Hackstons Limited, registered in England and Wales under company number 13522744, with registered offices at 3–4 William Street, London, SW1X 9HL, operates as the data controller for your personal information. This policy details how our auction platform collects, utilises, protects, and discloses your data when you engage our services.
We operate under strict registration with the Information Commissioner’s Office (ICO) and are committed to safeguarding your privacy in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
01 The Dual Nature of Our Platform
Our platform facilitates transactions across two distinct asset categories, each governed by specific operational and regulatory requirements:
- Consumable Assets (Bottles)
- Personally acquired wine and spirits destined for private collections or consumption.
- Liquid Investments (Casks)
- Casks held in HMRC bonded storage as long term investments, which require specialised digital title transfers and distinct regulatory compliance.
By accessing our services, creating a bidding account, or consigning lots, you acknowledge the data practices detailed within this policy.
02 Information We Collect and Retain
To provide a secure and functioning auction environment, we collect several distinct tiers of information.
Account and Profile Credentials
To participate in an auction, you must establish an official account. We collect your name, chosen username or pseudonym, secure password, contact number, and physical residential address. While your public bidding identity may display a pseudonym, your true identity remains confidential within our secure registry.
Verification and Compliance Data
Due to the statutory nature of high value asset trading and alcohol legislation, we require confirmation of your date of birth. We do not intentionally collect data from, or market to, individuals below the legal drinking age. If we suspect an account is in breach of these age restrictions, we reserve the right to request official photographic identification to verify your credentials.
Financial and Transactional Records
When you secure a lot or register your bidding credentials, we collect payment card details and billing information. This data is handled through secure, verified payment gateways to process hammer prices, buyer premiums, and delivery allocations.
Log and Device Analytics
When you browse our collections or place live bids, our system automatically notes technical details. This includes your IP address, browser type, operating system, geographical region, and interaction history across our lots. This information ensures platform stability, auction synchronization, and security tracking.
03 How Your Information Is Acquired
We obtain your personal information through two primary pathways:
- Direct Submission
- Provided voluntarily when you establish your account, input consignment notes, submit enquiries via email, or subscribe to our curated market updates.
- Verified Third Parties
- Gathered from secure data processors acting explicitly on our behalf, including identity verification services, credit reference bureaus where appropriate for high value cask transactions, and integrated secure payment processors.
04 Utilisation of Personal Data
We process your data strictly under recognised legal frameworks, primarily to fulfil contractual obligations, comply with statutory laws, or support legitimate business interests that do not override your personal rights.
Your information allows our concierge and operations teams to:
- Authenticate your bidding profile and manage live auction increments securely.
- Administer contracts, settle hammer prices, and manage successful acquisitions.
- Coordinate the physical fulfilment of bottle deliveries or execute the digital transfer of cask ownership within Scottish bonded warehouses.
- Address enquiries, provide dedicated customer support, and conduct post transaction market research.
- Detect, investigate, and prevent fraudulent activity, unverified bidding patterns, or breaches of our standard terms of use.
05 Selective Disclosure of Information
We do not sell, rent, or distribute your personal details to external marketing agencies. Disclosure occurs exclusively with verified partners vital to our operations, including:
- Logistics Partners
- Shared with specialised courier services and premium fulfilment houses to ensure the safe transit of physical bottles.
- Warehouse Managers
- Shared with specific HMRC registered excise warehouses in Scotland to finalise the digital transfer of title for cask investments.
- Professional Advisers
- Disclosed to IT infrastructure providers, secure cloud hosts, payment processors, and specialist legal or financial consultants.
- Statutory Authorities
- When legally required, disclosed to government departments, law enforcement, or regulatory bodies such as HMRC when we are legally compelled to do so to prevent revenue fraud or comply with UK law.
- Sale or Merger
- We may share your personal information in the event of a merger, acquisition, or sale of all or a portion of our assets. We will inform you of any transfer via email and/or a prominent notice on our site and inform you of your rights.
06 Secure Storage and Data Lifespans
Your information is retained within secure, restricted access architectures protected by digital authentication frameworks. Access is granted strictly to personnel whose operational duties require it.
In alignment with UK tax laws and asset management guidelines, we maintain data for the following specific durations:
| Information Type | Purpose of Retention | Retention Duration |
|---|---|---|
| Name, email address, and communication preferences | Curated updates and digital distribution lists | 6 months from inactive status, or until you choose to unsubscribe |
| Transaction records, name, and physical address | Purchase and delivery of physical bottle lots | 6 years following the transaction, in accordance with UK tax laws |
| Cask ownership titles, contract deeds, and identity data | Contractual fulfilment and statutory recording of bonded cask investments | 6 years following the formal termination or subsequent sale of the cask asset |
07 Your Statutory Rights
Under UK data protection laws, you possess comprehensive rights regarding your personal information. You may exercise these at any interval without incurring an application fee.
- Right of Access
- You may request copies of all personal data held within our systems.
- Right to Rectification
- You may request the immediate correction of inaccurate or incomplete details.
- Right to Erasure
- You may request the deletion of your personal data, subject to instances where Hackstons is legally obligated to retain records for tax or revenue compliance.
- Right to Object or Restrict
- You may object to data processing under legitimate interests, or restrict how we interact with your information.
- Right to Withdraw Consent
- Where processing relies on your explicit consent, you may withdraw this permission instantly via your account dashboard or by utilising the link at the base of our communications.
Should you wish to submit a formal request regarding your data rights, please allow up to one calendar month for our privacy team to complete the verification and response protocol.
08 Communications and Direct Outreach
We occasionally issue communications regarding upcoming auctions, exclusive consignments, and market insights. If you prefer to discontinue these updates, you may opt out instantly via your profile settings or by selecting the unsubscribe link included within our correspondence. We process all opt out preferences within two working days of receipt.
09 Contact and Supervisory Reassurance
Should you have questions regarding this privacy framework, or if you wish to file an enquiry regarding your data, please contact our privacy officer directly.
By post
Data Privacy Officer
Hackstons Limited
3–4 William Street
London, SW1X 9HL
By email
If you remain unsatisfied with our resolution, you retain the statutory right to raise your concern with the national supervisory authority:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline:
0303 123 1113
Website:
ico.org.uk