Privacy Policy

Auction Holdings Ltd and its Group Companies

1 PRIVACY POLICY

1.1 We are committed to protecting the privacy and security of personal data. This Privacy Policy (“Policy”) tells you how we will collect and use your personal data, and what you should expect in respect of the personal information about you that we have collected.

1.2 This Policy applies to information held by Auction Holdings Ltd and its subsidiary companies, including Forum Auctions Ltd, Bid for Wine Ltd and Forum Fine Wine Ltd, together with any future subsidiary or affiliated companies within the Auction Holdings Ltd group (together referred to in this Policy as the “Group”).

In this Policy, “we”, “our” and “us” refers to the relevant Group company with which you interact, or Auction Holdings Ltd where it acts on behalf of the Group. Each Group company is responsible for processing personal data in accordance with applicable data protection legislation.

A current list of Group companies covered by this Policy is available on request.

1.3 This Policy applies to any Group service, auction, sale, event, valuation service, website, bidding platform or other business activity which provides a link to or refers to this Policy.

1.4 In this Policy:

“Data Protection Legislation” means the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR), and all other applicable legislation relating to privacy and data protection; and where we use the terms “personal data”, “data subject”, “controller”, “processor” and “processing” (and its derivatives), such terms shall have the meanings given to them in the Data Protection Legislation.

1.5 Using your information

1.5.1 We may collect and process information relating to you, your Personnel or other relevant individuals, in order to provide our services to you, including (but not limited to) newsletters and other information services or marketing materials. We shall process any information we collect in accordance with Data Protection Legislation and the provisions of this Policy.

1.5.2 Before providing us with any information you are responsible for ensuring that your Personnel or other relevant individuals are aware of this Policy and the provisions of such Policy are clearly communicated to them.

1.6 The information we collect about you

1.6.1 This “information” includes personal data, which means information that can be used to identify a natural person, including (but not limited to) the following types of personal information:

(a) contact information, such as an individual’s home or work address and contact details (including mobile telephone number);

(b) date of birth, marital/civil partnership status, details of dependents and next of kin;

(d) information about an individual’s professional qualifications;

(e) pay records, bank account details, national insurance number and tax details;

(f) copies of your passport or any similar documents used to verify your identity and for other client due diligence checks;

(g) information recorded on any forms you submit, such as tax residence, status and assets held for reporting purposes and similar requirements;

(h) details of any complaints or concerns raised by you or a relevant individual;

(i) information we obtain from the goods and services we provide to you, such as the date, amount and currency of any payments which are made to or from us, any bids, purchase and/or transactions you make and any goods you own, purchase or wish to consign;

(j) limited financial information, such as digital wallet details and wire instructions;

(k) information we collect when you set up an account with our website and/or bidding platform, including username and password;

(l) profile data including your interests, preferences, feedback and survey responses; information we collect when you, your Personnel or other relevant individuals communicate with us, or when you apply for our products or services, or any other time you or they contact us;

(m) information we collect when we make recordings of our auctions, premises and certain live events;

(n) information we collect when we record telephone bids and/or calls made to our customer services team for quality assurance, compliance purposes, and recordkeeping purposes; and

(o) information we obtain from third parties such as information that we obtain when verifying details supplied by you. This information obtained from other third party organisations or people may include other companies within the Auction Holdings Ltd group, employers, clients, advisers, credit reference agencies, social media sites, data supplementation services, fraud prevention and compliance check agencies or other similar organisations.

1.6.2 We do not generally anticipate processing any special categories of personal data about you, your Personnel or other relevant individuals (such as information about racial or ethnic origin, criminal or alleged criminal offences or health and lifestyle). However, in respect of events that we offer, this information may include details of any access or dietary requirements that you, your Personnel or other relevant individuals have, which may reveal information about the health or religious beliefs of a data subject.

1.6.3 If you do not provide us with the information set out in 1.6.1 above, or you, your Personnel or other relevant individuals object to us processing such information (see Section 4 for more information about your rights in relation to your information), we may be prevented from conducting business with you, or continuing to manage any services you hold with us, and we may be unable to provide our services to you.

1.7 Our use of your information

1.7.1 We may collect, record and use information about you, your Personnel and other relevant individuals, and the business you conduct with us in physical and electronic form and will hold, use and otherwise process the data in accordance with the Data Protection Legislation and as set out in this Policy.

1.7.2 We and other companies within the Group may process information we hold about you, your Personnel and other relevant individuals for a number of business purposes, provided we always have a lawful basis for processing, including:

(a) to provide any service to you or to administer our relationship with you and operate any consignments, purchase, sales or client
account(s) you may have with us;

(b) to monitor and analyse your dealings with or through us, including to manage and monitor our auctions

(d) to comply with and meet any and all of our legal or regulatory obligations, including any tax or revenue reporting;

(e) for our reasonable commercial purposes (including quality control and administration, assisting us to develop new and improved products and services, and administering goods and services provided to us);

(f) to confirm your or their identity and carry out including as part of our checks in relation to anti-money laundering, compliance
screening and to prevent fraud and other crimes;

(g) to follow up with you or them after you request information to see if we can provide any further assistance;

(h) to check your instructions to us;

(i) to monitor and analyse any communications to assess and improve our services to you, as well as for training and quality purposes;

(j) to prevent or detect abuse of our services or any of our rights (and attempts to do so), and to enforce or apply our terms with you
and/or any other agreement and to protect our (or others’) property or rights;

(k) to share information with relevant third parties in the context of a sale or potential sale of all or part of our business, subject always to confidentiality obligations;

(l) to bring to your or their attention information about auctions, wine sales, valuations, consignments, collecting opportunities, events and other products or services offered by us and other companies within the Auction Holdings Ltd group which may be of interest to you, unless you have indicated that you do not wish to receive such communications;

(m) to protect your interests (or someone else’s interests);

(n) to improve the relevance of marketing messages we may send you, your Personnel or other relevant individuals (which you can opt into and out of as explained below);

(o) to facilitate the efficient operation of the Group, including sharing relevant client, bidder, consignor, buyer and supplier information between Group companies for administrative, customer relationship management, compliance, operational, marketing and business development purposes, where permitted by applicable law and subject to your marketing preferences.

1.8 Lawful grounds for using your information

1.8.1 We have described the purposes for which we may use information about you, your Personnel or other relevant individuals. We are permitted to process such information in this way, in compliance with the Data Protection Legislation, by relying on one or more of the following lawful grounds:

(a) you or they have explicitly consented to us processing such information for a specific reason;

(b) the processing is necessary to perform the agreement we have with you or them or to take steps to enter into an agreement with you or them;

(d) the processing is necessary for the purposes of a legitimate interest pursued by us and your interests and fundamental rights do not override those interests, which might be:

• to ensure that our services are well-managed and our websites and bidding platforms operate effectively;

• to ensure the security and integrity of our auctions;

• to prevent fraud;

• to protect our business interests;

• to ensure that complaints are investigated;

• to evaluate, develop or improve our products and services;

• to learn about the interests and preferences of our current and prospective clients; and

• to keep our clients informed about relevant products and services, unless you have indicated at any time that you do not wish us to do so.

1.8.2 In relation to any processing of special categories of personal data, we will generally rely on obtaining specific consent in order to process such information, although it may be necessary for us to use certain information in order to comply with our legal obligations. Where you, your Personnel or other relevant individuals have consented to our processing of such information (including special categories of personal data) you or they may withdraw such consent at any time, by contacting us using the contact details in Section 9 below. Please note, however, that in certain circumstances it may be still lawful for us to continue processing this information even where consent has been withdrawn, if one of the other legal bases described above is applicable.

2 INFORMATION SHARING

2.1 Sharing Your Information With Others

2.1.1 We keep all client information confidential. However, in order to provide our services and operate our businesses efficiently, we may share information you provide to us:

(a) with Auction Holdings Ltd and other companies within the Group, including Forum Auctions Ltd, Bid for Wine Ltd and Forum Fine Wine Ltd, for operational, administrative, compliance, customer service, marketing, valuation, auction, wine sales and business management purposes;

(b) with agents, contractors and service providers who work on our behalf, including shipping agents, storage providers, payment processors, IT providers, cloud hosting providers and professional advisers;

(d) with counterparties, including consignors and successful bidders, where necessary to facilitate a consignment, purchase, sale or other transaction;

(e) with support service providers, analytics providers and customer relationship management providers;

(f) with marketing service providers and technologies used to administer communications and marketing campaigns;

(g) with government bodies, regulators, law enforcement agencies, HMRC, the Arts Council and other competent authorities where required by law or regulation; and

(h) in connection with any proposed or actual merger, acquisition, investment, restructuring, refinancing, sale of assets or sale of all or part of our business.

Where we share personal data with third parties, we will ensure that such disclosure complies with applicable Data Protection Legislation.

2.1.2 The recipients, or categories of recipients, of your information, or information relating to your Personnel or other relevant individuals, may be:

(a) fund administrators or transfer agents;

(b) bankers and digital wallet and cryptocurrency providers in relation to us, the funds we administer, collect, remit, transfer, or our clients;

(d) your advisers (including, but not limited to, accountants, lawyers or other professional advisers) where authorised to do so by you;

(e) UK and overseas regulators and authorities in connection with their duties (such as crime prevention);

(f) fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. We and fraud prevention agencies may also enable law enforcement agencies to access and use your information to detect, investigate and prevent crime;

(g) anyone to whom we may transfer our rights and/or obligations under our terms of business; and

(h) any other person or organisation after a restructure, sale, acquisition or reorganisation involving any company within the Auction Holdings Ltd group, as long as that person uses your information for the same purposes as it was originally given to us or used by us (or both).

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and will only permit them to process your personal data for specified purposes and in accordance with our instructions.

2.1.3 If we, or a fraud prevention agency, determine that you, your Personnel or other relevant individuals pose a fraud or money laundering risk:

(a) we may refuse to provide the services or finance you have requested, or we may stop providing existing services to you; and

(b) a record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you or them.

2.2 Sharing Third Party Information with us

If any information which you, your Personnel or other relevant individuals provide to us relates to any third party, by providing us with such information you or they confirm that you or they have obtained any necessary permissions from such persons to the reasonable use of their information in accordance with this Policy, or are otherwise permitted to give us this information on their behalf.

3 TRANSFERRING YOUR INFORMATION OUTSIDE THE UK

3.1 Information about you, your Personnel or other relevant individuals in our possession may be transferred to other countries (which may include countries outside the United Kingdom) for any of the purposes described in this Policy, including our transmission of such information to our other companies within the Group, advisers, administrators, service providers and agents outside the UK. If any such information (including special categories of personal data) belongs to your Personnel or relevant individuals other than you, by providing us with such information you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their information for such purposes in accordance with the following provisions, or are otherwise permitted to give us this information on their behalf.

3.2 When we, or our permitted third parties, transfer personal data outside the United Kingdom, we will ensure appropriate safeguards are in place, including:

3.2.1 transfers to countries recognised by the UK Government as providing an adequate level of protection;

3.2.2 the use of UK International Data Transfer Agreements (IDTAs) or the UK Addendum to the EU Standard Contractual Clauses; or

3.2.3 any other safeguard recognised under applicable Data Protection Legislation.

4 YOUR RIGHTS IN RELATION TO YOUR INFORMATION

4.1 General Rights

4.1.1 You, your Personnel and other relevant individuals have a number of rights concerning the way that we use your information. You are responsible for ensuring that your Personnel and other relevant individuals are aware of these rights. At any time, such individuals shall have the right:

(a) to be informed about the processing of their personal data;

(b) to obtain a copy of any personal data we hold about them;

(d) to request the erasure of their personal data, if they consider that we do not have the right to hold it;

(e) to object to their personal data being processed for a particular purpose or to request that we stop using their information;

(f) where applicable, to request not to be subject to a decision based on automated processing and to have safeguards put in place if they are being profiled based on their personal data;

(g) to ask us to transfer a copy of their personal data to themselves or to another service provider or third party where technically feasible or otherwise required by applicable regulations;

(h) to withdraw, at any time, any consent that they have previously given to us for our use of their personal data; or

(i) to ask us to stop or start sending them marketing messages at any time.

4.2 Access to your information

4.2.1 You, your Personnel and other relevant individuals may have a right of access to some, or all, of the information we hold about you or them, or to have any inaccurate information corrected, under the Data Protection Legislation. Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards any individual’s rights of a data subject.

4.2.2 We aim to ensure that the information we hold about you, your Personnel or other relevant individuals is accurate at all times. To assist us in ensuring that such information is up to date, please let us know if the personal details of you, your Personnel or other relevant individuals change by contacting us using the contact details in section 9. We will correct any incorrect or incomplete information and will stop processing personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

5 RETAINING YOUR INFORMATION

5.1 We will only retain personal data for as long as reasonably necessary to fulfil the purposes for which it was collected, including satisfying legal, accounting, tax, regulatory and reporting requirements. Personal data may be retained and accessed by Group companies where necessary for the purposes described in this Policy.

5.2 If you cease to use our services or otherwise end your relationship with us, or you decide not to go ahead with receiving our services or dealing with us, we may still keep your information where required to comply with legal or regulatory obligations.

6 SENDING YOU MARKETING INFORMATION

6.1 We and other companies within the Auction Holdings Ltd group may use your information from time to time to provide information about auctions, wine sales, valuations, consignments, events, collecting opportunities and related products and services which may be of interest to you. Such communications may be sent by post, telephone, email, SMS or other electronic means where permitted by law.

6.2 You, your Personnel or other relevant individuals may, at any time, request that we cease or do not send such information by one, some or all channels, by contacting us using the contact details in Section 9.

7 LINKS FROM OUR WEBSITE

Our website may, from time to time, contain links to and from the websites and/or bidding platforms of third parties that we permit to make such links. If you follow a link to any of these websites and/or bidding platforms, please note that these websites and/or bidding platforms have their own privacy policies and that we do not accept any responsibility or liability for these policies. We recommend that you check these policies before you submit any personal data to these websites and/or bidding platforms.

8 COOKIES

We use cookies and similar technologies on our websites to improve functionality, analyse website traffic and enhance user experience. Where required by law, we will obtain your consent before placing non-essential cookies on your device. You may manage your cookie preferences through our cookie consent banner and your browser settings.

8.1 First Party Cookies

These are cookies that are set by this website directly.

8.1.1 Analytics Cookies

We use analytics services, such as Google Analytics, to help us understand how visitors use our websites and to improve the user experience. These services collect information such as the pages visited, the time spent on the website, how visitors arrived at the website, the type of device and browser used, and general location information derived from IP addresses.

The information collected through analytics cookies is used to generate statistical reports and website performance insights. We do not use analytics cookies to directly identify individual visitors. Where required by law, analytics cookies will only be placed on your device with your consent.

For further information about how Google processes data collected through Google Analytics, please visit: https://policies.google.com/privacy.

8.1.2 Tracking technologies: We may use session identifiers, web beacons, cookies, JavaScript tags, and other tracking technologies. We use these technologies to enhance the user’s experience of our website. We also use this information to collect statistics about the usage of our services, perform analytics, deliver content which is tailored to your interests and administer services to our users, advertisers, publishers, customers and partners. The information we collect does not usually directly identify you, but it can give you a more personalised web experience. If we associate the information we collect with your personal information, we will treat such information as Personal Information.

8.2 Third Party Cookies

Some cookies may be placed on your device by third-party service providers whose services are used on our websites. These may include analytics providers, advertising networks, social media platforms, embedded content providers and other technology partners.

For example, where our websites include social media sharing functionality or embedded content, the relevant social media platform or service provider may place cookies on your device and collect information about your interactions with their services and our websites.

These third parties may use cookies and similar technologies to collect information about your browsing activities across different websites and online services. We do not control the operation of these cookies and recommend that you review the privacy and cookie policies of the relevant third-party providers for further information about how they use your information and how you can manage your preferences.

You can control or disable cookies through our cookie preference centre and through your browser settings. Please note that disabling certain cookies may affect the functionality of our websites.

9 CONTACTING US

9.1 If you or any of your Personnel or other relevant individuals wish to exercise any of the rights relating to your information set out above, or if you have any questions or comments about data protection, or you wish to raise a complaint about how we are using your information, you can contact us at compliance@forumauctions.co.uk.

9.2 If you, your Personnel or other relevant individuals have any concerns about our use of your or their information, you and they also have the right to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, via their helpline on 0303 123 1113.

9.3 We may make changes to this Policy and how we use your information in the future. If we do this, we will post an updated version of this Policy on our website. You can find the current version of this Policy on the website of the relevant Group company with which you interact.

EFFECTIVE DATE 09 JUNE 2026