you where this is applicable.

Our site may, from time to time, contain links to and from Partner Websites, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites should have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

SECURITY

Bamboo Auctions takes security of data very seriously and we work hard to ensure that we protect the information that you provide to us from loss, misuse, and unauthorised access or disclosure. Some examples of our practices include:

We never store passwords on our servers and actively encourage that you do not share your password with anyone.

All payment details are tokenised and are not stored in our database. Our payment handling provider has PCI Level 1 Compliance and payment access is only available to specially trained employees.

ID checks and reports are handled by specially trained employees only.

We cannot guarantee that information, during transmission by email or otherwise, or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, but we do endeavour to protect against this at all times.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

DATA PROTECTION OFFICER

If you wish to speak directly with the Bamboo Auctions’ data protection officer, please contact hello@bambooauctions.com, indicating your request and contact details.

DATA CONTROLLER AND PROCESSOR DETAILS

For the purpose of the Data Protection Act 1998 (as shall be amended and replaced from time to time) (the Act) and the General Data Protection Regulation (GDPR), which shall come into force from 25 May 2018, Bamboo Auctions Ltd (company registration number: 08884197) is a data controller and a data processor.

Our contact details are below should you have any queries or require any information about how we manage your data.

DATA PROTECTION AUTHORITY

If you are a resident of the European Economic Area and believe your Personal Data is being processed within the scope of the GDPR, you may direct questions, complaints or report a breach to our lead supervisory authority:

Information Commissioner’s Office

Bamboo Auctions is registered with the Information Commissioner’s Office with the following registration number: ZA041269

CONTACT

Questions, feedback, comments and information requests regarding this privacy policy and how we manage your data are welcomed and should be addressed to hello@bambooauctions.com.