CONFIDENTIALITY POLICY IN FORCE FROM 03/10/2022


This document seeks to inform you of our practices for processing and protecting your Personal Data (“Data”), as defined below, obtained from the site https://drouot.com/ and https://www.moniteurlive.com/ (“The Platforms”), in strict compliance with your rights. 


We encourage you to read all the information we provide carefully and to please contact us if you have any questions.

  1. Definitions

"Data": means any information which, directly or indirectly, enables a natural person to be identified by reference to an identification number or to one or more elements specific to it.  You will never be asked to enter so-called “sensitive” personal data, such as your racial or ethnic origins, your political, philosophical or religious opinions, or information concerning your income or tax situation. 

Your Data are only collected for the strict use and understanding of the Platforms as well as the purposes described in Article 4.

Drouot SI acts as the data controller for your Data that is collected during the use of our Services and the Platforms to provide you with the Services. This means that Drouot SI is, in particular, responsible for its collection, security and use for the purposes described herein, in compliance with the Data Protection rules.

Drouot does not loan or transfer its customer files to third party commercial companies unrelated to the Services as defined herein.


"Services": Drouot SI provides websites that allow you to: 

  • participate remotely by electronic means on the website https://drouot.com/ (the “Drouot Platform ”) and on https://www.moniteurlive.com/ (“the MoniteurLive Platform”):
  • in public auctions broadcast live (“Live Sales”),
  • in auctions taking place only on the internet (“Online Sales”);


The Services are described in the General Terms and Conditions of Use of the Platforms (the “General Terms of Use”).


"Drouot SI" / "We": the Services are provided by Drouot SI, 9 rue Drouot – 75009 Paris, SAS with capital of 50,000 euros registered in the Paris Trade and Companies Register under number 790 095 780.


“User” / “You”: means any natural person using the Platforms.

  1. Consent

By using our Services and subscribing to the Platform, you undertake to provide genuine information about you and understand and agree that your Data may be collected, used, stored and disclosed to third parties as described below for the purposes of providing the Services to which you wish to subscribe.

The disclosure of false information is contrary to the General Terms and Conditions of Use.

  1. Data collected

We may collect the following categories of Data:


  1. Site Navigation

Connection data. Every time you log into one of the Platforms, we passively collect information such as, in particular, your computer’s IP address, the date and time of connection, together with information about your browser. 


Navigation data. We also collect information to identify how you access one of the Platforms, which pages are viewed and for how long. 

We may use Cookies as specified below.


  1. Creating an Account 

In accordance with the General Terms and Conditions of Use, when you create an Account on one of the Platforms (“Account”), you will be asked to enter a certain amount of Data, in particular your first and last names, your postal address, your email address, your telephone number, date of birth, etc.


We also ask that you send us your ID.


This information is required by sales operators organising auctions, in which you register to place Absentee Bids and bid, to comply with the legal obligation to formally identify their customers, to which they are subject in particular in the context of anti-money laundering. Account creation information is also needed to manage the customer relationship between Drouot SI and Users and is necessary for the use of one of the Platforms.


  1. Absentee Bids and online auctions with an Account

When submitting an Absentee Bid online (“Absentee Bid”) or when you bid online, we collect certain information such as the history and details of your purchases, the number and amounts of your bids, etc.

  1. Bank data

When you register for a sale on one of the Platforms, your bank details are requested to verify the validity of your bank account.

However, this Data is sent directly to Drouot SI’s payment service provider, (which is a PCI-DSS-certified company), through its own services. We do not hold such Data, we only have a footprint of it. Its collection and processing is governed by this company's own terms and conditions.


  1. Purposes of collecting your Data

Your Data are collected to enable us to provide you with the Services for one or more of the following purposes:

  • Creation of an account on one of the Platforms,
  • Enabling you to use one of the Platforms,
  • Providing you with a history and details of your purchases and the number and amounts of your bids,
  • Ensuring the proper execution of transactions initiated by Users such as: sales registrations, Absentee Bids, placing bids, purchases, payments and deliveries,
  • Offering efficient customer service, particularly in terms of helping users of one of the Platforms,  and complaint management,
  • Compiling a file of Users, customers and prospects,
  • Send Newsletters, solicitations and promotional messages according to the preferences selected when registering for one our website among the categories of objects offered under the conditions detailed below or the behavior observed during your navigation ("Newsletter "),
  • - Suggest, when you connect to the website, objects according to the preferences defined by you during your registration or observed during your navigation,Compiling sales and traffic statistics for our Services internally,
  • Managing outstanding payments and any disputes sent by sales operators regarding the use of our Services,
  • Combating fraud,
  • Managing your requests for the right to access, rectify and object to the collection of your Data, 
  • Complying with our legal and regulatory obligations. 


We inform you, when collecting your Data, if certain Data must be entered or if this is optional. If you do not complete these required fields, you will not be able to access the Services.


You can sign up to our Newsletter when you register or, later, by accessing your personal space from your Account. Your consent is obtained by ticking a box.

You can unsubscribe from Newsletters at any time by accessing your personal space from your Account in the "personal information" block in the "Profile" section or by clicking on the unsubscribe link found at the bottom of the emails received.

If the unsubscribe link malfunctions, you can unsubscribe by sending a message to the following address: [email protected]

  1. Recipients of the Data
  1. Sales operators

To find out more, we suggest that you read their privacy policies. You will then know how sales operators use your Data when they act as data controller for the running of Live Sales, Online Sales, the auction, payment and delivery of lots to the successful bidder.


A sales operator is a natural person or legal entity that arranges auctions. It uploads Traditional Catalogued Sales, Live Sales or Online Sales on one of the for use by Users.

This person can be: 

  • A voluntary auctioneer carrying out voluntary sales in accordance with the regime prescribed by Articles L.321-1 of the Commercial Code ((Voluntary auctioneer, notaries, bailiffs, sworn merchandise brokers, estate service, customs service fulfilling the conditions specified in the commercial code);
  • A legal Public Auctioneer, public officer and ministerial officer responsible for carrying out the appraisal, the valuation and the legal sale at public auction of the furniture and chattels governed by the laws of 10 July 2000 and 20 July 2011.
  • Anyone holding a certificate of aptitude for the profession of “commissaire de justice” in charge of carrying out the appraisal, auction, and judicial sale by public auction of furniture and personal effects whose activity is governed by law. known as “Macron” of August 6th, 2015;
  • Any person authorized to carry out auctions within the meaning of Articles L.322-1 et seq. Of the Commercial Code (notaries, bailiffs, sworn merchandise brokers);
  • Any person authorised to hold auctions in any other country and, in particular:
  • In Belgium, any person who has requested the presence of a ministerial officer to record the sale in the minutes;
  • In Italy, any company registered as such, having obtained a commercial sales licence issued by the Chamber of Commerce and a public safety licence issued by a special police force;
  • In Germany, the Versteigerer, counterpart of the French voluntary auctioneer, who is an independent professional of more than 25 years who has been judged to be of high moral standing and who has obtained administrative authorisation to carry out auctions.

During Galery Sales, the Sales Operator may also designate any professional wishing to sell at fixed price items on one of the Platforms independently of Live or Online Sale.

  • To manage your Absentee Bids or your online bids: we share some of your information with the sales operators to enable you to make an Absentee Bid or bid online on one of the Platforms. The sales operator thus checks your identity and meets the legal anti-money laundering obligation to which it is subject. Your identity data is then disclosed;


  • We also send your email or telephone number to sales operators so that they can contact you if necessary;


  • When sales operators manage the payment of your auction purchases themselves, we send them the necessary information, such as the amount of your bid and the nature of the lot won;


  • We may only share your Data with sales operators for direct marketing purposes with your agreement via a tick box when you register for one of the Platforms. When you have given us your consent, we undertake to share your Data only with sales operators and art professionals who use our services.     


  1. Our service providers

We share your Data with our own service providers located in the European Union, in particular to perform services and actions on request and on behalf of Drouot SI, such as checking the validity of your telephone number or ID, sending promotional and marketing emails or text messages or enabling you to manage your transactions.

Our service provider Selligent also uses your connection data to establish your preferences in terms of items categories. Drouot SI will thus be able to send you Newsletters corresponding to these preferences.

We use and process your login data to identify, delineate and eliminate malfunctions and errors in telecommunication systems.


If the conditions are met, we may use the login data to detect any illegal use of telecommunication systems and services.


  1. The Drouot Group companies

As Drouot SI is a subsidiary of the Drouot Group, it will be able to communicate your Data to any Drouot Group company in order to inform you about the services offered by the Drouot Group companies.


  1. The legal authorities

In accordance with the legal provisions in force, Drouot SI may be required to provide information to the competent authorities and courts for the purposes of criminal proceedings. Drouot SI may not notify you of the disclosure of your Data to authorised third parties.

  1. Data Retention Period

We retain your Data only for the period necessary for the performance of our Services and up to 3 years after the last use of your User Account. 

    

After this 3-year period, Drouot SI may contact you again to invite you to log in to your Account within a period of 15 days. In the absence of positive and express action on your part, the Account will be deactivated and the related data will be deleted or anonymised in accordance with the legal provisions in force.

In the event of a breach of the General Terms and Conditions of Use or this Privacy Policy, Drouot SI reserves the right to suspend your Account or to deactivate it definitively under the conditions described in the General Terms and Conditions of Use. 





  1. List of bad payers


In the event of a payment default by a Bidder at the end of the reminder procedure described in the General Terms and Conditions of Use, you agree that Drouot SI will keep your Data on a blacklist of bad payers for a maximum period of 3 years in order to prohibit you from using our Services during this period.

If you are registered on this list, you will be informed at the time of registration. 

 

If the incident is resolved, your Data will be completely removed from the blacklist. 


In the event of a dispute concerning inclusion on such a list, the User may contact Drouot SI on the conditions described in Article 11. 

  1. Closure of your Account

If you have created an Account and wish to close it, please write to us at the address shown in Article 15. 

Once your request has been received, we will deactivate your Account and delete or anonymise your Data within a maximum of two months of your request.


In addition, if your Account is not used for more than 3 years, Drouot SI reserves the right to deactivate your Account, subject to sending a prior email inviting you to connect to your Account within 15 days. If you do not log in, we will deactivate it and delete or anonymise your Data which will then be used only for internal statistical purposes.

  1. Security

We have implemented technical and organisational security measures to ensure the security, integrity and confidentiality of all of your Data to prevent it from being lost, stolen, damaged, distorted or distributed to unauthorised persons. 


In addition, you are responsible for ensuring the confidentiality of the password that allows you to access your Account. Do not share this information with anyone. If you share your computer, don’t forget to log out before leaving one of the Platforms.


We do not have access to your password. We cannot, therefore, send you your password if you forget it. However, you can change it at any time on one of the Platforms via the password reset procedure.


We store your Data on servers located within the European Union.

  1. Cookies

Cookies are text files stored in your browser. They are created when a User’s browser loads a given website: the site sends information to the browser, which then creates a text file.

Each time you return to the same site, the browser retrieves the file and sends it to the website server.


When you first visit one of the, a warning banner appears asking if you agree to the use of cookies while browsing. These cookies will be activated once you have given your permission. 

This banner informs you that, by continuing to visit the Platform, you are deemed to agree to the use of cookies, for which your permission is required, during your browsing.


You can also continue to browse while refusing cookies under the conditions described below.


  1. Cookies used

Drouot SI uses the services of Google Analytics to collect information about your use of the Platforms.


Google Analytics is a marketing analytics service operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses text and digit codes that will be stored on your device and that will analyse the use of the Services. 

The information generated by cookies about your use of the Services (including your IP address) will be transferred to and stored by a Google server. 

Google will use this information to assess your use of the Services, prepare activity reports for site operators and provide other services related to the use of sites and the Internet. 

Google may transfer this information to third parties if required by law or if third parties process this data on behalf of Google. 


Google Analytics stores information about:

  • The pages you visit on Platforms;
  • The time you spend on each of these pages;
  • The links that made it possible to arrive on Platforms;
  • What you click on when browsing Platforms.


We do not use re-targeting advertising cookies or any other pixel advertising prospecting service indicating whether users have performed specific actions on a site after clicking on an advertisement appearing on one of the pages.


Google Analytics uses the following cookies:

Name

Expiry

Role

_ga

14 months

Indicates how many people visit Platforms, distinguishing users who have already visited the Platform.

_gat

10 minutes

Used to monitor how often web page requests are made


  1. Purpose of using cookies

The cookies we send allow us to:

  • compile statistics and volumes of visits and use of the various features of Platforms (sections and content visited, routes), enabling us to improve the interest and ergonomics of our Services;
  • Adapt how Platforms is presented to the display preferences of your device (language used, display resolution, operating system used, etc.) during your visits to Platforms, depending on the hardware and software used by your device to view or read content.


  1. Managing cookie settings

To refuse cookies but continue to browse, you can change your settings in your browser at any time. 

Each browser’s configuration for the management of cookies and your choices is different. Your browser's help menu will tell you how to change your preferences regarding cookies. You will find information below about the main browsers.


Any reconfiguration may change your browsing on the Internet and your conditions of access to certain Services requiring the use of cookies. 

We do not accept any liability whatsoever for the consequences associated with the reduced operation of certain Services, resulting from the inability to save or consult the cookies necessary for their operation and which you have refused or deleted.


You can also choose to object specifically and solely to Google Analytics cookies by installing the additional unit accessible by clicking on the following link: 

https://tools.google.com/dlpage/gaoptout?hl=None

  1. User’s Rights

The Data provided are necessary for the performance of the contract for the provision of Services to which you have agreed. You may, therefore, not withdraw your consent to the processing of Data necessary for the performance of the Service, unless you cease using the Services.


However, you may consult, modify or request the deletion of your Data for legitimate reasons at any time using the contact details specified in Article 15 below. These requests will be implemented within two months of your request. Since 25 May 2018, requests to restrict the processing or portability of the Data have been made on the same conditions.


You may also object at any time to the processing of your Data to which you have previously given specific consent for marketing purposes.


Drouot SI provides you, free of charge, with information relating to the Data stored about you. Information may be provided electronically if you wish.


For your security, please understand that in the event of a request for information or modification, we need to verify your identity. Your ID will not be retained following your request.


Drouot SI undertakes to notify all recipients of the Data processing of your request.

  1. Treatment of data after death

You have the right to compile guidelines, to which you have specifically consented, relating to the retention, erasure and disclosure of your Data after your death. You may change or revoke these guidelines at any time.

You may appoint a person to carry out your guidelines. Upon your death, Drouot SI will consult the guidelines and request that they be implemented. Where you have made no such designation or, unless otherwise directed, in the event of the death of the person, your heirs have the capacity to read your guidelines and request that Drouot SI implements them.

In the absence of any guidelines or of anything to the contrary in your guidelines, your heirs may exercise your rights to the extent necessary for the following purposes:

  • Organisation and settlement of your estate. As such, your heirs can access the Data processing concerning you in order to identify and obtain information useful for the liquidation and sharing of the estate. They may also be provided with digital goods or family-related data that can be passed on to heirs;
  • Drouot SI’s processing of your death. For this purpose, your heirs may have your Accounts closed, object to the continued processing of Data concerning you or have them updated.


When requested by your heirs, Drouot SI shall provide evidence, at no cost to the applicant, that the transactions required by the heirs have been carried out.

Disagreements between heirs regarding the exercise of these rights will be brought before the competent High Court.

  1. Change to the privacy policy

Drouot SI reserves the right to amend the Privacy Policy at any time, and this remains applicable for the entire duration of the use of Platforms and Services. In the event of a change, Drouot SI will inform you by email.

If you decline such changes, you agree to cease using the Services. Otherwise, your use of the Services is subject to the terms of the new version of the Privacy Policy.

Where you access the Services after being notified by Drouot SI of the new version of the Privacy Policy, you are deemed to have accepted this new version of the Privacy Policy in full.

The new version of the Privacy Policy applicable to the Services is available on thePlatforms. Drouot SI invites you to consult this regularly.

Drouot SI also reserves the right to modify or suspend, without giving any reason, all or part of the Services.

No compensation is payable to you for any modification or deletion of the Services.

  1. Disputes

In the event of a dispute concerning the use of your Data, you may refer the matter to the French National Data Protection Authority (the CNIL).

  1. Contact

You can send any questions about your Data and how we use it directly to: [email protected] or to the following postal address: Drouot SI - 18 boulevard Montmartre - 75009 Paris.


If you want to delete your Account or to exercise your right to object, question, access, correct or remove the Data, you can contact us at the same addresses on the conditions described in Article 11 above.