Privacy Policy

1. Introduction

1.1  This Privacy Policy details how we, Apollo Galleries LTD and Apollo Art Auctions LTD of  10-12 Mulberry Green, Old Harlow, Essex, CM17 0ET collect, use and process personal data provided to us. If you have any questions on this Privacy Policy or otherwise relating to how we process your personal data you can contact us atinfo@apollogalleries.com.
1.2  This Privacy Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide your personal data to us or request that your employer does not do so.
1.3  We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any changes to it.
1.4  We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.

2. Whose personal data do we collect?

2.1 By personal data we mean identifiable information about you, such as your name, email address, gender, age, mobile and home telephone number and your IP address.  
Information you provide to us
From time to time you may provide to us personal data. This may be because you wish to:

• use our website;

• purchase goods from us;

• sell or purchase goods through our auction;

• apply for a job with us;

• provide services to us; or

• otherwise contact us including with queries, comments or complaints.
   

You may provide personal data to us directly, or to us through our social media platforms.
We shall process all such personal data in accordance with this Privacy Policy. Certain personal data is mandatory to be provided to us in order that we can fulfil your request, for example to buy goods from us or to participate in our auctions, and we shall make this clear to you at the point of collection of the personal data.
If you provide to us personal data about any other individual, you must have their consent to do so.
All personal data that you provide to us must be true, complete and accurate.  If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.
At our request, you shall promptly provide evidence of your identity.
When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.
Information we automatically collect about you
When you use our website, we automatically collect and store information about your device and your activities. This information could include :

• technical information about your device such as type of device, web browser or operating system;

• your preferences and settings such as time zone and language; and

• how long you used the website and which services and features you used.
   

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.
Information we receive from others
If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties confirming or otherwise, your identity.
We may also receive personal data about you from third parties such as our payment providers and our website security service partners.  

3. Lawful use of your personal data

We will only use your personal data where we have a lawful basis to do so.  The lawful purposes that we rely on under this Privacy Policy are:

• consent (where you choose to provide it);

• performance of our contract with you;

• compliance with legal requirements; and

• legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.

If you order goods from us, we shall use your personal data to manage your order.
If you participate in an auction, we shall use your personal data to manage your participation.
We may from time to time need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety.  
We may also use your personal data for our legitimate interests including to improve our services and in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; to deal with any customer services you require; for audit purposes and to contact you about changes to this Privacy Policy.

4. Who do we share your data with?

For our legitimate interests, we may share your personal data with our service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers,  IT service providers, accountants, auditors and lawyers.  
We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems.
If you participate in our auction platform, we may also share your personal data with the buyer or seller of goods you have sold or bought as appropriate if there is a dispute in relation to the sale.

5. Where we hold and process your personal data

Some or all of your personal data may be stored or transferred outside of the European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the EEA or if any of our service providers are based outside of the EEA
Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’sStandard Contractual Clauses, or by ensuring the entity isPrivacy Shield certified(for transfers to US-based third parties).

6. Security

We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.  In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.
However, unfortunately, because of the nature of electronic storage,  we cannot promise that your personal data will always remain secure.   If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.

7. Marketing

If you have bought goods from us, or participated in one of our auctions, we may send you marketing emails for our legitimate business interests.    You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email.  Please note that it may take us a few days to update our records to reflect your request.
If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information.

8. Your rights

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be foundhere

• Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.

• Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.

• Right to portability: You can request that we transfer your personal data to another service provider.

• Right to restriction of processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information.

• Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws.

• Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your subscription
   

We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.
If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time.  You can also contact the Information Commissioner, see www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local regulatory authority.

9. Retention of personal data

Subject to the provisions of this Privacy Policy, we will retain personal data in accordance with applicable laws.
In particular, we shall retain your personal data for as long as you access or use our services. However, we may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents.

10. General

If any provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.
This Privacy Policy shall be governed by and construed in accordance with English law and you agree to submit to the exclusive jurisdiction of the English Courts.
 
Last updated: October 2021
 
Anti-Money Laundering (AML) Policy
Apollo Art Auctions Ltd

1. Purpose

This Anti-Money Laundering (AML) Policy outlines the procedures and controls in place at
Apollo Art Auctions Ltd to prevent the auction house from being used for money laundering
or terrorist financing. It ensures compliance with the UK's Money Laundering, Terrorist
Financing, and Transfer of Funds (Information on the Payer) Regulations 2017, as amended,
and other applicable legislation.

2. Scope

This policy applies to all employees, contractors, and third-party agents involved in the
auction house’s operations. It covers the identification, verification, and monitoring of clients,
as well as the reporting of suspicious activities.

3. Key Principles

3.1. Risk-Based Approach
We adopt a risk-based approach to identify, assess, and mitigate money laundering risks,
focusing on higher-risk transactions and clients.

3.2. Customer Due Diligence (CDD)
 
Identification and Verification:

• For all buyers and sellers, we collect and verify identification documents, such

• as a valid passport, driving license, or national ID.

• For entities, we verify the corporate structure, beneficial ownership, and registration details.

• ​Enhanced Due Diligence (EDD):

• Applied to high-value transactions (£8,000 or more), high-risk individuals (e.g., politically exposed persons), and clients from high-risk jurisdictions.

• Additional information, such as the source of funds and purpose of the
  transaction, may be requested. 
   

3.3. Ongoing Monitoring

Transactions and relationships are continuously monitored to identify inconsistencies with the
client's profile or suspicious activities.

3.4. Record-Keeping

All identification, transaction records, and communications are securely stored for a
minimum of five years, as required by law.

4. Suspicious Activity Reporting (SAR)

4.1. Identifying Suspicious Activity

Suspicious activity includes, but is not limited to:
 

• Unusual payment methods or amounts inconsistent with the client's profile.

• Attempts to bypass identification procedures.

• Transactions involving high-risk jurisdictions or politically exposed persons.
   

4.2. Reporting Obligations
 

• Any suspicion of money laundering or terrorist financing must be reported to the Money Laundering Reporting Officer (MLRO) immediately.

• The MLRO will review the information and, if necessary, submit a Suspicious Activity Report (SAR) to the UK’s National Crime Agency (NCA).
   

4.3. Confidentiality

The reporting of suspicious activities is conducted confidentially. Staff must not inform the
client or any third party that a SAR has been filed (tipping off is a criminal offence).

5. Roles and Responsibilities

5.1. Money Laundering Reporting Officer (MLRO)

The MLRO is responsible for:
 

• Overseeing AML compliance.

• Conducting risk assessments and internal audits.

• Reviewing and submitting SARs to the NCA.

• Providing training and guidance to staff on AML policies.
   

5.2. Employees

All employees must:
 

• Familiarise themselves with this AML Policy.

• Conduct due diligence and report any suspicions to the MLRO.

• Complete mandatory AML training sessions.
   

6. Training

Regular training is provided to ensure that all staff:
 

• Understand their obligations under AML regulations.

• Can identify and report suspicious activities.

• Stay updated on emerging risks and changes in legislation.
   

7. Non-Compliance

Failure to comply with this policy or relevant legislation may result in disciplinary action,
termination of employment, or legal consequences, including fines and imprisonment.

8. Policy Review

This policy will be reviewed annually or sooner if required by changes in legislation or the risk
environment.

 
Last updated: 2024
‍