Introduction

Integrity, Expertise and Service have been Doyle’s guiding principles since we were established in 1962. Our priority has always been to provide auction and appraisal services that exceed industry standards, while building lasting relationships based on trust and professionalism with our clients around the world. 

Doyle closely guards the privacy of our clients, including our consignors, sellers, buyers, bidders and visitors to our website and our offices in New York and across the country. Protecting the identities of our clients and their personal information has always been essential to our core beliefs at Doyle. 

This Privacy Policy applies to Doyle and to Hayloft Auctions by Doyle. We may update this Privacy Policy as needed and recommend that you check this page regularly, as we do not necessarily send notifications of changes to our Privacy Policy.  

Doyle has built a professional reputation for transparency and ethical business practices. We invite you to contact us with any questions regarding the personal information that we gather and process. 

How and when we collect your personal information
What personal information we collect and why
Who gets to see your personal information
How long is your personal information retained
How we ensure the security of your personal information
California Privacy Rights
Children’s Policy
Additional information for EEA residents
Contact Information

How and when we collect your personal information

Most of the information we collect is provided directly by you
• When you register to bid in an auction or express interest in purchasing property
• When you request an evaluation of your property, make an appointment with our Specialists or Regional Representatives, or agree to sell property at Doyle
• When you complete a mailing list form, sign up on Doyle.com to receive news about upcoming auctions and events, subscribe to our auction catalogues, or provide us with your business card or other materials
• When you attend one of our events in New York and elsewhere

Automatic methods we use to collect information
• Your voice will be recorded if you use our live telephone bidding service during an auction
• Your image may be recorded by our closed-circuit video security system when you visit our premises. Closed-circuit video is an important component of our comprehensive security system designed to protect our clients, our staff and the property on our premises
• Information about your computer is gathered when you visit our website. This includes your browser type, operating system and IP address. This information is used to maintain our website and its capabilities and to improve the user experience
• Our website collects information about you through the use of cookies, a simple text file that is stored on your computer or mobile device. A cookie allows our website to remember your browser activity while visiting our site, which enhances the functionality and user experience during your visit. The information collected also allows us to deliver targeted advertisements. Read our Cookie Policy

How we collect information from other sources
• When we are informed by a client that you are authorized to bid at auction on their behalf, to receive information on their transactions, or to retrieve their property
• When we are introduced to you or you are referred to us by an individual or organization
• When we come across information about you while researching auctions, market trends, collecting and other topics in publications and online 

What personal information we collect and why
Doyle collects any and/or all of the following:

Examples of Personal Information
(This list is not comprehensive)
Purpose Legal Basis for Processing
• Name, business, mailing address, email address, telephone number and references
• Payment details, including banking information, credit card number and other documents to establish credit
• Details of your insurance if your property remains at your risk
• The person or organization who introduced you, any fee they receive
• Details of the property related to services provided and contractual terms
• Records of your communications with us
• To provide you with requested services, including but not limited to placing bids, establishing credit, selling property, conducting appraisals • Performance of a contract
• Name, business, mailing address, email address, and information about your location and collecting interests • To provide you with news about upcoming auctions and events • Legitimate Interests
• Consent
• Information about your IP address, browser type, operating system, session duration, navigation and transactions • To improve the functionality and user experience of our website
• To deliver targeted advertisements
• Legitimate Interests
• Date of birth and identification documents with photograph • To comply with legal requirements, including preventing money laundering • Compliance with a legal obligation
• Your voice recording when you use our live telephone bidding service during an auction
• Your opinions, feedback, suggestions and responses to our survey
• To monitor your use of our services, train our staff and improve the client experience • Legitimate Interests
• To keep you, our staff and the property on our premises secure • Your image captured by our closed-circuit video security system when you visit our premises • Legitimate Interests
• Public Interest
• Your interest in or possession of certain art and other property
• Allegations of unlawful activity relating to an object connected to you and communications with government authorities in relation to you or the object
• To create and maintain records on art and other objects to assist with authenticity, provenance, title and prevent unlawful activities • Legitimate Interests

Who gets to see your personal information

Doyle keeps all of your personal information completely confidential. We do not sell, rent, transfer or share any of your information to any third parties for commercial purposes. We only share your personal information with our service providers and other organizations when it is necessary to enable us to provide certain services. For example, we may transfer your data to our bank, a designated shipper, an insurer or a mailing house for direct marketing fulfillment. We may also may be required by subpoena, court order or other legal process to disclose certain personal information about you with third parties that are acting on proper legal authority, including law enforcement and government agencies.

How long is your personal information retained
Doyle will retain your personal information as long as necessary to provide requested services, and as long as the data is relevant to our legitimate business interest and the public interest.

How we ensure the security of your personal information

Doyle protects your personal information using a variety of security technologies and procedures. Please be aware that no security system is impenetrable, and we cannot guarantee that your personal information is entirely safe from unauthorized intrusion or access. You remain responsible for the security of your username and password and any information that you transmit to us.

In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. We will provide that notification as promptly as possible under the circumstances or as otherwise required by applicable law. You consent to our use of your e-mail address as a means of such notification.

California Privacy Rights

Under the California “Shine The Light” law, California residents may request certain information with respect to any personally identifiable information that may be shared with third parties for direct marketing purposes. If you are a California resident and would like to request such information, please see Contact Information below.

Children’s Privacy

We do not collect any personal information from children under 13 years of age. All auction bidding is restricted to adults over the age of 18.

Additional information for EEA residents

The following GDPR supplemental terms apply specifically to residents of the European Economic Area (EEA). To the extent these GDPR terms vary from those above, the GDPR terms shall control your relationship with us when you interact with us or provide any “Personal Data” to us.

Personal Data: The GDPR defines “Personal Data” broadly to include with respect to a natural person a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Controller of Personal Data: Any Personal Data you provide to us or we gather from you is controlled by William Doyle Galleries, Inc (“Doyle”), 175 East 87th Street, New York,New York 10128 USA. Doyle also does business as Hayloft Auctions.

Information We Collect From You: The types of Personal Data we collect from you are described above under What personal information we collect and why.

Where Your Data is Stored: Doyle and the Doyle.com website store personal data on Doyle’s own servers located in New York.  Hayloft Auctions and HayloftAuctions.com store personal data relating to auction sales with a third party service provider. Credit card payments for Hayloft auction sales are processed securely through our third party service providers, currently AuctionFlex and First Data/CardConnect, both of which providers are GDPR compliant as data processors.

Consent for Computer Cookies: Your consent to accept cookies from our Site will be requested when you access this Site. You have the option to reject our cookies, but some functionality of our Site may be affected.

Marketing and Promotional Emails: If you have been receiving email communications from us, you will be separately requested to voluntarily accept ongoing emails and any other marketing and promotional communications from us. If you do not agree to accept such communications, then we will not send any further marketing or promotional emails or materials to you unless you opt-in voluntarily. If you give your consent, you may revoke that consent at any time by contacting us at the Contact Information below.

Use of Your Personal Information: Your Personal Data is used by us in accordance with the provisions set out above under: What personal information we collect and why.

Disclosure of Your Personal Data: We disclose your Personal Data in accordance with the provisions set out above under: Who gets to see your personal information. We insure that our third party service providers who receive or process any Personal Data as data processors are GDPR compliant.

Changing or Deleting Your Personal Data: You have the right to have your Personal Data updated, corrected or, where necessary, supplemented. You have the right to have your Personal Data deleted in certain situations where the data retention is no longer necessary in relation to the purposes for which it was collected or otherwise processed, unless there is a compelling legal ground for the data processing, we are required to retain the data for compliance with a legal obligation, or we need to retain the data for the establishment, exercise or defense of legal claims.

You also have the right to have your Personal Data transformed into anonymous form or blocked if processed in violation of the law.

Access to Your Data: You have the additional right to make a “subject access request” for access to, review of or to obtain a copy of your Personal Data. Should you exercise this right, Doyle will provide you with a description and copy of your Personal Data that we have gathered and an explanation of why we are processing it. You also have the right to request that we stop collecting, processing or using your Personal Data.

Contact Information: Any requests to access your Personal Data and any other requests concerning our use and retention of such data, changes or deletion of your data, and enforcement of your privacy rights, should be submitted to us verbally or in writing as directed below under Contact Information below.

Complaints: You may raise a complaint with the relevant EEA supervisory authority if you believe Doyle has infringed applicable data privacy laws when processing your personal data. This right is without prejudice to any other administrative or judicial remedy you might have.

Contact Information

Doyle is happy to address any questions, concerns, suggestions or complaints relating to the processing of your personal information. Please contact us at compliance@Doyle.com or write to us at:

Doyle
Compliance Department
175 East 87th Street
New York, NY 10128 USA
Tel: 212-427-2730
Dated: July 27, 2018