Privacy Policy

Showkeen.in is a property of AstaGuru Auction House Private Limited, Hargovindas Building, 2nd Floor, K. Dubash Marg, Kala Ghoda, Fort, Mumbai – 400 001.

Like most businesses, AstaGuru holds and processes a range of information about its clients, customers, sellers, vendors, and other persons who may be interested in AstaGuru’s services.

This Privacy Policy applies to AstaGuru globally and explains the type of information that we process, why we are processing it and how that processing may affect you.  

The Privacy Policy is split into the sections listed below.  The Glossary section explains what we mean by “personal data,” “processing,” and other terms used in this notice.

We may update this Privacy Policy from time to time and will post any revised notice on this webpage.  Where appropriate, we may notify you by email or by a notice on our website that our privacy notice has changed, but we recommend that you check this page regularly.  Any changes will be immediately effective on posting. 

Who we are

AstaGuru Auction House Private Limited (“AstaGuru” or “Company”) is a Company registered under the Companies Act, 2013 in India.

When you buy and sell in our auctions or by private sale or purchase other services or goods from us, or when you take part in one of our events or attend a course or lecture in person, the controller of your data will be the Company. 

How and when do we collect your personal data?

Collection directly from you in response to our request
Personal information is information, or a combination of pieces of information, that could reasonably allow you to be identified. As described in more detail below, we collect personal information about you from a variety of sources, including information we collect from you directly, information we collect about you from other sources, and information we collect automatically from you.
We collect information that you submit to us or provide to us on forms available on third party websites. The types of information that we collect directly from you include: personal details (e.g., name, date of birth, alias and/or avatar alias), contact details (e.g., phone number, email address, postal address), transaction information (e.g., bidding or purchase records, shipping details, information about items you purchase or wish to consign), details about your collection, limited financial information (e.g., tokenized payment information in connection with your purchases, wire instructions, digital wallet details and address), username and password, user ID, unique device ID, information on forms required for certain transactions (e.g PAN, AADHAAR number, etc.), and identification information (e.g. photo ID).

We rely on the information you provide to us or that we collect or observe about your individual interactions with us, for example, if you attend a live event, agree to sell or consign property, participate in one of our auctions, become a client, register or bid online.

We may make video recordings of our auctions, gallery spaces, and certain live events. We record calls made to our customer care line for quality assurance, compliance purposes, and recordkeeping purposes.
We may use common data collection technologies as you visit our websites or apps or interact with our emails. For example:

Most of the personal information/data we process about you comes directly from you (whether face to face, over the telephone, on a paper form, by email or online), for example:

Automatic collection of data may take place when you telephone bid, call Client Relations, visit our premises or our website or attend any event conducted, hosted and/or sponsored by AstaGuru.

Your voice will be recorded when you call our Client Relations team, and when you use our telephone bidding service.
Your image may be collected by AstaGuru if you attend our premises. We use CCTV at our premises and offices for the protection of our staff, our visitors and the property that we sell. We video our auctions for security reasons and to monitor bidding practices. Cameras and microphones recording images and sound for any events focus primarily on the auctioneer/presenters and AstaGuru specialists, but background sound and images may also be captured. Attendees should inform AstaGuru in advance if they do not wish to be filmed/recorded. However, the only remedy available in certain situations, if you do not wish to be filmed/recorded would be to remain absent from that particular event.

Our digital events generally display and record only the presenters’ images and audio. Exceptions include discussions such as round tables, certain panels and seminars. Please contact the event organiser if you have questions about the filming/recording of a particular event or course.

As you interact with our Digital Platforms, we collect data through cookies and other similar technologies together with technical data about your equipment, browsing actions and patterns.  We may also receive technical data about you if you visit other websites employing our cookies. More detail is available below and in our Cookies Policy. You can change your cookies settings at any time by visiting the Cookies Settings page on our website (Cookies Settings).

Collection of data from other sources

We may collect information about you from external sources, including social media sites and data supplementation services. The types of information we collect about you from other sources include your public profile information, family relationships, and organizational affiliations. We may work to expand our customer base by acquiring names, contact data, financial information, affiliations, and demographic information from other sources such as private companies, public registers, and social media sites, where permitted by law. We may also generate information such as appraisals, profiles, and a history of our relationships with you based on the information you have provided or that we have obtained from other sources, as permitted under applicable law.


We may obtain information about you and/or the property you own or wish to collect from other sources, for example:

Aggregated and special categories of data

We may collect, use and share aggregated data, such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect special categories of personal data unless it is necessary for us to do so to enable us to provide services or access.

What personal data do we process and why?

We have set out below the types of personal data that we process, the purposes for which we use it and the legal grounds on which we process it.  The Glossary contains more information about the legal grounds for processing.


Purpose
To provide you with requested services
(for example, bidding, selling, valuations, storage, shipping, loans and loan referral, catalogue subscription, restoration, expertise)


Examples of personal data
(Please note that the list is not exhaustive)


Legal grounds for processing
Performance of a contract


Marketing
We aim to provide you with choices around marketing and advertising.  You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving such marketing.  We do not transfer your personal data to organisations who wish to use it for their own marketing promotions or other purposes. AstaGuru shall use the non-identifiable, non-personal data with such agencies and organizations in order to analyse, offer and improve its services and for general marketing and advertising purposes.
You can ask us to stop sending you marketing messages at any time by following the unsubscribe links on any marketing message sent to you or by contacting us at any time at [email protected]. 

Who gets to see your personal data?

Your personal data will be processed by the AstaGuru entity that initially receives it and may also be transferred to and processed by other companies within AstaGuru.  

Outside AstaGuru
We do not transfer your personal data to organisations who wish to use it for their own marketing promotions or other purposes.  Your personal data will only be shared with other organisations where it is necessary to enable us to provide you with the services you have requested (for example: we may transfer your data to our bank, payment card acquirers, shippers, warehouses, insurers, experts who help us authenticate or value property, companies that perform identification, anti-fraud and credit checks or screening for sanctions, anti-money laundering and/or negative media purposes, event venues, caterers, catalogue and direct marketing fulfilment and distribution).  Where we do so it will be on the basis that these organisations are required to keep the information confidential and secure, and they will only use the information to carry out the instructed services.

Some of these organisations may be located in a different country to the one where your personal data was collected.


We may need to retain and disclose certain information about you to appropriate agencies to conduct anti-money laundering and trade sanction checks, to assist with fraud and crime prevention and detection and to meet our health and safety obligations. We may also need to disclose this information to our banks, insurers or auditors for the purposes of evidencing AstaGuru’s compliance with anti-money laundering, sanctions and other relevant regulations, or to enable the bank, insurer or other regulated firm to complete its own due diligence in connection with you or your transactions.
If law enforcement or other entities, bodies or persons request disclosure of your personal data (such as your contact details or information about purchases), we will only disclose data if we are satisfied after internal review that we are legally required to do so or that disclosure is necessary to protect our rights or the rights of others and is not prohibited by law.

Is your personal data transferred internationally?

As an organisation that conducts transactions with entities globally, AstaGuru may in the normal course of its business transfer your personal data internationally to any entities who may need to process your data in connection with the services that AstaGuru provides to you. AstaGuru uses Amazon Web Services (AWS) for its servers, and the location of the servers is dependent on AWS.

How long will we keep your personal data?

We will retain your personal data for as long as is necessary to provide the relevant services, maintain business records to satisfy tax, legal and other regulatory requirements, and protect and defend against potential legal claims.

In the context of our research and records on ownership of art objects to assist with checks on authenticity, provenance and title, we will keep this data for as long as the record is relevant to our legitimate business interests and the public interest. Please be aware that we do not remove or amend property titles or provenance information once published. AstaGuru’s catalogues and lot pages are important resources for public research, market transparency and, where relevant, supporting object value and, as such, we consider that it is in the interests of sellers and buyers and the public more generally for the published provenance of a property to remain available online to the public indefinitely. We take this approach unless required otherwise by applicable law.

How do we keep your personal data secure? 

We understand that your personal information is important, and we are committed to treating it with the utmost care and security.

We have multiple layers of security technologies and controls in our environment which safeguard your data, while at rest or in transit, from unauthorised access or disclosure. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. In addition, our colleagues receive data protection training, and we have in place detailed security and data protection policies which colleagues are required to follow when handling personal information. 
In an ever-altering threat landscape, we are constantly assessing our security defences to ensure your data continues to stay protected. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Third party websites

You may ask us if you have questions about the data we hold on you. Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include:

The right of access: Youmay request a copy of the personal data that we hold about you (a “subject access request”).  If you exercise this right and we process personal data about you by automated means or as part of a filing system, once we have verified your identity and, if relevant, the authority of any third-party requestor, we are required to provide you with a description and copy of that personal data and tell you why we are processing it.

Other rights
As well as your subject access right, you may have a legal right to have some or all of your personal data rectified or erased, to object to its processing, or have its processing restricted.

If you have provided us with data about yourself and the ground for processing is Contract or Consent, you may have the right to be given the data in machine readable format for transmitting to another data controller.
If we are relying on Consent as the grounds for processing your data, you may withdraw consent at any time. This will not affect the lawfulness of AstaGuru’s processing of your data prior to your withdrawal.

Please contact us at [email protected] if you would like to exercise any of your rights explained above in relation to your personal data.

Contact Information

If you have any queries in relation to AstaGuru’s processing of your personal data please contact us at [email protected].

Complaints

You have the right to make a complaint at any time to the applicable data privacy regulator. We would, however, appreciate the chance to deal with your concerns before you do so.

Glossary

Compliance with a legal obligation – processing is necessary to ensure we comply with our legal and regulatory obligations.

Consent – you have given specific consent to the processing of your personal data.

Data Controller – the person who determines the purposes and means of processing personal data.

Filing System – a structured set of personal data that is accessible according to specific criteria.

Legitimate Interests – processing is necessary for our or a third party’s legitimate interests in carrying on, managing and administering our respective businesses effectively and properly (except where our or the third party’s interests are overridden by your own interests, rights and freedoms).

Performance of a contract – processing is necessary to carry out our contractual duties, exercise our contractual rights or otherwise perform our contract with you, or to take steps at your request to enter a contract.

Personal Data – any data relating to an identified or identifiable natural person.  This can include names, user ID, location data, email addresses, photographs, job applications, purchase history, user account information, opinions, and correspondence to and from an individual.

Processing – any operation performed on personal data, such as collection, recording, storage, retrieval, use, combining it with other data, transmission, disclosure or deletion.

Public Interest – processing is necessary for the performance of a task carried out in the public interest.

Special category data – details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health and genetic and biometric data.