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Privacy policy

Updated 02 May 2018

This privacy policy is separate from the PFW Terms and Conditions and sets out how we use and protect any information that you give us when you use this website or when purchase or sell through our auctions.

P.F. Windibank Fine Art Auctioneers and Valuers (“ we”, “ us”, “ our”) take your privacy very seriously. Please ensure you have read this privacy policy c2arefully as it contains important information on how and why we collect, store, use and share your personal information (being any information relating to an identified or identifiable individual). It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation (“ GDPR”), which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. 

We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

  1. What we collect

We may collect the following information:

  1. How we collect your personal information

We collect most of this personal information directly from you; in person, by telephone, or email. However, we may also collect information from cookies on our website, for more information on our use of cookies please see clause 11 below.

  1. How and why we collect and use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, these include:

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

Our reasons

To provide you with the goods available at our auctions or on our website and providing a service to you in doing so

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or us

For our legitimate interests or those of a third party, i.e.  to minimise fraud that could be damaging for us and for you

Conducting checks to identify our customers and verify their identity and other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulations

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g. policies covering security and internet use

For our legitimate interests, or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base and range of goods available

For our legitimate interests,  or those of a third party,  i.e. to be as efficient as we can so we can delivery the best service for you at the best price

Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party i.e. to prevent and detect criminal activity that could be damaging for us and for you and

to comply with our legal and regulatory obligations

Updating and enhancing customer records

For the performance of our contract with you or to take steps at your request before entering into a contract.

To comply with our legal and regulatory obligations.

For our legitimate interests,  or those of a third party,  e.g. making sure that we can keep in touch with our customers about goods that may be of interest to them

Statutory returns

To comply with our legal and regulatory obligations

Marketing our services to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests,  or those of a third party, i.e. to promote our business to existing and former customers and to provide you with a better service.

  1. Promotional Communication

We may use your personal information to send you updates (by email, text message, telephone or post) about our goods and upcoming auctions, this may also include exclusive offers, promotions or new goods available in our Online Shop.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘ How and why we collect and use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:


We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

  1. Who we share your personal information with

We routinely share personal information with:

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Save as where stated above, we will not share your personal information with any other third party.

  1. Where your personal information is held

Information may be held on our computer systems at our offices, third party agencies (i.e. Easy Live Auctions), service providers, representatives and agents as described above (see above: ‘ Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area (“ EEA”). For more information, including on how we safeguard your personal information when this occurs, see below: ‘ Transferring your personal information out of the EEA’.

  1. How long your personal information will be kept

We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

  1. Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the EEA, for example:

These transfers are subject to special rules under European and UK data protection law.

Non-EEA countries do not always have the same data protection laws as the United Kingdom and EEA. We will use our reasonable endeavours to ensure the transfer complies with data protection law and all personal information will be secure.

  1. Your rights

You have the following rights, which you can exercise free of charge:


The right to be provided with a copy of your personal information (the right of access)


The right to require us to correct any mistakes in your personal information

To be forgotten

The right to require us to delete your personal information—in certain situations

Restriction of processing

The right to require us to restrict processing of your personal information, in certain circumstances, e.g. if you contest the accuracy of the data

Data portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party, in certain situations

To object

The right to object:

—at any time to your personal information being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision-making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  1. Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

  1. How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your computer, or other electronic device, such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.

In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a service you have requested (e.g. to enable you to put goods in your shopping basket and use our check-out process).

If you visit our website when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of cookies and other similar technologies as described in this policy. If you change your mind in the future about letting us use cookies, you can modify the settings of your browser to reject cookies or disable cookies completely.

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies:

  1. Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

  1. Shop Transactions and SagePay does not directly process your payment and debit card information will never be entered on our website. Your name, invoicing address, delivery address and contact details that are entered during the checkout process are encrypted (using SimpleXOR and Base64) and passed to SagePay (our chosen payment processing partner) for processing. SagePay then process your payment securely using their chosen security and encryption methods (please see for more details).

  1. How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at or telephone: 0303 123 1113.

  1. Changes to this Privacy Policy

This privacy notice was published on 02 May 2018 and last updated on 02 May 2018.

We may change this privacy notice from time to time, when we do we will inform you via our website or via email, if we have your information.

  1. How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below and are available at any time on the “Contact us” page of our Website:

Address: P.F. Windibank, The Dorking Halls, Reigate Road, Dorking, Surrey, RH4 1SG

Email address:

Telephone: 01306 884556

Opening Times
The Office and Showroom are open
Monday to Friday 9am to 5pm and 
Most Saturdays 10am to 1pm (Please call before coming)
you can contact us on 01306 884556 or

Our Location
P.F. Windibank
The Dorking Halls,
Reigate Road,
Dorking, Surrey,
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