We are committed to respecting your privacy. This
Notice is intended to inform you about how we collect, use and protect any
personal data we collect about you. It sets out how we comply with the data
protection laws and what your rights are.
This Notice applies to you if we process your
personal data and you are not an employee. You could be an individual customer,
a sole trader, a partnership, a user of our Website, www.THELINESMITH.EU,
someone who works at a supplier or customer of ours or another organisation
that we deal with, someone who enters one of our marketing competitions or
attends one of our events, a recruitment candidate or someone else who is
affected by our activities.
We are THELINESMITH.EU
(“9 BEAUFORT SPORTS”) Dutch chamber of commerce 39098443
VAT NO: NL002175002B43
Regstration address:
Rudolf nureyevstraat 6
1326 TH ALMERE
Netherlands
If you have any queries regarding your personal
data and how it may be used by THELINESMITH.EU, then you can contact us by
email on support@THELINESMITH.EU .
References to we, our or us in this Notice are
references to THELINESMITH.EU.
This Notice provides details about:
- What personal data we collect
- Where we collect your personal data from
- How we use your personal data
- Who we share your personal data with
- How we aim to protect your privacy
- How long we will keep your personal data
- International transfers of your personal
data
- Your Rights
- Changes to this notice
- Contact Us
WHAT PERSONAL DATA DO WE
COLLECT?
We may collect the following personal data about
you:
- Contact details such as your name, address
(including billing and delivery addresses), telephone number (including
mobile number) and email address.
- Identification information such as your
passport and other official identification details, information from a
third-party money laundering check provider, Companies House information
and your national insurance number.
- Personal data including your age or date of
birth, gender, family details and dietary requirements.
- Your social media handles, posts and information
about your followers and the people that follow you.
- Details of financial and transaction data
including purchases, orders, returns and refunds.
- Online browsing activities on our Website
including which items you store in your shopping cart.
- Your usage of our website and your username
and password.
- Information about the device you use to browse
our Website including the IP address, device type, usernames, account
details and passwords.
- Information connected with any purchases made
on our Website including financial and transaction data.
- Communication and marketing preferences.
- Interests, preferences, feedback and
competition and survey responses.
- Your real-time location.
- Correspondence and communications with us
including relating to complaints, allegations, disputes and claims.
- Other publicly available personal data,
including any which you have shared via a public platform (such as
LinkedIn, Instagram, YouTube, Twitter or a public Facebook page).
- Business information, such as where you are a
sole trader, a partner or a company director.
- Creditworthiness, where we are required to
undertake investigations in order to establish whether to enter into or
continue a business relationship with you or the organisation you work
for.
- Details of your performance when working with
or for us or in relation to any project or work we are engaged in.
- Videos, photographs and audio recordings which
you or other people take and provide to us or we take ourselves.
- Subscription Information such as when you
subscribe to one of our blogs or other materials.
This list is not exhaustive and in specific
instances, we may need to collect additional personal data for the purposes set
out in this Notice.
Special Categories of Personal Data
There are limited situations in which we collect,
store and use the following “special categories” of more sensitive personal
data including:
- information about your race or ethnicity,
religious beliefs and sexual orientation;
- information about your health, including any
medical condition, dietary requirements, health and sickness records,
medical records and health professional information; and
- biometric data including your height and
weight.
Where we do collect any special category personal
data, we will do so based on your explicit consent.
We may collect, store and use any criminal records
information in relation to you; in which case we will do so based on legal
obligation or your explicit consent.
WHERE DO WE COLLECT YOUR
PERSONAL DATA FROM?
You
We may collect your personal data directly or
indirectly from you, for example when you:
- engage with us during our relationship with
you or the organisation you work for;
- set up an online account on our Website and
/or purchase products from us;
- Register to use, Website or other services we
provide;
- communicate with us regarding one of our App,
Website or services, to ask a question, report a problem or for any other
reason;
- register for, attend and/or participate in one
of our events or enter one of our competitions;
- enquire about a vacancy or apply to become an
employee of ours;
- enquire about and/or become one of our content
contributors; and
- raise a query, complaint, claim, legal dispute
on behalf of yourself or the organisation you work for.
Third Parties
We may also collect personal data from third
parties who have your consent or some other lawful basis for doing so
including:
- professional bodies;
- credit reference agencies including those
which carry out data cleansing services;
- organisations who carry out research and
analysis;
- Companies House;
- social media platforms including such as
LinkedIn; Instagram, YouTube, Twitter or public Facebook page;
- referrals and recommendations, usually given
by other people who know you or have a working relationship with you;
- your employer or the organisation you work
for;
- our professional advisors including lawyers,
accountants and other advisors;
- your professional advisors including lawyers,
accountants and other advisors; and
- Government, local authorities or relevant
regulators.
HOW WE USE YOUR DATA
Purpose |
Personal data Used |
Lawful Basis |
To carry out identity and credit checks |
Contact details and payment information relating to you or the
organisation you work for |
We may have a legal obligation to undertake identification We also have a legitimate interest in knowing your identity and
carrying out money laundering checks and ensuring that we are likely to be
paid |
To enter into and perform contracts, where we may be supplying
products/services to you and/or the organisation you work for and/or you may
be supplying products/services to us and/or the organisation you work for or
where we may be involved in similar arrangements with third parties |
All the personal data we collect |
To enter into and perform contracts with either yourself or the
organisation that you represent We have a legitimate interest to properly perform contracts with third
parties |
To deal with queries, complaints, claims, legal disputes submitted by
you or the organisation you work for and to make queries, complaints, claims,
legal disputes in which relate you or the organisation you work for |
All the personal data we collect |
This may be necessary to perform a contract with you or the
organisation that you represent We have a legitimate interest to improve the services and/or products
we provide To defend, bring or establish legal claims |
To maintain and improve our services and/or products |
All the personal data we collect |
We have a legitimate interest to improve the services and/or products
we provide |
Data analytics, statistical analysis and other research to help us
improve our products and services |
All the personal data we collect |
We have a legitimate interest to improve the products and services we
provide and to improve user experience |
Security of our IT systems |
All the personal data we collect |
We have a legitimate interest in ensuring the security of our IT
systems |
Direct marketing |
Contact details and services and products that we have determined may
be of interest to you or your organisation and/or which you or your
organisation has purchased in the past |
We may ask for your consent to process your data for this purpose, you
may revoke your consent at any point. Alternatively, if you or your
organisation has purchased similar services or products from us previously,
we may market similar products or services as a legitimate interest in
developing our business. You have the right to opt out from such
marketing at any time. For more details see the ‘Marketing’ section
below. |
For the prevention, detection or investigation of crime or the prosecution
of offenders |
All of the personal data we collect |
We have a legitimate interest in protecting our rights and interests
(for example in court cases) and in protecting the rights and interests of
our employees, customers and any other third party with who we engage. To comply with any legal obligations and regulatory requirements |
To comply with our legal and regulatory obligations |
All the personal data we collect |
To comply with any legal obligations and regulatory requirements |
To manage our relationship with you or the organisation you work for
and to operate and manage our business and internal reporting |
All the personal data we collect |
We have a legitimate interest to operate our business in an efficient
way and to expand our business To enter into and perform contracts with either yourself or the organisation
that you represent |
Storage of records relating to you and also records relating to our
business |
All the personal data we collect |
To be able to manage and fulfil any contract with you, we may have a
legal obligation to do so and we also have a legitimate interest to keep
proper records |
Marketing activities including THELINESMITH.EU’s website, social media
sites and Apps, internal employee engagement and presentations by THELINESMITH.EU
employees at internal and external meetings |
All the personal data we collect |
We have a legitimate interest in tracking attendance at events and
using the images and footage produced for business and marketing purposes We may also have a legal and/or regulatory obligation to comply with |
For some of your personal data you may have a
legal, contractual or other requirement or obligation for you to provide us
with your personal data. If you do not provide us with the requested
personal data, we may not be able to properly perform our contract with you or
the organisation you represent or comply with legal obligations and we may have
to terminate our relationship. For other personal data you may not be
under an obligation to provide it to us, but if you do not provide it then we
may not be able to properly provide you with our goods and services or perform
our arrangements with you or the organisation you represent.
Where you have given us your consent to use your
personal data in a particular manner, you have the right to withdraw this consent
at any time, which you may do by contacting us as described in the Contact us section
below. We will generally only process your personal data based on your
consent in relation to direct marketing or in relation to the processing of
special category data and data relating to criminal convictions and offences.
Please note however that the withdrawal of your
consent will not affect any use of the data made before you withdrew your
consent and we may still be entitled to hold and process the relevant personal
data to the extent that we are entitled to do so on a basis other than your consent.
Withdrawing consent may also have the same effects as not providing the
information in the first place, for example we may no longer be able to provide
marketing information to you.
We may anonymise and aggregate any of the personal
data we hold (so that it does not identify you). We may use anonymised
and aggregated information for purposes that include testing our IT systems,
research, data analysis, improving our site and developing new products and
services and for any other purpose.
You have the right to opt out of receiving
marketing communications from us at any time, by:
1. informing us that you wish to change your marketing preferences by
contacting our customer support team at support@THELINESMITH.EU;
2. making use of the simple “unsubscribe” link in emails
This will not stop service messages such as order
updates and other non-marketing communications.
Personalisation and Automated Decision Making
If you visit our Website or use our App, you may
receive personalised banner advertisements whilst browsing website of other
companies. Any banner advertisements you see will relate to your browsing
activity on our website from your computer or other devices.
These advertisements are provided by us via
external market leading specialist providers using techniques such as pixels,
web beacons, ad tags, mobile identifiers and ‘cookies’ placed on your computer
or other devices (see further information on the use of cookies in
our Cookie policy. You can remove or disable cookies at any time –
see our cookie policy for further information.
We may analyse your browsing and purchasing
activity online and your responses to marketing communications. The
results of this analysis, together with other demographic data, allow us to
decide what marketing communications are suitable for you and to ensure that we
contact you with information on products, services, events and offers that are
tailored and relevant to you. To do so, we use software and other
technology for automated decision making.
This allows us to provide more personalised
services and experiences, we may review personal data held by external social
media platform providers about you, such as the personal data available on
social media platforms such as Twitter, Instagram, YouTube, Twitter and
Facebook. Some of our services enable you to sign-in via external social media
platform providers such as Facebook. If you choose to sign-in via a third party
app, you will be presented with a dialog box which will ask your permission to
allow us to access your personal data (e.g. your full name, date of birth,
email address and any other information you have made accessible).
We aim to update you about products and services
which are of interest and relevance to you as an individual. To help us do
this, we process personal data by profiling and segmenting, identifying what
our customers like and ensuring messages we send them are relevant based on their
demographics, interests, purchase behaviour, online web browsing activity and
engagement with previous communications. We may also use your personal data to
exclude you from communications which we feel are irrelevant to you. For
example, we may exclude someone from resends of marketing emails when we know
that person has already opened the original email sent.
Another example of how we may tailor our
communications with you is that we may group individuals with similar interests
using this data so we can send them product news or promotional offers that are
relevant to that shared interest.
You may have the right to opt out of some automated
processing, including profiling, at any time by:
1. informing us that you wish to opt out of automated processing by contacting
our customer support team at support@THELINESMITH.EU; and/or
Cookies
Our Website uses cookies to capture personal data
such as the browsing and purchasing behaviours of people who visit our Website
including the pages viewed, products purchased and the journey around our
Website.
We currently use a cookies tool on our Website
which relies on implied consent of users. In recognition of the fact that
the implementation date for the revised e-Privacy Regulation remains unknown,
we are taking reasonable steps now to align our use of cookies the standard of
consent required by GDPR. This means that we are in the process of updating the
tool which, by default, requires explicit opt in action by users of our
Website. This will apply to the non-necessary cookies. We will ensure any
necessary cookies for functionality and security are marked so that they are
not deleted by the tool.
Detailed information about how we use cookies is in
our Cookie policy This will allow you to make an informed choice as to
whether you wish to accept our cookies.
WHO WE SHARE YOUR PERSONAL
DATA WITH
We may share your personal data with the following
third parties:
- The organisation that you represent.
- Other companies within our group.
- Other organisations within our supply chain so
that they can contact you about any issues in the supply chain or where
your personal data is relevant to a subcontractor or party above us in the
supply chain.
- Other organisation including but not limited
to organisations who own the venues at which our events take place,
organisations who market and/or facilitate our events and photographers
and videographers who attend our events.
- Purchasers, investors, funders and advisers if
we sell or negotiate to sell all or part of our business or assets or
restructure our business whether by merger, re-organisation or otherwise.
- Third parties who ask for or want referrals
for example we may provide your details to a third party who is seeking
services/products which are the same or similar to those that you provide.
- Other service providers and advisors to us
including companies that support our IT, help us analyse the data we hold,
process payments, send communications to our customers, provide us with
legal, property or financial advice and generally help us deliver our
products and services to you or the organisation that you represent or for
us to purchase them from you or the organisation you represent.
- Our professional advisors including lawyers,
accountants and other advisors.
- Your professional advisors including lawyers,
accountants and other advisors.
- Credit reference agencies and other
identification agencies so that we can assess your creditworthiness or
verify your identity.
- Organisations who carry out research, analysis
and/or data cleansing services.Governmental bodies, regulators, law
enforcement agencies, security services, courts/tribunals and insurers
including where we are required to do so in order to comply with our legal
obligations and the administration of justice.
HOW WE PROTECT YOUR DATA
Our controls
THELINESMITH.EU is committed to keeping your
personal data safe and secure and so we have numerous security measures in
place to protect the loss, misuse and alteration of information under our
control. Our security measures include: -
- encryption of personal data;
- regular cyber security assessments of all
service providers who may handle your personal data;
- regular planning to ensure we are ready to
respond to cyber security attacks and data security incidents;
- weekly penetration testing of systems;
- security controls which protect our IT systems
infrastructure and our premises from external attack and unauthorised
access;
- internal policies setting out our data
security rules for our personnel; and
- regular training for our employees.
We take data security very seriously and will use
all reasonable endeavours to protect the integrity and security of the personal
data we collect about you.
WHAT YOU CAN DO TO HELP
PROTECT YOUR DATA
You should always be cautious when sharing your
personal data. No one from our company will ever ask you to confirm any bank
account or credit card details via email. If you receive an email
claiming to be from THELINESMITH.EU asking you to do so, please ignore it and
do not respond.
If you are using a computing device in a public
location, we recommend that you always log out and close the website browser
when you complete an online session.
In addition, we recommend that you take the
following security measures to enhance your online safety:
- When creating a password, use a difficult
word/number combination of at least 8 characters and something that is not
easily guessed or something that cannot be easily obtained such as your
name, email address, or other personal data that can be easily obtained.
- Frequently change your password (you can do
this in your account settings.
- Avoid using the same password for different
online accounts.
HOW LONG WE KEEP YOUR DATA
We will not retain your personal data for longer
than necessary for the purpose for which is has been obtained and then for as
long as there is any risk of a potential claim, which will be dependent upon
the limitation period for the particular type of claim. Various laws,
accounting and regulatory requirements applicable to us also require us to retain
certain records for specific amounts of time. In relation to your personal
data, we will hold this only for so long as we require that personal data for
legal or regulatory reasons or for legitimate organisational purposes. We will
not keep your data for longer than is necessary for the purposes for which we
collect them.
Our Data Retention Policy sets out the length of
time we will usually retain personal data and where these default periods might
be changed.
It is important to ensure that the personal data we
hold about you is accurate and up-to-date, and you should let us know if
anything changes, for example if you move position or work for a different
organisation or change your phone number or email address. You can contact us
by using the details set out in the Contact us section below.
INTERNATIONAL TRANSFERS
The personal data we collect may be transferred to
and stored in countries outside The netherlandss and the European Union. This
will typically occur when service providers are located outside the THE
NETHERLANDS and the European Union or if you are based outside theThe
Netherlands and the European Union. These transfers are subject to
special rules under data protection laws.
Some of these jurisdictions require different
levels of protection in respect of personal data and, in certain instances, the
laws in those countries may be less protective than the jurisdiction you are
typically resident in. We will ensure that your personal data is only used in
accordance with this Notice and applicable data protection laws and is
respected and kept secure and where a third party processes your personal data
on our behalf we will ensure that one of the following safeguards is
implemented:
- we will only transfer your personal data to
countries that have been deemed to provide an adequate level of protection
for personal data by the European Commission;
- where we use certain service providers, we may
use specific contracts approved by the European Commission which give
personal data the same protection it has in the THE NETHERLANDS and the
European Union; and
- where we use providers based in the US, we may
transfer data to them if they are part of the Privacy Shield
which requires them to provide similar protection to personal data shared
between the Europe Union and the US.
Our directors and other individuals working for us
may in limited circumstances access personal data outside of the THE
NETHERLANDS and European Union if they are on holiday abroad outside of the THE
NETHERLANDS or European Union. If they do so they will be using our
security measures and will be subject to their arrangements with us which are
subject to English Law and the same legal protections that would apply to
accessing personal data within the THE NETHERLANDS.
In limited circumstances the people to whom we may
disclose personal data as mentioned in the “Who We Share Your Personal Data
With” section above may be located outside of the THE NETHERLANDS and European
Union. In these cases, we will impose any legally required protections to
the personal data as required by law before it is disclosed.
For further details please contact us by using the
details set out in the Netherlands section below.
YOUR RIGHTS
You have the following rights in relation to your
personal data:
- The right to be informed about
how your personal data is being used.
- The right to request access to
personal data we hold about you.
- The right to ask us to update and
correct any out-of-date or incorrect personal data that we hold
about you.
- The right to object to processing of
your personal data and/or to withdraw any consent you have given
us and to opt out of any marketing communications that we may send you.
- The right to restrict processing of
your personal data.
- The right to object to certain
automated decision-making processes using your personal data including
profiling.
- The right to request that we erase your
personal data in certain circumstances (the right to be forgotten)
for example when the data are no longer necessary for the purpose for
which we collected them.
- The right to have your personal data
provided to you by us in a structured, commonly used and machine-readable
format and transmitted to another data controller. This is known
as the right to data portability.
You should note that some of these rights, for
example the right to require us to transfer your data to another service
provider or the right to object to automated decision making, may not apply as
they have specific requirements and exemptions which apply to them and they may
not apply to personal data recorded and stored by us. However, some have
no conditions attached, so your right to withdraw consent or object to
processing for direct marketing are absolute rights.
We may need to request specific information from
you to help us confirm your identity and ensure your right to access the
information (or to exercise any of your other rights). This is another
appropriate security measure to ensure that personal data is not disclosed to
any person who has no right to receive it.
Whilst this Notice sets out a general summary of
your legal rights in respect of personal data, this is a very complex area of
law. More information about your legal rights can be found on the Information
Commissioner’s website at KVK.NL
If you wish to exercise any of the above rights,
you can always contact us using the details set out in the 'Contact Us'
section below.
CHANGES TO THIS NOTICE
We may update this Notice from time to time. When
we change this Notice in a material way, we will update the version date at the
bottom of this Notice. For significant changes to this Notice we will try to
give you reasonable notice unless we are prevented from doing so. Where
required by law we will seek your consent to changes in the way we use your
personal data.
CONTACTING US
In the event of any query or complaint in
connection with the information we hold about you, please email support@THELINESMITH.EU