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Updated 21 May 2018 Privacy Policy and Compliance Introduction Classical Numismatic Group, LLC (CNG) holds a wide range of information about its customers and other persons who may be interested in CNG’s services. This Privacy Policy and Compliance notice applies to CNG’s operations world-wide and explains the type of personal data we process and how this processing may affect you. Under our guidelines, personal data is to be:
• Kept up to date and accurate. • Used lawfully. • Kept only as long as necessary. • Maintained securely. • Provided, where required by law, for your review and your right “to be forgotten”. CNG is a United States limited company in the state of Pennsylvania and has a registered branch office in London, United Kingdom. Personal information held by CNG is shared and used by both offices in the conduct of business. On occasion we may update this notice and will post any revisions on this web page. All policies listed in this notice are in affect as of 25 May 2018. Data Collection Personal Data You Provide Most of the personal data we process and retain about you has been supplied to CNG by you (face to face, over the telephone, in writing, by email or online). Some examples:
• public auction viewing. • attendance at a trade show where you provided us with your details. • response to a published advertisement or publication.
• To carry out our contract (if applicable) with you • To allow us to comply with any legal requirements • For our legitimate interests in dealing with any enquiry or complaint. • For the purposes of maintaining you account. Automatic Data Collection Website traffic is collected for analysis, which includes your internet address, your operating system and browser type. This information is used for internal systems administration and to monitor bidding activities. It is also used to help diagnose problems with our servers, administer our web site and monitor and improve the user experience. In addition data is collected from:
We use session only cookies when you submit bids or place orders through our web site. These cookies expire once you close out your session. We do not track your movements around the web with cookies. Collection of Data from Other Sources We may also obtain information about you from other referring sources. For example:
• Your registration for live bidding at our public auctions which is handled by an external provider (the-saleroom.com). • Your registration and ordering on VCoins (vcoins.com). • Your clicking on various advertising banners and links that refer you to CNG’s website. • Your response to printed advertisements or publications. We use basic contact information to promote the company and the products we buy, sell or auction through email, printed mailings, telephone contact, and social media. We respect your right to not receive our information, and electronic mailings can be unsubscribed to at any time. Printed information can de discontinued by contacting CNG by mail, phone or email. Data Processing and Retention The following is a list of items we collect and retain from you for the legal performance of a contract that we undertake in providing our services.
• Your bank account details for payments. • Card details and bank transfer information. • Purchase orders for items purchased from you. • Invoices of items sold to you. • Contracts you have entered into with us for selling or consigning material. • Records of your communications and instructions to and from us.
• Details of past transactions (including any tax paid or withheld) and or shipments including any permits obtained or fees paid). • Any information relating to a dispute or legal proceeding. Data Privacy Retention of Data by CNG All electronic data is stored on secure severs.
• On secure servers provided by Amazon Web Services. • On secure servers provided by our web hosting company. • On secure servers provided by our information back up provider. Access to Data at CNG Information is used internally by CNG to conduct business and provide services to our customers. Information is not sold or transmitted outside of CNG with the following exceptions:
• Information provided to credit card processors for payments. • Information provided to transport agencies for delivery or collection of property. • Information provided to our insurers, attorneys, accountants, and other professional service providers. • Credit information provided to business colleagues regarding credit worthiness with CNG. We may need to provide your data to certain government agencies who conduct investigations regarding money laundering, fraud, crime prevention and trade restrictions. No government entity has direct access to your information. We will only provide information that has been directly requested by appropriate legal means and which has been reviewed and approved for release by our legal representatives. Length of Data Retention by CNG We will retain information for as long as is needed to provide our services and maintain business records to satisfy all tax, legal and regulatory requirements. We will retain all information needed for potential legal claims. Security of Data at CNG We take all reasonable steps to secure your information provided by means outlined above. We employ a variety of security measures and internal rules to protect your personal information from unauthorized physical and electronic access. We have put in place procedures to deal with any suspected data security breach. We will notify you in a timely matter if we suspect a breach. As effective as modern security practices are, we cannot guarantee that all information provided is safe from unauthorized access or manipulation. The transmission of any information is at your own risk. We will not be liable for any resulting misuse of your data. Access to Data at CNG We are open and transparent about the information we strive to compile about you. If you have questions about the data we hold about you, please request this information. Data protection laws give you a number or rights when it comes to personal information we hold about you. European Economic Area Residents European Economic Area (EEA) residents have a legal right to make a “data subject access request”. If you exercise this right (subject to verification of your identity) to find what personal data we hold, we will provide it to you within the time frame required by law in an electronic format. If you have provided us with data you have the legal right to request that we stop collecting data going forward and that your contact information be withdrawn from any future solicitations. You are welcome to review, clarify, correct or request erasure of your personal information, object to the processing of your information, withdraw your consent to the processing of your personal information or request that we transfer your personal information to another party, subject to our legitimate needs to maintain data in order to carry out our obligations and preserve our rights.
• No further information will be collected. •Any and all information collected prior to your withdrawal of permission will be removed from our systems, so long as it does not affect the legal rights of CNG to your data to that point. If you wish to stop receiving information from CNG contact us at dataprivacy@cngcoins.com, or by phone or in writing. Classical Numismatic Group, LLC (CNG) PO Box 479 Lancaster, PA 17608 USA +1 717 390 9194 |