- Responsible for Data Processing
The entity responsible for processing the provided personal data is Império Numis.
Nevertheless, Império Numis may, within the scope of its activities, engage partners to pursue the purposes of data collection outlined below. In such cases, Império Numis ensures that such partners provide sufficient guarantees for the implementation of technical and organizational measures and safeguard the rights of data subjects.
- Personal Data Collected and Processed
In accordance with applicable regulations, any information of any nature and regardless of its medium, including sound and image, relating to an identified or identifiable individual constitutes personal data. An individual is considered identifiable if they can be identified directly or indirectly, particularly by reference to an identification number or one or more specific elements of their physical, physiological, mental, economic, cultural, or social identity.
The personal information collected by Império Numis may include your name, email address, phone number, fax, address, date of birth, citizen card or other identification document, taxpayer number, and banking and/or other data.
Some collected personal data are mandatory, and in case of absence or insufficiency of such data, Império Numis may not be able to provide the requested services or information. In each specific case, Império Numis will inform you of the mandatory or optional nature of providing the relevant personal data.
Império Numis assumes that the data has been provided by the data subject or that the data subject has authorized the provision, and presumes that the information is true and up-to-date, unless indicated otherwise by the data subject.
- General Rules Applicable to Collection and Processing
Império Numis undertakes to process personal data lawfully, respecting the principle of good faith and absolute confidentiality.
Personal data are only collected for specific, explicit, and legitimate purposes and are never processed in a manner incompatible with these purposes. Império Numis ensures that the collected personal data are appropriate, relevant, and not excessive in relation to the purposes for which they are collected and processed.
- Methods of Collection and Processing of Personal Data
Personal data are collected electronically or on paper and processed in the following situations:
- In the context of entering into, or potentially entering into (contractual proposals), contracts with Império Numis, especially for the provision of appraisal services or auctioning of goods.
- During the auctions organized by Império Numis, when the data subject registers for participation, submits purchase orders, or places telephone bids or makes on-site purchases.
- Through the completion and submission of a Consent Form by the data subject.
The collected data are processed electronically and stored in specific databases created and managed by Império Numis in strict compliance with personal data protection legislation.
- Legitimacy and Purpose of Personal Data Collection
Personal data are collected and processed when processing is legitimately necessary for:
- Fulfillment by Império Numis of contractual and pre-contractual obligations, including assessments of goods, auctioning of goods, and the data subject’s participation in auctions, whether in person or through purchase orders or telephone bidding.
- Fulfillment by Império Numis of legal obligations to which it is subject.
If necessary consent is provided during the collection of personal data or subsequently, the data are also collected and used for marketing purposes, including the mailing of information, invitations, and other commercial actions related to auctions organized and other services provided by Império Numis. In this context, segmentations and/or profiles may also be created for the same promotional/advertising purpose.
Additionally, and within the limits of personal data protection legislation, personal data may be collected and processed when processing is legitimately necessary for:
- Protection of the vital interests of the data subject, if the data subject is physically or legally incapable of giving consent.
- Pursuit of legitimate interests of the data controller or third party to whom the data are communicated, provided that the interests or rights, freedoms, and guarantees of the data subject do not prevail.
- Sharing of Personal Data
Império Numis may share personal data with official entities based on legal requirements. It may also share personal data with partners and service providers of Império Numis for the purpose of providing the mentioned services, always respecting the duty of confidentiality and the principle of the purpose that guided the collection.
If data transfers to third countries that do not belong to the European Union or the European Economic Area occur, Império Numis will comply with the law, especially regarding the adequacy of the destination country concerning the protection of personal data and the requirements applicable to these transfers. Under no circumstances will personal data be transferred to jurisdictions that do not offer adequate security and protection guarantees.
- Retention Period of Personal Data
The period during which data are stored and retained varies according to the purpose for which they were collected. If there is no specific legal requirement, data will be stored and retained only for the minimum period necessary for the purposes that prompted their collection and subsequent processing.
For marketing purposes, the personal data collected will be retained for a maximum period of 5 (five) years from the date of consent collection or the last contact made (whichever occurs later), without prejudice to the fact that consent can be withdrawn at any time.
Once the maximum retention period is reached, personal data will be securely destroyed.
- Security Measures
Império Numis is committed to ensuring the protection and security of the collected and processed personal data. For this purpose, it adopts various security measures, both technical and organizational, to protect personal data against dissemination, loss, misuse, alteration, unauthorized access, or any other form of unlawful processing.
These measures include, among others:
- Limited personal access to personal data based on the criterion of “need to know” and only within the scope of the communicated purposes.
- Encrypted transfer of collected data.
- Encrypted storage of highly confidential data (e.g., credit card information).
- Protection of information technology systems through a firewall to minimize the risk of unauthorized access.
- Monitoring of access to information technology systems to prevent and detect the misuse of personal data.
Império Numis requires its partners to adopt security measures, both technical and organizational, equivalent to those it practices.
- Rights of the Data Subject
Império Numis guarantees the data subject, at all times, all rights arising from personal data protection legislation, including the rights of access, updating, rectification, erasure, restriction of processing, or elimination of personal data, and, when applicable, the right to data portability.
Império Numis grants the data subject, in particular, the right to revoke, withdraw, narrow the scope, or limit the extent of any previously given consent, especially regarding the use of data for marketing purposes.
The exercise of these rights should be carried out through the email address [email protected] or by sending a registered letter with acknowledgment of receipt to the headquarters of Império Numis.
- Changes to the Privacy Policy
Império Numis reserves the right to change this Privacy Policy at any time. In the event that such changes are materially relevant, to the extent that it is reasonably presumed that the conditions on which your consent was based are compromised, Império Numis commits to requesting it again.