Privacy Policy

 

Practicum100 (the "Practicum100" or "we") is deeply committed to safeguard the privacy expectations of its users (“you” or “your”). Accordingly, we have put in place this policy (the "Privacy Policy"), which outlines our data protection practices, including how we collect, use, disclose and protect your Personal Data in accordance with our legal obligations as a Data Controller under the General Data Protection Regulation (the "GDPR") and other applicable data protection laws.

 

This Privacy Policy should be read in conjunction with other terms and applies to you when using our services (the "Services"), and shall be interpreted in accordance with the Glossary section appears at the end of this policy which explains what we mean by “personal data”, “processing”, and other terms used in this Privacy Policy.

 

As we update and expand our Services, this Privacy Policy may be changed to better serve everyone. We will post any revised version on this webpage but we do not typically send notifications of changes to our Privacy Policy, so please check back periodically for updates. Any changes will be immediately effective on posting.

HOW AND WHEN WE COLLECT YOUR PERSONAL DATA

 

Information we collect directly from you:

 

We may collect Personal Data directly from you (whether face to face, over the telephone, by email, in paper form or online), including when you:

  • subscribe to our newsletters;

  • express an interest in our Services or interact with us as a client or prospective client;

  • create an account with our website or applications;

  • instruct us to provide Services to you and sign contractual documentation;

  •  Information we process on your behalf: In order to provide you with the Services, you need to upload certain information about your clients and the property you sell. We use and process this information to provide the Services in accordance with our Terms of Service.

 

Information we collect from other sources:

 

We may collect Personal Data about you from external sources (social media sites for instance), including when:

  • someone introduces you to us;

  • we may work to expand our customer base by acquiring names, financial information, contact data, and demographic information from other sources such as private companies, public registers, and social media sites.

 

Automated data collection:

 

We collect information about you, your computer and devices when you visit our website, which includes your internet address, your operating system and browser type. We use this information to personalise your experience and administer our website, and for security and analytical purposes. 

 

We use (and authorise third parties to use) cookies, web beacons, pixels, scripts, tags and other technologies when you visit or access our Services (for example when you visit our website). For more information about cookies, web beacons, similar technologies, and how they are used, please see our Cookies Policy .

 

We may record your communications with us, including by telephone and online (e.g. telephone and on-line bidding) for client service, security and bid monitoring purposes. Where we record such information we will process it for the purposes set out below.

 
WHAT PERSONAL DATA DO WE COLLECT AND WHY? 

We will process your Personal Data for a variety of reasons, each of which is prescribed by relevant data protection laws. Please refer to the Glossary for more information about the legal grounds for processing and other defined terms. In addition to the other uses of information described in this Privacy Policy, we may use all of the information that we obtain from or about you for the following purposes and reasons:

  • We may process your contact details (including email address, postal address, telephone numbers), bank account details, insurance details, employment information, records of your communications with us, the person or organisation who has introduced you, and any fee they receive and more, in order to provide our Services to you, including new Services we develop later, prevent fraud and collect fees (legal ground: performance of a contract);

  • We may process your date of birth, identification documents (including photo), and any information relating to a dispute or legal proceeding, in order to enforce compliance with our Terms & Conditions and to comply with our legal obligations (legal ground: compliance with a legal obligation, performance of a contract);

  •  We may process personally identifiable information, together with web activity history, transactional history, survey data, and other data sources in order to improve our Service, customise our website, provide personalized experiences (through our sales staff, client services staff, accounting, shipping, as well as print and digital channels), focus our direct marketing efforts and send you personalized marketing communications, manage our fraud risks, establish credit limits, and other similar goals to further our business (legal ground: legitimate interest, consent);

  • We process data from your account, including Personal Data of your clients, to provide and improve the Services. For example, when you open an account with the website as a auction house or gallery and upload your property details and clients’ information, we use such information like clients’ details and bidding history, so we can create purchase recommendation for your clients and audience segmentation, whether offering recommendation or other services on your behalf, or on our behalf. As always, we take the privacy of Personal Data seriously, and will continue to implement appropriate safeguards to protect this Personal Data from misuse or unauthorised disclosure (legal ground: legitimate interest, consent).    

  • We may process your IP address, browser type and operating system, and any data obtained from cookies, web logs and other similar technologies that monitor the use of our website and Services digitally in order to monitor, evaluate and improve your user experience and the performance and effectiveness of our website, applications and Services (legal ground: legitimate interest, consent);

  • We may process your complaints, opinions, responses to our surveys or market research in order to train our staff and improve your client or user experience (legal ground: legitimate interest);

  • We may process your name and contact details, identification and other documentation (including passport, ID card, proof of address) for our Know Your Client checks and tax status in order to carry out identity and credit checks (legal ground: compliance with a legal obligation, legitimate interest).

 
 
WHEN WE MAY DISCLOSE YOUR PERSONAL DATA

When processing your Personal Data for the purposes listed above, we may have to share or transfer your Personal Data and any other information you provided to us with other companies or entities relying on the legal grounds for processing described above, including:

  • To business partners and vendors that work on our behalf to provide services such as mailings, customer account and technology support, secure payment processing, fraud prevention and digital marketing management;

  • We may transfer Personal Data about you to ad technology firms so that they may deliver interest-based content and advertisements to you where you have consented to marketing (such consent can be withdrawn at any time), or they may inform our Services to you or other audiences similar to you on third-party sites. 

  • Persons acting on your behalf;

  • Financial institutions, fraud prevention agencies, credit reference agencies, professional advisors and internal and external auditors; 

  • Law enforcement and judicial, administrative and regulatory bodies;

  • As part of a sale, merger, liquidation, or transfer of our business assets.

 

We require third parties acting as data processors to respect the security of your Personal Data and to treat it in compliance with applicable law.