Prop Store Limited, The Propstore of London, Inc., and their affiliates (collectively referred to as “Propstore”, “we”, “us”, or “our”) are strongly committed to protecting the privacy of your personal information when you interact with the Propstore websites (“Sites”) or use our services (“Services”). This privacy notice (“Privacy Notice”) describes the types of information we may gather from your use of the Sites or Services; why we gather your information; how we use your personal information; when we might disclose your personal information to others; and how you can manage your personal information. We also include specific disclosures for residents of the European Economic Area, UK, and Switzerland, as well as California.

The relevant Propstore contracting entity and data controller of your personal data depends on where you are located:

Please see the ‘YOUR PRIVACY RIGHTS – United States’ section of this Privacy Policy for details about the data protection laws which apply to our Site and Services, and your rights which apply to you if you are based in the United States.

Please see ‘YOUR PRIVACY RIGHTS – UNITED KINGDOM (AND GIBRALTAR), EUROPEAN UNION, AND SWITZERLAND for details of the data protection laws which apply to our Site and Services when you are located in such territories, and how you can exercise your rights.

When you use our Site or Services, you consent to our collection, use, and disclosure of information about you as described in this Privacy Notice. A link to a Portable Document Format (PDF) version of this Notice can be found here: /privacy-policy-pdf.

Propstore collects Personal Information to facilitate your use of our Site and Services. “Personal Information” in the UK/EU/Switzerland has the meaning given to it in the GDPR, and in the US, means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is being associated with an identified or reasonably identifiable individual.

For ease of reference, we have compiled the list below to demonstrate how we use the categories of Personal Information we have collected, used, and disclosed.

The categories and purposes for the collection, use, and disclosure of Personal Information relating to each individual as a bidder/buyer, consignor, or website user, or other user of our Services (as applicable) include:

The Personal Information we collect, and the practices described above, are undertaken to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve Propstore offerings. We may use your Personal Information to:

• Provide You with Propstore Services. Propstore uses your Personal Information to provide you with its Services and Site pursuant to its Terms of Use for the Site and this Privacy Notice.

• Contact You: Where you have requested, we may contact you over various channels (including telephone, email, SMS, WhatsApp) to facilitate your request, including to discuss a potential consignment with you, a purchase you have made, or to provide you with auction alerts where you sign up for these;

• Send you Service Messages: We may sometimes send you essential service-related communications, for example, to confirm that you have registered an account, to notify you of changes to your account or our services, or to confirm actions that you have taken when using our services. These communication are necessary to provide our services to you. Our logo or branding on a message or non intrusive publicity is unlikely to be considered direct marketing on its own.

• Comply with Legal and Regulatory Requirements. Propstore processes your Personal Information as required by applicable laws and regulations.

• Protect the Security and Integrity of Our Site and Services. Propstore uses your Personal Information to further our security practices related to Personal Information.

• Optimize and Enhance Our Services, and statistical analysis. Propstore uses your Personal Information to understand how our Services are being used to help us improve our Services and manage our business. We may also use cookies or similar technologies to do so, generally with your consent unless those cookies are exempt from the requirement to obtain consent under applicable laws.

• Customer and Consignor Feedback Surveys. Propstore may contact you via email to ask you to complete surveys and feedback forms. We do this to improve our customer and consignor services and the products we offer. You are under no obligation to respond to such requests.

• Market Our Services to You.Propstore may contact you with information about our Services. We will only do so with your consent, which can be revoked at any time.

• Other Business Purposes. Propstore may use your information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent. A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. If under UK/EU data protection laws we rely on ‘legitimate interests’ to process your personal data, we will undertake appropriate assessments as required by applicable laws to fully consider and protect your privacy rights.

We may use the Personal Information we collect or receive through the Site and Services (alone or in combination with other data we source) for the purposes and on the legal bases identified below:

• To perform our contract with you for use of the Site and Services or, where we have not entered into a contract with you, in accordance with our legitimate interests to operate and administer our Site and Services.

• To enforce compliance with our contractual obligations and applicable law, and to protect your rights and safety in reliance on our legitimate interest to protect against misuse or abuse of our Site and Services and to pursue available remedies. This includes, in some cases, disclosing the identity of our consignors/buyers to allow the relevant party to enforce a contractual or legal right, or bring a claim, against the other party. This takes place in limited circumstances where following an auction there is a product issue, failure to make payment in full, or suspected fraud.

• To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.

• To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests.

• To prosecute and defend a court, arbitration, or similar legal proceeding.

• To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.

• To provide, support, and improve the Site and Services to perform our contract with you for the use of the Site and Services or, where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Site and Services and providing certain features. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws.

Automated decision making and use of artificial intelligence

We do not engage in decision making processes that are based solely on automated means which produce legal effects concerning you or significantly affect you. All significant decisions involving your personal data are subject to human oversight to ensure fairness, transparency and accountability. We do not employ automated decision making in any determination that would result in the provision or denial of financial or lending services, housing, education enrolment or opportunities, employment or independent contracting opportunities or compensation, or healthcare service.

We use artificial intelligence (“AI”) technologies in limited ways to enhance our services. This includes but is not limited to responding to certain customer service queries. The use of AI within our operations does not involve the collection, use or processing of your personal data. Our AI functionalities are designed to operate without accessing or relying on your personal data.

Propstore will not share your Personal Information with third parties except as described in the table below.

In the preceding twelve (12) months, Propstore has disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below.

A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers to recognize your device the next time you visit their website. Propstore uses the term “cookies” in this policy to refer to cookies and all such similar technologies that collect information in this way.

We will give you an opportunity to reject non-essential cookies using our consent management platform (CMP) where you can also view in detail each cookie we place, its purpose and its retention period. You can amend your preferences at any time using the CMP.

We may deploy certain cookies automatically and without asking for your consent, which is generally those that are essential for the Site to function and where permitted by law, low-risk analytics cookies. We will only do so in line with all applicable legislation.

You can review our Cookie Policy here.

We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we refer to these criteria in order to determine retention period:

• Whether we have a legal or contractual need to retain the data;

• Whether the data is necessary to provide our Site and Services; and

• Whether our consumers would reasonably expect that we would retain the data until they remove it or until their accounts are closed or terminated.

We will generally retain your Personal Information in line with our internal retention policies and will not keep such information for longer than necessary, in accordance with applicable data protection laws. When you use our Services, we will generally retain that Personal Information for 6 years, in accordance with statutory limitation periods.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and cease any further processing until deletion is possible.

Propstore is required under European Union, United Kingdom (and Gibraltar), and Switzerland privacy laws to provide certain information to individuals about how Propstore collects, uses, and shares your Personal Information, and about the rights and choices that you may have concerning your Personal Information. The following sections provide an overview of the Personal Information that Propstore collects, uses, and shares, outlines the rights that you have concerning your data, and describes the actions that you can take to make certain requests concerning your Personal Information.

Please see below for a link to this specific notice:

• Your Privacy Rights – United Kingdom (and Gibraltar), European Union, and Switzerland

This section outlines the privacy rights that may be available to you under applicable state privacy laws.

We are required various state laws in the United States, in particular the California Consumer Privacy Act of 2018 and the Consumer Privacy Rights Act, as amended, and by regulations adopted by the California Privacy Protection Agency (collectively, the “CCPA”) to provide certain information to consumers about how we collect, use, and share their Personal Information in our capacity as a business, and about the rights and choices California residents may have concerning their Personal Information. For purposes of this section, “Personal Information” has the meaning provided in the CCPA.

The rights described below are not absolute, and, in certain cases, we may decline your request as permitted by law. To exercise any of these rights, please email privacy@propstore.com or call us at +1 (818) 727-7829. Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information.

The following disclosures are made in compliance with the CCPA and other state laws. In the past twelve (12) months, we have collected the Personal Information described above, and disclosed it to the third parties listed under the section “How We Share Personal information We Collect” for the business purposes identified therein and under the section “How We Use Personal Information We Collect.” This information falls into the following categories of Personal Information under the CCPA:

• Identifiers;

• Categories of Personal Information described in section 1798.80(e) of the California Civil Code;

• Characteristics of protected classifications under California or federal law;

• Commercial information;

• Geolocation information;

• Audio, electronic, or visual information;

• Internet or electronic network activity information;

• Professional or employment-related information; and

• Sensitive personal information.

As disclosed above in “How We Share Personal information We Collect,” we may engage in activity that may be considered “sharing” Personal Information. If you wish to opt-out of this use of your Personal Information, click here: Do Not Sell or Share My Personal Information. We do not use or disclose Sensitive Personal Information for purposes other than those specified in regulations adopted under the CCPA. Below is a summary of your privacy rights under the CCPA and other state privacy laws.

Exercising Your Privacy Rights

Global Privacy Controls To be completed

To exercise any of these rights, please email privacy@propstore.com or contact us at +1 (818) 727-7829.

Sale and Sharing of Personal Information

We do not “sell” Personal Information. To the extent that we may have “shared” Personal Information in the last twelve (12) months, it is identified in the sections of this Notice titled “Personal Information We Collect/Sources of Personal Information We Collect” and “How We Share Personal Information We Collect.”

Automated decision making

You have the right to opt-out of our use of automated decision making, and you may request us to provide you information about the logic, significance and consequences of our use of automated decision making.

No security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect Propstore and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information that we collect and store.

We have security processes in place to comply with applicable federal and state standards. This includes physical safeguards (e.g., locked files and a secured building) and electronic safeguards (e.g., encrypted computers, strong passwords, and restricted access).

Propstore also trains its employees and representatives on the proper handling of Personal Information, the confidentiality of Personal Information, and their duty to take reasonable steps to safeguard it.

Propstore may utilize third-party applications and integrations to enhance your experience and ensure our Services work effectively and as efficiently as possible. We disclaim any and all liability and responsibility for the use of these applications and integrations to the fullest extent permitted by law, and we encourage you to review their individual privacy policies before using our Site or otherwise engaging with us.

We do not intend, and we do not direct our Site or Services towards children under the age of 17. We do not knowingly collect Personal Information from children. Should you believe we may have collected Personal Information from a child, please contact us at privacy@propstore.com.

We may revise this Privacy Notice from time to time. If we make material changes to this Privacy Notice, we will notify you by email or by posting a notice on our Site prior to or on the effective date of the changes. By continuing to access or use the Site after those changes become effective, you acknowledge the revised Privacy Notice.

If you have any questions or comments about this Notice, or the ways in which we collect and use your Personal Information, please do not hesitate to contact us at:

Email: support@propstore.com

EU and UK Address:

Propstore
Attn: Privacy
Great House Farm
Chenies
Rickmansworth
Hertfordshire
WD3 6EP
England

US Address:

Propstore
Attn: Privacy
28014 Harrison Pkwy
Valencia, CA 91355

If you have an unresolved privacy or personal information use concern or complaint that we have not addressed to your satisfaction, please contact privacy@propstore.com

To the extent these laws apply to Propstore, we are required under the European Union General Data Protection Regulation (“EU GDPR”), the United Kingdom General Data Protection Regulation (“UK GDPR”), and Switzerland’s the Act on Federal Data Protection (“nFADP”) to provide certain information to EU, UK (and Gibraltar) and Swiss residents about how we collect, use, and share their Personal Information in our capacity as a business, and about the rights and choices you may have concerning their Personal Information. For purposes of this section, “Personal Information” has the meaning provided in the GDPR and nFADP.

This section applies only to EU, UK (and Gibraltar) and Swiss residents. As EU, UK (and Gibraltar) and Swiss resident, you have the rights listed below. However, these rights are not absolute, and, in certain cases, we may decline your request as permitted by law.Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information.

Any references made to “Personal information” in this Privacy Notice are equivalent to “Personal Data” governed by EU, UK (and Gibraltar) and Swiss data protection laws. “Personal Data” includes information about an individual, where that individual is either directly identified or can be identified. It does not include anonymous data, for example, where information where the identity of an individual has been permanently removed.

Legal Basis of Processing

We use your personal information only as permitted by law. Applicable EU, UK (and Gibraltar) and Swiss data protection law requires data protection law requires us to have a “legal basis” for each purpose for which we collect your Personal Information. Our legal basis for collecting and using the Personal Information described in this Privacy Notice will depend on the type of personal information and the specific context in which we collect it. However, we will normally process Personal Information from you when:

• We have your consent to do so;
•  We have a contract with you, and it is necessary to process your Personal Information to perform our contract with you, including to provide you with the benefits of our Site and Services and to operate our business;
• The processing is in our legitimate business interests, such as operating our businesses, improving and developing our Site and Services, communicating with you, marketing our offerings and services and personalizing your experience, and to detect illegal activities; and/or
• To comply with legal requirements, including applicable laws and regulations.

International Transfers of Personal Data

As we are a global company, data may be shared with our group company(ies) based in the USA or with suppliers based outside of the UK or European Economic Area.

Where your Personal Information is transferred to a restricted territory, we will ensure there are adequate safeguards in place to protect your Personal Information, which may include (without limitation), contractual safeguards and a transfer risk assessment where appropriate.

Your Rights and How to Exercise Them

Below is a summary of your rights under the GDPR and nFADP. Please note that these rights are not absolute, and, in certain cases, we may decline your request as permitted by law.

Exercising Your Privacy Rights