TBAuctions Netherlands B.V. and its subsidiaries auctioning under various brands (including TWA B.V.) in Europe (hereinafter collectively “TBAuctions“) process personal data of visitors and users of our auction platform and Apps. TBAuctions is headquartered in Amsterdam, the Netherlands. In this privacy statement, we inform you about the personal data we may process, the reasons for this and the manner in which this is done. In addition, we inform you about your privacy rights with respect to the processing of your personal data.

The most recent version of this privacy statement is always available on our website. We encourage you to periodically review our privacy statement so that you are aware of any changes.

TBAuctions processes your personal data because you use our services and/or because you provide them to us yourself. Below is an overview of the personal data we may process:

• Account ID
• First and last name
• Second name
• Salutation Mr./Mrs. (gender)
• Date of birth
• Address details
• Country
• Phone number
• Email address
• Signature
• Bank account number
• VAT number
• Chamber of Commerce number
• TIN number (for vendors)

• Personal Identification Number (for vendors)
• Copy of ID

• Your bid history (the number of bids placed on our lots) and bid amount
• IP address
• Internet browser and device type
• Data about your activities on our websites and/or apps

• Data about your browsing behavior across different websites (after permission on our cookies)

Other personal data that you actively provide, for example by creating a profile on our websites and/or apps, in correspondence and by telephone

In order to provide you with the best possible service, we collect, process and store your personal data for the following purposes;

Creating an account
Through our websites or in our apps, you can create an account on our auction platform that allows you to participate in our auctions. As a buyer, you have the choice of a business or a private account. When creating an account, we collect, process and store personal data from you that is necessary for entering into a business contract (for sellers), or your participation in our auctions (for buyers)

Customer review
When you register as a seller or buyer on our auction platform, we are required by law to collect and verify certain information from you before we can accept you as a seller or buyer. This includes collecting your first and last name, date of birth, address and contact information, tax identification number and a copy of your ID.

Releasing bids
When you place a bid in our auctions, we process personal data such as your first and last name, e-mail address, telephone number and your bidding history (the number of bids placed). When a lot is closed and you have become the highest bidder, this is called a successful bid.

Successful bids and payments
When you have made a successful bid, a purchase agreement is created between you and TBAuctions. This means that you have a payment obligation. To register your payments we process your first and last name and bank account number.

Both as a seller and as a buyer, you can view your registered personal data in your account on our auction platform and adjust it where necessary.

Financing your purchases
Once you have made a successful bid on the platform, you may have the opportunity to finance your purchase. To process your financing requests, we collect and process your first and last name, date of birth, address and contact information, among other things.

Collection and delivery purchases
When you, the buyer, come to pick up your purchases, please bring our invoice with you. If everything is correct, we may ask you for your signature confirming receipt of the lot(s). For this purpose, we process the personal data provided on the invoice and explained in your Profile under My Purchases.

If you are unable to take advantage of our pick-up days yourself, we offer you the option of having your purchases delivered.

Property transfer
For some parcels, such as registered property, we work with notaries, lawyers and/or trustees in the case of transfer of ownership. In such cases, we may process your personal data, such as your name, e-mail address and telephone number, to comply with legal requirements.

Receiving transactional communications
During your interactions on our auction platform, such as participating in our auctions, we process your first and last name and email address to send you transactional emails. Transactional emails are messages sent automatically in response to your interactions with our platform. These emails contain important information about your activities, such as bid confirmations, updates on your purchases and other relevant notifications. These emails are intended to inform you and do not contain commercial messages. It is not possible to unsubscribe from these emails as they are essential for your use of our services.

Contacting our Customer Service Team
If you have questions or complaints about our auctions, or other aspects of our service, please contact our Customer Service team. We record all interactions you have with our Customer Service team. To do so, we process your first and last name, contact information, account ID and other data that facilitates handling. We may record your telephone conversation with one of our employees for training purposes. You will be informed if this occurs.

Participation in our customer satisfaction surveys
We believe it is important to continually improve our services. We may ask you for feedback on our services through customer satisfaction surveys. This can be done, for example, via email, in which we ask you to leave a review of your last purchase.

If you do not need these emails, you can easily adjust your communication preferences in your account under Communication Preferences or use the unsubscribe link in the emails. If you need assistance, please contact our Customer Service team.

Receive personalized recommendations and newsletters
As a buyer, you can easily indicate via Communication Preferences in your account which channel you want to be informed by us and with what frequency. We will only send you personal recommendations, marketing campaigns, platform updates or newsletters if you have given us your prior consent (opt-in). This means that you may also receive information from other auction brands within TBAuctions. For this purpose, we process your first and last name, e-mail address, address data or telephone number, depending on the preferences selected. In our newsletters, we use techniques that measure and improve the effectiveness of our services.

You can easily withdraw your consent yourself in your account under Communication Preferences, via the unsubscribe link at the bottom of our emails, or by contacting our Customer Service team.

Visiting and using our websites and apps
When you accept our cookies while visiting our websites, we process your data to optimize our website and provide you with an optimal user experience. For example, we track the search terms you use, the auctions you click on and the types of lots you bid on. This information allows us to send you personally relevant emails and share information on social media. In addition, we use this information for reporting purposes. More information about the use of cookies can be found on your auction partner’s website.

Contact via Social media
You can connect with us through various social media, including Facebook, Instagram, WhatsApp, LinkedIn, YouTube and X. Based on your interests, we show personalized ads about our upcoming auctions. This is done through the use of cookies. More information about the use of cookies can be found on your auction partner’s website.

We process your personal data on the following bases:

Basis Implementation of agreement
It is necessary to process your personal data in order to perform a contract with you. This basis applies to the following processing purposes:

• Creating an account;
• Issuing bids;
• Successful bids and payments;
• Financing your purchases;
• Collection and delivery of purchases;
• Contacting our Customer service;
• Receiving transactional communications.

Basis Consent.
You have given us permission to process your personal data. You have the right to withdraw your consent at any time. From then on, we will no longer process your personal data unless there is (also) another basis for processing your data. This basis applies to the following processing purposes:

• Receive personalized recommendations and newsletters;
• Visiting and using our websites and apps;
• Participation in our customer satisfaction surveys;
• Contact via Social media;

Basis Legal obligation
In certain cases, the processing of your personal data is necessary for us to comply with a legal obligation.  This basis applies to the following processing purposes:

• Customer review;
• Property transfer;
• Tax and administrative obligations;
• Competent authorities.

We are required by law to respond to requests from judicial authorities, such as the police, prosecution, courts or supervisory authorities within the countries in which we operate.

Justified interest
In certain cases we process your personal data on the basis of our ‘legitimate interest’. In doing so, we balance the interests of TBAuctions to provide you with the best possible service against your own privacy interests. This basis applies to the following processing purposes:

• Tracking and fixing technical problems;

When a technical problem occurs on our platform, we process data from you to enable us to prevent the loss of vital information.

Camera surveillance for the purpose of securing our auction locations and offices.

TBAuctions is the controller for the processing of your personal data and determines the purposes and means of processing. We use third parties to process your personal data. We never sell your personal data to such parties.

Sharing your personal data with Vendors
When you, the buyer, have made a successful bid on one or more lots, a purchase agreement is created. We provide your information to the seller of the lot so that they can fulfill their own tax and administrative legal obligations or contact you with questions or complaints.

Sharing your personal data with third parties
We use third parties (Processors) to provide our services. Examples of Processors are our payment partners, logistics partners, marketing partners or parties that collect your feedback for us. TBAuctions determines the processing purposes of your personal data for the Processors. Processors may not process your personal data for other processing purposes without prior written consent from TBAuctions. TBAuctions enters into processing agreements with Processors to ensure the protection of your personal data, unless it concerns a party that is itself also a Processor. In that case, TBAuctions records who is responsible for which part of the processing purpose.

Sharing your personal data with competent authorities
There are also competent authorities to whom we may share your personal data when they require us to do so. We may share your personal data to fulfill our legal obligation to respond to requests from competent authorities within the countries in which we operate, such as:

• IRS;
• Investigative Services;
• Supervisory authorities.

Sharing your personal data with our auction brands
We offer you as a buyer on our auction platform the opportunity to participate in auctions organized by our various auction brands. We may share your personal data with our auction brands to enable bidding or to execute the contract in the event of a successful bid. In doing so, the processing purposes such as mentioned in section 3 of this privacy statement.

Whenever possible, we store your data within the European Union. If your data is stored in countries outside the European Economic Area, we ensure that these countries have a comparable level of protection. For partners based in the United States, we use model contracts, which ensure the protection of your personal data. For the storage of your data, we have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access, loss, destruction or alteration.

 

We do not retain your data longer than necessary for the purposes of processing, taking into account legal retention obligations. We process some of your data anonymously for internal analysis and reporting purposes, such as your bid progress on lots in our auctions.

You have the right to know how we handle your data and what privacy rights you can exercise, such as access, rectification, deletion, restriction of processing, objection and data portability.

We do not charge for exercising these rights unless you make multiple similar requests withina short period of time.

TBAuctions takes your privacy seriously and asks for identification before we process your request. If in doubt about your identity or inaccurate information, we may request additional information or deny your request. You will receive a response within 30 days. If necessary, the deadline may be extended by 60 days.

Right of inspection
If you want to know what personal data TBAuctions process about you, you can submit a request for inspection to us by contacting our Customer Service team. After verifying your identity, you will receive a copy of your data, including:

• The processing purposes;
• The categories of personal data processed;
• Recipients or categories of recipients and their countries of residence;
• The expected retention period or criteria for doing so;
• Information about your rights to rectification, deletion, objection and restriction of processing;
• Information about your right to file a complaint with the Personal Data Authority;
• Information about the source of the data, if not provided by you;
• Information about automated decision-making, including profiling;
• Information on the safeguards for the protection of your personal data when disclosed to countries outside the EEA.

Right to rectification
You have the right to correct incorrect or outdated data that we hold about you and to complete incomplete data. You can easily change (some of) your data yourself in your account or by contacting our Customer Service team.

Right of removal
You have in some cases the right to have your data deleted, also called “the right to be forgotten. You can make a deletion request by contacting our Customer Service team. To process this request, please clearly provide your first and last name, e-mail address, address information and account ID. In certain cases, we may deny your removal request, for example, if we are required by law to retain your data.

Right to restriction of processing
You have the right to make a request to restrict the processing of your personal data. This means that we may keep your data, but not use it. This right applies in certain situations. If you think this right applies to you, please contact our Customer Service team about this.

Right to object
You have the right to object to the way we process your data. This right applies to personal data we use for Direct Marketing, such as newsletters. If you would like us to stop using your personal data for personalized emails about our auctions, this can be done through our Customer Service team or you have the option to opt out via your account, under Communication Preferences.

Right to data portability
You have the right to request any data you have provided to us; within the framework of the contract, you have concluded with us. So that you can store this data in a database for yourself or a third party. To do so, you can submit an exercise request to our Customer Service team, stating your first and last name, e-mail address and account ID.

You will receive a file in a machine-readable format (CSV or XML) containing all personal data that you have provided to us during the creation of your account and during your activity on our auction platform, such as:

• First and last name;
• Contact details;
• Address information;

If applicable, your bid information and purchase history.

TBAuctions does not collect or process special categories of personal data, such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, data concerning health or sexual behavior, as defined in Article 9 of the AVG.

Sensitive data, such as creditworthiness, is required only for special lots at auctions, such as aircraft or expensive goods, to avoid any payment and delivery issues.

TBAuctions Netherlands B.V. together with TWA B.V. is responsible for your data once it has been provided by you for the use of our platform and auction services.

The address of our main office is:
Overschiestraat 59
1062 XD Amsterdam

Chamber of Commerce number :          33191886
VAT number :                                        NL003587344B01

For questions about this Privacy Statement, the processing of your personal data or other Privacy-related questions, please contact us at dpo@tbauctions.com.

If you are not satisfied with how we handle your data, we are committed to working with you to address and resolve any concerns you may have. You can submit any questions or complaints by contacting our Customer Service team. Please clearly state your first and last name, e-mail address and account ID, so we can process and help resolve your question or complaint efficiently.

Alternatively, you can contact the Personal Data Authority for all of our auction brands:

• Personal Data Authority
  Attn: Data Protection Officer
  P.O. Box 93374
  2509AJ The Hague