United Kingdom Sotheby’s International Realty registered office is at 48 Conduit Street, London, England, W1S 2YR and we are a company registered in England and Wales under company number 01266162. We are registered on the Information Commissioner's Office Register registration number Z6320862, and act as the data controller.
Information that we collect
United Kingdom Sotheby’s International Realty processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this policy.
Personal data, or personal information, means any information about an individual from which that individual can be identified. Personal data does not include personal information where the identity of the individual has been removed or anonymised.
As a business we collect, use, store and transfer different types of personal data depending on who you are (for example, a client, customer, or job applicant) and how you interact with Sotheby’s.
We may collect, use, store and transfer the following categories of personal data about you:
In instances where the provision of personal data is a legal requirement or a prerequisite for the fulfilment of a contract, and an individual fails to supply such data upon request, it is important to understand the implications of this non-compliance. Under these circumstances, we are compelled to inform you that our ability to perform the contractual obligations may be hindered or rendered impossible. Consequently, we reserve the right to terminate the services being provided to you. Please be assured that if such a situation arises, we will communicate this decision to you in a timely and clear manner. This measure is a necessary step to maintain compliance with legal and contractual requirements, and to ensure the integrity and effectiveness of our services.
How we use your personal data
United Kingdom Sotheby’s International Realty takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this policy. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.
The purposes and reasons for processing your personal data are detailed below:
The following additional grounds may also apply where we process special category data:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email, text message or social messaging platform.
You have the right to withdraw consent to marketing at any time by contacting us in the following ways:
Purposes for which we will use your personal data
We have set out below, the details of all the ways in which we intend to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate business interests are.
Your right to opt out of marketing messages will not preclude you from receiving services from us or to our rights and obligations in relation to the personal data provided to us in order to receive a service from Sotheby's.
How we collect your personal data
We use different methods to collect data from and about you including through:
⁃ Use or apply for our products or services.
⁃ Create an account on our website.
⁃ Subscribe to our service or publications.
⁃ Request marketing to be sent to you.
⁃ Enter a competition, promotion or survey.
⁃ Give us feedback or contact us.
⁃ Analytics providers such as Google based outside the UK.
⁃ Advertising networks based inside or outside the UK.
⁃ Search information providers based inside or outside the UK.
⁃ Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the UK.
⁃ Identity and Contact Data from data brokers or aggregators based inside or outside the UK.
⁃ Identity and Contact Data from publicly available sources such as Companies House, the Electoral Register and the Land Registry.
Sharing and disclosing your personal information
We may share your personal data internally within the Sotheby's Group and with external third parties that may include:
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We may also share your personal data if required by law to do so, to prevent financial or reputational loss or for investigation of suspected or actual fraudulent or illegal activities.
Some of our external third parties may be located outside the UK. Consequently, processing of your personal data could involve a transfer of data outside the UK.
Whenever we transfer your personal data to a third party who may transfer it out of the UK, we aim to ensure a similar degree of protection is applied to the handling of your data by following at least one of the following safeguards:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, accessed, altered, disclosed or used in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of care and confidentiality. Sotheby's has put in place procedures to address any suspected personal data breach. We will notify you and any applicable regulator of a breach, where we are legally required to do so.
We will retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including whilst you use our services and for at least 6 years after the conclusion of those services for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there to be the prospect of litigation during or following our relationship with you.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) while maintaining the context for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In certain circumstances, you can ask us to delete your data. Please see below for further information.
Your legal rights
You have the following rights under data protection laws in relation to your personal data:
Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
⁃ If you want us to establish the data’s accuracy.
⁃ Where our use of the data is unlawful but you do not want us to erase it. ○ Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims.
⁃ You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Our policy is designed to facilitate your access to personal data without any fees in most situations. However, we reserve the right to charge a reasonable fee or refuse requests that are clearly unfounded, repetitive, or excessive, to cover administrative costs and protect our resources. In terms of timing, we aim to respond to all legitimate data requests within one month of receipt. This period ensures accurate processing and provision of the necessary information. Should your request be complex or involve multiple queries, we may extend this timeframe by up to two additional months. In any case of a delay or the need to charge a fee, we commit to keeping you fully informed, providing clear explanations for our decisions, and maintaining open communication to ensure transparency throughout the process
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.