Privacy policy
As of: 22 September 2026
The protection of your personal data is important to us. This privacy policy informs you about which personal data we process when you visit our website www.die-auktionshalle-berlin.de, for what purposes this is done, on what legal basis, and what rights you have under the General Data Protection Regulation (GDPR).
1. Controller
The person responsible for data processing on this website is:
Schwolow Solutions GmbH – Die Auktionshalle Berlin
Am Stener Berg 41e
13125 Berlin
Managing Director: Fabian Schwolow
Telephone: 030 229087545
Email: info@die-auktionshalle-berlin.de
Contact person for data protection questions: Fabian Schwolow, fabian.schwolow@die-auktionshalle-berlin.de. Further information can be found in the Imprint.
2. Hosting and server log files
When you access our website, the web server automatically processes information transmitted by your browser. This includes IP address, date and time of access, accessed page, transferred data volume, browser type and version, operating system, and the previously visited page (referrer). These data are stored in server log files and are not combined with other data sources.
Processing is technically necessary to deliver the website, ensure its stability and security, and to trace attacks or misuse. The legal basis is Art. 6 para. 1 lit. f GDPR (legitimate interest in a secure and functional operation). Log files are usually deleted after 14 days unless they are needed longer to clarify a specific incident.
The website is operated on servers of a hosting service provider in the European Union, with whom a data processing agreement according to Art. 28 GDPR exists.
3. Cookies and consent
Technically necessary cookies
Our website uses cookies that are necessary for operation: a session cookie and a cookie to protect against attacks on forms (CSRF protection). They do not contain any personal information, are not used for tracking, and are deleted when the browser is closed or after a short time. The legal basis is § 25 para. 2 no. 2 TDDDG in conjunction with Art. 6 para. 1 lit. f GDPR.
Consent cookie (“ws_consent”)
On your first visit, we ask via a banner whether external services (currently: HubSpot, see section 4) may be loaded. We store your selection for twelve months in the cookie ws_consent, so the banner does not appear again with each visit. This cookie is technically necessary to respect your decision (Art. 6 para. 1 lit. c and f GDPR). You can change or revoke your selection at any time via the link "Cookie Settings" in the footer of each page.
We do not use cookies for analysis, statistics, or advertising purposes and do not use tracking services like Google Analytics or advertising networks.
4. HubSpot: Forms, appointment booking and customer management
We use services from HubSpot, operated by HubSpot Inc., 2 Canal Park, Cambridge, MA 02141, USA, with a European branch HubSpot Ireland Ltd., 1 Sir John Rogerson's Quay, Dublin 2, Ireland. Our HubSpot account is operated in a data centre in the EU. HubSpot is used in two areas, which we describe separately below.
Forms and online appointment booking on this website
The HubSpot forms and appointment booking are only loaded when you consent in the cookie banner or directly at the respective element. Before that, no data is transmitted to HubSpot. Upon loading, HubSpot receives technical data such as your IP address and browser information and can set its own cookies. If you submit a form or book an appointment, the information you enter (e.g., name, email address, phone number, your request, uploaded photos, chosen appointment) is stored in our HubSpot account and used by us to process your request, coordinate appointments, and provide customer support.
Legal bases: Your consent to load the service (Art. 6 para. 1 lit. a GDPR, § 25 para. 1 TDDDG); the processing of your request for the implementation of pre-contractual measures or a contract (Art. 6 para. 1 lit. b GDPR); our legitimate interest in structured customer communication (Art. 6 para. 1 lit. f GDPR). You can revoke your consent at any time via the "Cookie Settings" in the footer; requests already submitted remain unaffected.
Reconciliation with our internal customer management
Our internal order and customer management system is connected to our HubSpot account. This synchronisation occurs regardless of whether you have filled out a form on this website – it therefore also affects people who have only called or written to us or for whom we are executing an order.
Data is processed in both directions:
- From us to HubSpot:<\/strong> Master data of our customers and prospects – salutation, first and last name, company, address, phone numbers, email address, and our internal customer number. If these details change with us, the change is transmitted to HubSpot.
- From HubSpot to us:<\/strong> the history of correspondence conducted via HubSpot (sender, time, and content of messages) as well as appointments agreed upon through online booking. Our system automatically creates an order with the associated appointment from suitable appointments, such as a viewing.
The purpose is a complete and consistent customer record: inquiries, correspondence, appointments, and orders should converge in one place so that your request can be processed comprehensibly and appointment agreements are not lost. Automated decision-making or profiling within the meaning of Art. 22 GDPR does not take place.
The legal basis is Art. 6 para. 1 lit. b GDPR, insofar as the processing serves the initiation or execution of a contract with you, otherwise Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in orderly customer care and reliable scheduling and order management. You can object to this processing pursuant to Art. 21 GDPR (see section 11).
For both areas of application, a data processing agreement exists with HubSpot. If data is transferred to the USA, this is based on HubSpot's certification under the EU-U.S. Data Privacy Framework and the EU Standard Contractual Clauses. Further information: HubSpot's Privacy Policy.
5. Customer account, bidding and identity verification
Customer account and bids
When you create a customer account for our online auctions, we process your name, email address, password (only as a hash), address, date of birth, and for commercial bidders, company and VAT ID, as well as the bids you place, hammer prices, invoices, and payments. We also log when you have confirmed our auction terms and your email address. When setting a password, we check if it appears in known data breaches; only a five-character part of the hash value is transmitted to the service "Have I Been Pwned" (Troy Hunt, Australia), from which neither your password nor your identity can be derived (Art. 6 para. 1 lit. f GDPR, protection of your account). Our registration and account activation forms contain a cookie-free protection against automated registrations, which does not send data to third parties. The legal basis is the performance of the contract or pre-contractual measures (Art. 6 para. 1 lit. b GDPR). For bids, we store the time and IP address to be able to prove the binding nature of a bid (Art. 6 para. 1 lit. f GDPR).
Through your account, you receive emails necessary for processing: email address confirmation, activation, hammer price, invoice, and payment reminders. Additionally, we inform you by email if you have been outbid; this notification can be disabled in the account settings. We only send advertising or newsletters with separate consent (Section 6).
ID verification
Before you are authorised to bid, we ask you once for a copy of your identity card or passport (for identity card, front and back) and a photo showing you together with the document. This is to verify your identity. The legal basis is our obligation as an auctioneer under the Money Laundering Act (§ 10 ff. GwG in conjunction with Art. 6 para. 1 lit. c GDPR) as well as our legitimate interest in a secure auction operation (Art. 6 para. 1 lit. f GDPR). We do not require the access and serial number of the document; you may cover them.
The files are transmitted encrypted, stored exclusively on our own server outside the public web directory, and only viewed by the staff conducting the verification. They are not transmitted to service providers and are not evaluated by automated procedures (e.g., text recognition by external AI services). The decision on approval is always made by a human. We will inform you of a rejection by email; you can then submit new documents or contact us.
We retain copies of IDs for five years after the end of the business relationship in accordance with § 8 GwG and delete them thereafter. If the account is not activated or is deleted beforehand, we remove the files within three months of the last activity, provided there is no legal obligation to retain them.
6. Newsletter
If you subscribe to our newsletter, we need your email address. Registration is done using the double opt-in procedure: you will receive an email with a confirmation link, only after which the registration is effective. We log registration and confirmation (time, IP address) to be able to prove consent. The dispatch is carried out via HubSpot (see section 4).
The legal basis is your consent (Art. 6 para. 1 lit. a GDPR). You can unsubscribe from the newsletter at any time via the unsubscribe link in each issue or by email to info@die-auktionshalle-berlin.de. Your data will then be removed from the distribution list.
7. Contact by phone, email and WhatsApp
If you call us, write an email, or send photos via WhatsApp, we process the data transmitted (name, contact details, content of the message, photos) to handle your request and for any follow-up questions. The legal basis is Art. 6 para. 1 lit. b GDPR (initiation or performance of a contract) or Art. 6 para. 1 lit. f GDPR (legitimate interest in responding to inquiries).
Email mailboxes (Google Workspace)
Our email mailboxes are operated by Google Workspace (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). Emails you send us and our replies are additionally transferred to our internal order and customer management system (sender, recipient, time, subject, message text, as well as name and size of attachments – not the attachments themselves). This allows us to assign your request to the appropriate process and respond reliably even if the originally contacted person is unavailable. Attachments are only transferred to our document storage on Google Drive if they belong to an order.
The legal basis is Art. 6 para. 1 lit. b GDPR or Art. 6 para. 1 lit. f GDPR (legitimate interest in an orderly, representative handling of inquiries). A contract for order processing exists with Google; insofar as data is transferred to the USA, this is based on Google's certification under the EU-U.S. Data Privacy Framework and the EU Standard Contractual Clauses. Further information: Google's Privacy Policy.
On WhatsApp (WhatsApp Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland), metadata of the communication is transmitted to WhatsApp or Meta; the message contents are end-to-end encrypted. The use of WhatsApp is voluntary; you can also reach us at any time via the other mentioned ways. Details: WhatsApp's Privacy Policy.
8. External links and services
Our website contains links to third-party offers, such as our previous online catalogues (online.die-auktionshalle-berlin.de), partner auctions (luedtke-auktion-online.de), and Google Maps for route planning. By clicking on such a link, you leave our website; the privacy policy of the respective provider applies. We do not embed maps, videos, or social media plugins directly into our pages, so no data flows to these providers when you simply visit our website.
9. Reach measurement (own statistics)
To understand which content on our website is in demand, we conduct our own access statistics. We do not use cookies or third-party analytics services for this – the evaluation takes place exclusively on our own server, and no data is transmitted to third parties.
For each page view, we store: the page accessed, date and time, language version, referring website or search engine, type of device (mobile, tablet, computer), browser family, and – if included in the accessed address – campaign identifiers (utm parameters). Additionally, we record whether a phone number, an email address, a catalogue link, a download, or the online appointment booking was clicked on a page.
To ensure that repeated visits from the same device within a day are not counted multiple times, we create a non-reversible check value from the IP address, browser identification, a secret key, and the respective date. The IP address itself is not stored.<\/strong> Because the date is included in the check value, recognition beyond the day is excluded; we cannot identify individual persons from this.
The legal basis is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the needs-based design and improvement of our offer. Consent is not required as no information is stored or read on your device (§ 25 para. 2 TDDDG). The collected data is automatically deleted after 14 months.
10. Fonts, encryption and error logs
Fonts
The fonts used on the website are delivered from our own server. There is no connection to Google Fonts or other external font providers.
Encryption
The transmission between your browser and our website is encrypted via TLS/SSL (recognisable by the "https://" and the lock symbol in the address bar). This prevents third parties from reading the transmitted data.
11. Storage duration
We store personal data only as long as necessary for the respective purpose. Inquiries that do not result in an order are usually deleted after twelve months. Data related to orders, invoices, and settlements are subject to commercial and tax retention obligations of six to ten years (§ 257 HGB, § 147 AO) and are deleted after their expiration. Newsletter data is stored until you unsubscribe.
The same deadlines apply to data reconciled with HubSpot as per Section 4. The ongoing reconciliation does not automatically delete anything there – we carry out deletions separately in our HubSpot account. If you request the deletion of your data, we will record both systems.
Copies of emails and HubSpot conversations in our internal system (Sections 4 and 7), which are not assigned to any order, auction or contact, are automatically deleted after 24 months. If a message is deleted in the original system (Gmail or HubSpot), we remove the internal copy at the next synchronisation.
12. Your rights
You have the following rights regarding your personal data concerning us:
- Information<\/strong> (Art. 15 GDPR) about the processed data, purposes, recipients, and storage duration,
- Correction<\/strong> of incorrect or incomplete data (Art. 16 GDPR),
- Deletion<\/strong> (Art. 17 GDPR), unless there are legal retention obligations,
- Restriction of processing<\/strong> (Art. 18 GDPR),
- Data portability<\/strong> (Art. 20 GDPR),
- Objection<\/strong> to processing based on legitimate interests (Art. 21 GDPR),
- Revocation<\/strong> of a given consent with effect for the future (Art. 7 para. 3 GDPR).
To exercise your rights, a simple message to info@die-auktionshalle-berlin.de<\/a> or to the postal address mentioned above is sufficient.
You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The competent authority for us is the Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59–61, 10555 Berlin, www.datenschutz-berlin.de.
13. Changes to this privacy policy
We will adapt this privacy policy if the legal situation or our website changes, for example, when we launch our own online auction system with a customer account. The version published here applies; the date of the status can be found at the top of this page.