GENERAL STATEMENT OF POLICY

We are Tiancheng International Auctioneer Limited (referred in this Privacy Policy Statement as "we", "us", or "our"). We pledge to meet fully, and where possible exceed, internationally recognised standards of personal data privacy protection, in complying with the requirements of the Personal Data (Privacy) Ordinance (as amended). In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality.

This policy together with our Personal Information Collection Statements set out the basis on which we will collect, use and process your personal data.

Please read this Privacy Policy carefully to ensure you understand how we handle your personal data and please also check this page from time to time as the Policy may be updated.

PERSONAL DATA COLLECTION AND RETENTION

We may collect your personal data directly from you when you complete certain forms and registrations, including when you complete our Bidding Form, sign up for news updates on our website, provide us with your business card, and provide us with personal data in your correspondence and other communication with us. We do not collect personally identifiable information from your use of our website without your knowledge, e.g. through the use of cookies.

In general, it is voluntary for you to provide your personal data. However, if you do not provide sufficient information, we may not be able to provide auction services to you.

It is our policy to retain your personal data only for as long as is necessary for the relevant purpose that it is held for.

PURPOSE OF USE OF PERSONAL DATA

We may use your personal data for the purposes of:

• enabling you to participate in our auction process;
• carrying out our obligations arising from any contracts entered into between you and us;
• communicating with you;
• verifying your identity;
• with your consent providing you with direct marketing information in relation to our previews, auctions and other events , which relate to our auction business;
• notifying you about changes to our services;
• analysing market trends and individual preferences to improve our services;
• liaising with third parties on your behalf, including your counterparty or counterparties to an auction transaction, and associated third party service providers for web hosting and other IT services, freight and logistics, insurance, testing laboratories, appraisers and experts; and
• ensuring that our website is presented in the most effective manner for users and their computers and their mobile devices.

POSSIBLE TRANSFEREES

We will treat your personal data as confidential, and shall not disclose it to third parties, save to the extent that:

• your counterparty or counterparties in an auction sale may require; or
• our appointed third party service providers (e.g. freight and logistics, insurance, testing laboratories, appraisers and experts) reasonably require to enable them to provide the applicable services to us, our client, or you; or Apr 2013
• we may be required to do so by a valid court order; at the lawful request of regulatory, government or law enforcement authorities; or pursuant to other legal processes, or if it becomes necessary to protect our rights or property.

While we are based in Hong Kong, we regularly handle transactions that involve overseas elements such as foreign buyers or sellers in a transaction, or engaging an overseas service provider or expert. As such your personal data may be used outside Hong Kong. By providing your personal data to us, you consent to our transmission to, and use of your information in, any jurisdiction, in accordance with this Privacy Policy, provided we ensure appropriate safeguards are in place to protect your personal data.

RIGHTS OF ACCESS AND CORRECTION

You have the right to request access to and correction of your personal data held by us. A small fee of HK$50 may be charged towards administration expenses in complying with data access requests but any requests for correction of your personal data will be free of charge.

SECURITY

We will take all reasonable and appropriate steps to protect the security and integrity of all personal data provided to us by electronic means or otherwise. We will ensure that your personal data is suitably protected against both unauthorised physical and electronic access. These measures include an electronic firewall and various other protection measures that involve virus scanning, installation of security patches, vulnerability testing, backup and recovery planning, employee training, security audits and other steps designed constantly to improve data protection. However, we cannot guarantee that information during transmission through the internet or any computer network is entirely safe from unauthorised intrusion, access or manipulation. We will have no liability for disclosure of information due to errors or unauthorised acts of third parties. In any event, where we believe personal data has been compromised, we will notify you of this.

CONTACT PERSON

If you wish to exercise your rights to access or correct your personal data held by us, or opt-out of our direct marketing activities, you should addressed your correspondence to the Client Services Department which is contactable by e-mail at info@tianchengauction.com or by mail to 30/F Bank of China Tower, 1 Garden Road, Central, Hong Kong.

You have a right (without charge) to opt out from receiving direct marketing from us at any time. If at any time you no longer wish to receive our direct marketing, please let us know by contacting our Client Services Department, listed above.

DIRECT MARKETING

We will not sell or transfer your personal data to third parties for direct marketing.

We intend to use your name, email address, correspondence address and telephone number to directly market our previews, auctions and other events, which relate to our auction business to you but we cannot so use your personal data without your consent.

CHANGES TO THIS POLICY

We reserve the right to amend or update this Privacy Policy and any of our privacy practices at any time. We will notify users of this website by posting any updated policy on this page and such changes will be effective immediately and without further notice. Where appropriate, we may notify you directly of changes to the Privacy Policy either through email or a prominent notice on our website.