We take your privacy seriously and will only use your personal information to administer your account utilising our internal systems and third-party applications controlled by us. It enables us to provide the products, services, and information that you have requested from us. All financial information is securely stored, and we do not to take payments from individuals or organisations without their authority.

Why do we collect your personal data?

We collect personal information to comply with our legal obligations under the UK General Data Protection Regulation (UK GDPR) and Anti-Money Laundering (AML) regulations. The type and amount of data we collect depends on the nature and value of the item or items in question. Buying or selling high-value and/or regulated items may require us to verify your identity and to carry out further due diligence checks. This information helps us ensure we comply with our legal and regulatory obligations, our transactions are secure, we prevent financial crime, and to maintain the integrity of our services.

As part of our obligations under the relevant Money Laundering legislation, Tennants may require customers buying or selling with Tennants to provide documentation to verify their identity and current address before completing certain transactions. This will be made aware prior of the exchange of goods.

Lawful Basis for Processing

Tennants Auctioneers processes your personal data in accordance with the UK General Data Protection Regulation (UK GDPR). The lawful basis we rely upon will depend on the nature of our relationship with you and the services we provide.

We process your personal data where it is necessary to:

• Comply with a legal obligation (Article 6(1))

• Perform a contract (Article 6(1)(b))

• Pursue our legitimate interests (Article 6(1)(f))

• Obtain your consent (Article 6(1)(a))

We do not routinely collect or process special category personal data. However, where such information is provided as part of identity verification, source of funds enquiries or other due diligence processes, we will only process it where permitted under Article 9(2) of the UK GDPR and appropriate safeguards are in place. Where necessary to comply with Anti-Money Laundering legislation or prevent financial crime, we may also process information relating to criminal convictions and offences in accordance with Article 10 of the UK GDPR and applicable UK data protection legislation.

What information do Tennants collect?

To enable us to comply with Anti-Money Laundering Regulations, you may be required to provide several forms of identification, to prove your identity and your address, some of the information we request are listed (but not limited to) the below:

• Date of birth

• Residential address

• A valid form of photo identification

• Proof of address

• Source of funds (verification may be required depending on nature of transaction)

• AMP registration number (If you are operating as an Art Market Participant, we may require your HMRC Art Market Participant registration number where applicable.)

Third Parties/Who we share details with

For online bidding, Tennants uses the third-party platform the-saleroom.com, which operates independently. By registering or bidding through their site, your data is subject to their privacy policy. We recommend reviewing it to understand how your information is used. You can view their Privacy Policy here.

Tennants only works with trusted partners who comply with data protection regulations to ensure your information remains secure. We may use Smartsearch, a third-party provider to assist us with our due diligence checks. You can view their Privacy Policy here. We may also use other carefully selected third-party providers to assist with identity verification, sanctions screening, politically exposed person (PEP) checks, adverse media screening, and other due diligence requirements where necessary to comply with Anti-Money Laundering legislation.

Marketing Purposes

Tennants is committed to protecting your personal data in accordance with the UK General Data Protection Regulation (UK GDPR). We do not share your personal information with third-party organisations for marketing purposes without your consent. From time to time, we may wish to contact you with details of our events, offers, and services—if you would like to receive this information, please let us know your preferred method of contact (phone, email, or post).

Google Ads Retargeting

Google Ads Retargeting is a remarketing and behavioural targeting service provided by Google. It connects the browsing activity on our website www.tennants.co.uk with the Google Ads advertising network. We use Google Ads Remarketing to advertise Tennants Auctioneers throughout the Internet by displaying ads to you based on web pages of Tennants that you have viewed. It does this by placing a cookie on your machine. Importantly this cookie does not in any way identify you or give us access to your computer. The cookie simply allows us to show you relevant adverts across the Google Advertising Network based on your previous browsing of www.tennants.co.uk

You can opt out of Google Ads Remarketing by visiting http://www.google.com/settings/ads You can opt out of all third party cookie advertising by visiting

http://www.networkadvertising.org/choices/

Meta Retargeting

Tennants Auctioneers uses, through its website, the Meta retargeting service to advertise on Facebook and Instagram to previous visitors to our website. Meta retargeting displays relevant advertisements to you based on pages of the www.tennants.co.uk that you have viewed by placing a cookie on your computer. This cookie does not identify you or give us access to your computer. The cookie simply allows us to show you relevant advertisements across the Meta Network based on your previous browsing of www.tennants.co.uk

Any data that we collect will be used in accordance with this Privacy Policy and Meta’s retargeting privacy policy. You can opt out of all third-party cookie advertising by visiting http://www.networkadvertising.org/choices

How long do we keep your personal data?

Tennants will keep your data in line with our information policy. Most of the information we process about you will be retained as determined by statutory obligations. Any personal information which we are not required by law to retain will only be kept for as long as necessary to fulfil our organisational needs.

What rights do you have over your data?

Under GDPR you have the following rights in relation to the processing of your personal data:

• To be informed about how we process your personal data. This notice fulfils this obligation.

• To request access to your personal data that we hold and be provided with a copy of it.

• To request that your personal data is amended if inaccurate or incomplete.

• To request that your personal data is erased where there is no compelling reason for its continued processing.

• To request that the processing of your personal data is restricted.

• To object to your personal data being processed.

If you have any concerns about the way, we have handled your personal data or would like any further information, then please contact our Data Protection Officer by ringing 01642 248750 or emailing compliance@adnsgroup.com (For the attention of Scott Thornhill).

If we cannot resolve your concerns, you may also contact the Information Commissioner’s Office (the data protection regulator) and raise a complaint about the way in which we have handled your personal data. You can do so by contacting the ICO by either ringing 0303 123 1113 or emailing casework@ico.org.uk

Further information about the UK's Anti-Money Laundering Regulations can be found https://www.gov.uk/anti-money-laundering-registration. For more information about how Tennants processes your personal data, please refer to this Privacy Policy.