Who is responsible for your data processing?
HeilisimR22R, registered in the Dutch Chamber of Commerce under number 63321645 (hereinafter referred to as ‘R22R’)
Every reference in this Privacy and Cookies Policy (“Policy”) to “we”, “us”, or “our” shall be regarded as referring to R22R.
Data protection officer:
For R22R the DPO is Ewout van Linge.
The purpose of this Privacy Statement and Cookies Policy
This Privacy Statement and Cookies Policy describes how R22R use the personal information collected from her services, your visit to R22R websites, online applications and mobile platforms. Because R22R is committed to ensuring the privacy and safety of your personal data.
All personal data collected via the website or any other applications and mobile platforms (“Platform”) shall be processed in accordance with the applicable legislation on data protection, more specifically the EU Directive 2016/679, known as General Data Protection Regulations as well as any other future legislation and its national supplementing legislation.
This Privacy Statement and Cookies Policy is valid from May 25, 2018. All future changes to our data protection guidelines will be published on this website. You should therefore check the data protection statement regularly for changes.
Purpose of processing personal data
We will handle your personal data carefully and take measures to protect it. In line with legal requirements, please be informed that R22R will process and use your (personal) data for the following purposes:
- For the performance of agreements;
- Because of an legitimate interest of R22R;
- To fulfil legal obligations
In all other cases R22R will ask your consent.
- to store your (personal) registration data in a database in order to facilitate your (future) participation in services by R22R;
- to perform audits and security checks in connection with the R22R website;
- to inform you of functional changes to the R22R website and provide you with important information concerning participation in R22R services;
- to ask your feedback on a new website page to optimize the website;
- in case you accept our cookies: to measure your experience anonymously in order to optimize the website;
- in case of technical problems to solve these;
- to manage accounts of customers in the central database;
- to handle questions or complaints of customers and potential customers;
- to invoice you;
- to do our administration and fulfil tax obligations;
to meet legal obligations, comply with judicial rulings and/or implement measures required in connection with a judicial proceeding;
What personal data is collected by us?
As part of the account creation process, R22R only collects personal data that is required in order to provide services to you and to perform the agreement with you.
For the creation of an account:
- Name of the account creator
- Contact persons/representative agencies (if applicable)
- Email addresses and telephone numbers
For management of the website and content management:
- Technical and pseudonmised data
- Anonymous data which cannot be traced back to a person for reporting purposes
Legal Ground for data processing
The legal ground for our processing activities is twofold:
- the execution of the agreement we made with you
- our legitimate interest as a professional auctioneer to communicate with our customers and to manage our platform to enable you to participate;
R22R will not collect or store special categories of personal data, such as data revealing political opinions, religious beliefs or data concerning health as defined in article 9 GDPR.
Protection of personal data
R22R ensures the effective protection of data by using encrypted communication and secure links in line with the state of the art where necessary. BVA has also taken measures to ensure the security of both physical and virtual access to data on its premises and its computer systems.
We will furthermore implement the necessary administrative, technical and organisational measures in order to ensure a level of security that is appropriate for the specific risks that we have identified.
Retention of stored data
Your personal data will only be processed for the required duration and will then be deleted once it is no longer required, taking into account legal data retention obligations. R22R has a process for the secure retention of the documentation in question.
Exchange of data
R22R works with third parties to provide services to you and will only pass on information to third parties falling within the following scope:
- Associated companies: associated companies if these companies offer comparable data protection and the transfer of data is permitted.
- Service providers: we commission other companies and individuals to carry out work on our behalf. Examples of service providers include companies offering shipping services or payment processing (credit card, direct debit and purchase on account).
If R22R uses the services of third parties, it concludes data processing agreements with these parties, from which no independent obligation arises for these parties concerning processing personal data. These service providers have access to personal information that is necessary in order for them to complete their work. However, they are not permitted to use this data for other purposes.
In all other cases you will be informed if your personal information is to be sent to third parties and will be given the opportunity to consent to this separately.
For every disclosure we will ensure that the necessary contractual safeguards for the protection of your personal data are set in place.
In every case where personal information is passed on within the aforementioned scope to third parties in countries outside of the European Economic Community (EEC), we guarantee that the data is transferred in accordance with this Privacy Statement and with applicable data protection laws.
In principle all data will be processed within the EU where possible and will not be exchanged with third parties outside of the EU. Data may only be exchanged with a non-EU country on the part of R22R if the recipient can ensure the same level of data protection, either based on the laws in force in said country or through separate agreements as prescribed by the EU in the EU binding agreement format.
Your rights concerning your data
You have the following legal rights (provided that you request us hereto in writing and provide us with a copy of your ID card to evidence that we are dealing with you):
- Right to information and right to access your personal data. You may at any time request more information on our processing activities and the personal data that we are keeping from you.
- Right to rectification of inaccurate or incomplete personal data. You have the right to obtain from us, without undue delay, the rectification or completion of any inaccurate or incomplete personal data.
- Right to data portability. In some cases, you have the right to receive all our personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. This right applies in case the processing is based on consent or on the necessity for the performance of a contract and in case the processing is carried out by automated means.
- Right to restrict processing of personal data. You may request us to restrict the processing of your personal data when:
- you have contested the accuracy of your personal data, for a period enabling us to verify this accuracy;
- we no longer need the personal data for the purposes of processing, but you need them for the establishment, exercise or defence of legal claims;
- the processing appears to be unlawful and you requested us the restriction of the use of your data;
- we are in the process of verification whether our legitimate interests override yours in the framework of an objection against the processing of your data.
- Right to deletion of your personal data (right to be forgotten). You may request to delete (part of) your personal data in the following situations:
- when the processing is no longer necessary for archiving purposes for which they were collected or otherwise processed;
- when the processing is no longer necessary to execute our agreement with you or when it is no longer legally required;
- when processing was based on consent and you have decided to withdraw your consent;
- when your date have been unlawfully processed;
- when you have reasonable grounds to object to the processing of your personal data;
- when your personal data have to be erased in compliance with a legal obligation.
In exceptional cases we may refuse to delete your data for compliance with a legal obligations or for the establishment, exercise or defence of claims or for any legitimate interest.
- Right to object to the processing of your personal data without any charge. You may object to the processing of your personal data, when such processing is based on our “legitimate interests”. In that case we will no longer process your data, unless we have compelling legitimate grounds to do so or because we are required to do so because of a legal obligation. Where (part of) your personal data are processed for direct marketing purposes, you may at any time object to the processing of your data or withdraw your consent thereto. You also have the right not to be subject to profiling for direct marketing purposes.
- Right to complain. In case you have a complaint about our data processing you can contact us by writing our DPO, see for contact details paragraph 1. You also have the right to send your complaint to the local Data Protection Authority. Where R22R is the responsible controller, the responsible Data Protection Authority is the Data Protection Authority of the Netherlands, Autoriteit Persoonsgegevens.
It is important to note that email and marketing campaigns do not result from cookies. Neither your email address nor your telephone number is stored in cookies and cookies are not used to create traceable personal profiles.
You have the option of accepting or disabling all cookies from any visited websites by changing your Internet browser settings. Please note that certain functions on this website will not be available if you disable cookies. If you are not sure how to change your browser settings or delete cookies, please consult the instructions provided by your browser.
On our website we use the following cookies:
Through our website a cookie is placed from the American company Google, as part of the “Analytics” service. We use this service to track and get reports on how visitors use the website. Google may provide this information to third parties if Google is legally obliged to do so, or if third parties process the information on behalf of Google. We have no influence on this. We have not allowed Google to use the obtained analytics information for other Google services.
The information that Google collects is anonymized as much as possible. Your IP address is emphatically not given. The information is transferred to and stored by Google on servers in the United States. Google maintains the Privacy Shield principles and is affiliated with the Privacy Shield program of the US Department of Commerce. This means that there is an appropriate level of protection for the processing of any personal data.
On our website buttons are included to promote web pages (“like”) or share on social networks like Facebook. These buttons work through pieces of code that come from Facebook itself. Cookies are placed through this code. We have no influence on that. Read the privacy statement of Facebook (which can change regularly) to read what they do with your (personal) data that they process via these cookies.
The information they collect is anonymized as much as possible. The information is transferred to and through Twitter, and LinkedIn is stored on servers in the United States. LinkedIn, Twitter, and adhere to the Privacy Shield principles and are affiliated with the Privacy Shield program of the US Department of Commerce. This means that there is an appropriate level of protection for the processing of any personal data.
Web browser settings
If you do not want websites to store cookies on your computer, you can change your web browser settings so that a warning appears before cookies are stored. You can also change the settings so that the web browser blocks all cookies or only those from third-party providers. In your web browser settings you can also delete cookies that have already been stored. Please note that these settings must be defined separately on every web browser and computer you use. Please also note that R22R cannot guarantee that its website will function as intended if cookies are blocked. You may find that some website functions are lost or that you can no longer access the website. The steps to change the settings are different for each web browser. Access the help function of your web browser, if necessary, or click on one of the links below to go directly to the instructions for your particular web browser.
You can block cookies from certain providers on the following website:
The R22R website may contain hyperlinks to other websites and to websites of business partners which are not part of BVA. BVA does not accept any responsibility for the data protection practices and content of these websites.
R22R reserves the right to make changes to this Privacy Statement and Cookies Policy from time to time. Please check this each time you visit the website in order to stay up to date.
If you still have questions this Privacy Statement and Cookies Policy, the R22R website or your registration details, or if you wish to amend these details, please contact: