Finance & GST

Please download our Fee Adjustment and GST Notices below.

Privacy Policy

• when you visit any of our websites or website pages (including traffic data, web logs or other communications data and the resources you access), whether via a re-direction from a third party website (e.g. https://www.the-saleroom.com/en-gb) or otherwise
• when you use any of our mobile responsive websites or applications
• if you use our Wi-Fi
• if you use any social network/media or other platforms or providers to access or use any of our websites, webpages, applications, products, services, information, content or features
• when you visit our saleroom or other viewing locations
• when you become a member or set up an account, register or sign up with us, fill in any form or subscribe to any of our products, services, information, content or features (including alerts and newsletters)
• when you sell, buy, access or use any of our products, services, information, content or features or you transact with or through us (including payment processing and information from third parties)
• when you request or provide information or feedback, correspond or communicate with us or contact us with a question or for assistance (including monitoring or recording of certain telephone conversations)
• when you otherwise provide us with information about you (including participating in any survey, competition or the like)
• from public sources of information
• from our third party business partners (e.g. https://www.the-saleroom.com/en-gb) in relation to any transactions directed to our websites or website pages from such third parties

• your first and last name, address, telephone number, e-mail address, date of birth, gender, NRIC, FIN or passport number (or other government identifiers), financial information such as bank and credit card details, device ID and IP address
• a copy or image of your government identity document (including your NRIC, FIN or passport), a photograph or face "selfie", and biometric facial data and liveness-detection results generated from them, to identify you or comply with applicable law including relating to the sale of precious stones and metals 
• information about your interactions with us, including monitoring, noting or recording a call, email or letter or other records of any contact between you and us
• your membership, account or subscription information or details including passwords or challenge questions and answers
• information on your access or use of our products, services, information, content, features or premises
• location information of your mobile device (if enabled)
• for website, webpage, application or Wi-Fi access and use, your phone and computer type and operating system, IP address, device ID, browser type and language, geographic location, access times and usage information
• information associated with managing requests, queries and complaints
• marketing and other preferences, likes or interests based on what you specify to us including contact method and preferred products, services, information, content or features
• information from other organisations including identity verification, know your customer, fraud-prevention agencies, business directories, credit reference agencies, our aggregation platform partners or individuals we believe you have authorised to provide your personal details on your behalf
• some information about your physical or mental health or condition, religious or similar beliefs, or commission or allegations of an offence (for example if you attend any of our salerooms)
• information from social network/media or other platforms or providers to access or use any of our websites, webpages, applications, products, services, information, content or features

1. Purpose	Legal basis for processing personal data under GDPR (Please refer to section 5 below)	Legal basis for processing personal data under Singapore PDPA
   your access or use of, or to otherwise provide or administer, our products, services, information, content, features, premises or other business activities (including verifying your identity, know your customer, eligibility, membership or subscription, accepting, rejecting or blocking you if needed, and selling or purchasing property or services)	Legitimate interests Performance of a contract (for membership or subscription and selling or purchasing property or services)	Consent Legitimate interests Contractual necessity
   to enter into or perform any contract with you, including processing of any payments, refunds, deliveries and logistics	Performance of a contract	Consent Contractual necessity
   notifying you about changes to our products, services, information, content, features, premises or other business activities	Legitimate interests (if you have previously requested or received services) Consent (if you have not requested or received services but have signed up to receive Hotlotz’ marketing materials)	Legitimate interests (if you have previously requested or received services) Consent
   responding to enquiries and requests from you or people you have authorised	Performance of a contract	Contractual necessity
   forecasting, planning, record keeping, management and administration	Legitimate interests	Legitimate interests Compliance with a legal obligation
   contact relationship management, managing your membership or account and providing you with customer support	Legitimate interests	Consent Legitimate interests
   benefit, loyalty, promotional and reward programs	Legitimate interests	Consent  Legitimate interests
   market research, business and sales analysis or analytics, feedback and satisfaction surveys to improve our products, services, information, content, features or premises	Legitimate interests	Consent  Legitimate interests
   ensuring that our websites, webpages or applications are presented in the most effective manner for you and your devices	Legitimate interests	Consent  Legitimate interests
   product and service improvement, enhancement, personalisation, design or development	Legitimate interests	Consent  Legitimate interests
   training, learning and development	Legitimate interests	Consent  Legitimate interests
   advising you of forthcoming sales, events, products and services	Legitimate interests (if you have previously requested or received services) Consent (if you have not requested or received services but have signed up to receive Hotlotz’ marketing materials)	Consent  Legitimate interests
   providing updates, offers, promotions, invitations to events and relevant advertising and informing you about products and services	Legitimate interests (if you have previously requested or received services) Consent (if you have not requested or received services but have signed up to receive Hotlotz’ marketing materials)	Consent  Legitimate interests
   ensure the safety and security of our properties and systems and other security and risk management or information	Legitimate interests	Consent  Legitimate interests
   conducting checks against money laundering, terrorism/proliferation financing and related risks	Compliance with a legal obligation	Consent Compliance with a legal obligation Legitimate interests
   preventing and detecting fraud or other crimes or other wrongdoing or recovering debts	Compliance with a legal obligation	Consent Compliance with a legal obligation Legitimate interests
   conducting internal audits or investigations	Legitimate interests	Consent Legitimate interests
   resolving any disputes or in relation to any transaction, demand, order, request, right, enforcement, property or safety issue, claim, proceeding, insurance or other law, regulation or requirements	Legitimate interests	Consent Compliance with a legal obligation Legitimate interests
   in connection with any corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the event of insolvency or the like	Legitimate interests	Consent Legitimate interests
   complying with other laws, regulations or requirements, including providing assistance to law enforcement, judicial and other government agencies	Compliance with a legal obligation	Consent Compliance with a legal obligation Legitimate interests
   working with any third party including our service providers (including the ATG group and thesaleroom.com, our whitelabel online auction platform provider, Stripe, our payment processing, Persona, our know your customer and identity verification provider, and delivery and shipping providers)	Legitimate interests	Consent Legitimate interests

   We may contact you for the above purposes by telephone call, email, text or SMS messaging, post and other means.

   
   We will not use your personal data for purposes other than those for which we have informed you, or which are permitted under applicable laws and regulations.

Anti-Money Laundering (AML), Countering Financing of Terrorism (CTF) and Countering Proliferation Financing (CPF) Policy (including Know Your Customer (KYC))

Overview

Singapore has a very stringent AML/CTF/CPF regulatory framework including specific requirements relating to Precious Stones and Precious Metals Dealers (PSMDs).

Hotlotz is committed to conducting business in accordance with ethical standards and in compliance with applicable AML/CTF/CPF laws and regulations in Singapore, including:

● The Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act

● The Anti-Money Laundering and Other Matters Act

● The Terrorism (Suppression of Financing) Act

● The Precious Stones and Precious Metals (Prevention of Money Laundering, Terrorism Financing and Proliferation Financing) Act

● The Precious Stones and Precious Metals (Prevention of Money Laundering and Terrorism Financing) Regulation

● Any sanctions/terrorist designation requirements

As part of these requirements, customer and other identities may need to be KYC-ed in order to verify them.

This policy sets out the framework for detecting, preventing, and reporting relevant activities in the course of Hotlotz’s business, using a business-risk and risk-based approach. This includes the fact that:

● Hotlotz operates a cashless business and does not accept or pay any form of currency or bank cheques or other cash equivalent means.

● Payments can only be accepted from the individual or organisation that is named as the winning bidder on the invoice and not a third party.

● Hotlotz can only make settlement payments to the individual or organisation that is named as the registered seller on the sales contract and not a third party.

This policy applies to Hotlotz (and Hotlotz affiliate) employees (who receive regular training on these topics), contractors and sub-contractors.

It also applies to all customers and counterparties engaging with Hotlotz, including buyers and sellers, and all transactions involving items facilitated by Hotlotz.

Customer due diligence

Customer due diligence may need to be conducted as follows:

● Prior to establishing a business relationship with a customer

● When there is suspicion of money laundering/terrorism financing/proliferation financing

● When there is doubt about the accuracy of previously obtained customer information

All bidders in auctions must register and may be held for approval by Hotlotz while customer due diligence is confirmed or carried out.

Information about customers and transactions is also shared by our white label platform providers, thesaleroom.com and liveauctioneers.com, aggregated from thousands of auction houses around the world who also use those platforms.

Any of the following information may be requested:

For Individuals:

● Full name

● Date of birth

● Nationality

● Identification document (NRIC, passport, or equivalent) with photograph

● Residential address

● Contact number/email

● Occupation and source of funds (when required)

For Entities:

● Company name and registration number

● Date of incorporation

● Place of incorporation

● Registered office and place of business address

● Phone/email

● Nature of business

● Proof of ongoing existence

● Constitution or equivalent

● Identity of senior management

● Details of directors and ultimate beneficial owners (UBOs)

● Identification documents of UBOs

Information may need to be verified using reliable, independent source documents.

Enhanced due diligence

Enhanced due diligence may need to be applied in higher-risk scenarios, such as:

● Politically Exposed Persons (PEPs)

● Transactions involving high-value or unusual items

● Customers from high-risk jurisdictions as identified by the G7’s Financial Action Task Force

● Higher-risk businesses, activities, sectors or customers

● Non-face-to-face customers

Enhanced due diligence measures may include:

● Using technology equivalent to face-to-face measures

● Obtaining additional identification documents

● Corroborating source of wealth or funds

● Conducting background checks

● Enhanced ongoing monitoring

● Obtaining management/executive internal approval

Monitoring and records

Hotlotz may monitor customer transactions to ensure consistency with the customer’s profile. We may scrutinize large or complex transactions with no apparent economic or lawful purpose. We may also review customer profiles and records on a periodic basis.

All customer due diligence records may be retained for at least 5 years after the end of the business relationship or completion of the transaction. Transaction records may need to be sufficient to permit reconstruction of individual transactions.

Reporting

All staff are required to report any suspicious transactions or customers promptly to the Compliance Officer.

The Compliance Officer is responsible for assessing the suspicion and, if necessary, filing a Suspicious Transaction Report (STR) with the Suspicious Transaction Reporting Office (STRO).

No customer will be informed (tipped off) about a STR filing.

Cash Transaction Reports (CTR) and semi-annual returns are also submitted as required.

Governance

Customer-facing employees are the first line of defence for identifying, assessing and controlling money laundering/terrorism financing/proliferation financing risks. The second line of defence includes support functions such as operations when they process transactions. The third line of defence is the internal compliance function.

The Hotlotz Managing Director is the designated Compliance Officer responsible for overseeing AML/CTF/CPF/KYC compliance.

Periodic internal audits are conducted to test the effectiveness of Hotlotz’s policies and procedures.

The Hotlotz directors and senior management are responsible for ensuring resources and authority are provided to enforce this policy. They have set a clear risk appetite and ensure a compliance culture where financial crime is not acceptable.

Sanctions

Hotlotz screens customers and transactions against relevant sanctions/terrorist designation lists (including those kept by the Ministry of Home Affairs and Monetary Authority of Singapore).

The aim of which is to ensure that no business will be conducted with any person or entity on the sanctions lists or in violation of sanctions laws.