1. Introduction

We, Srixon Sports Europe Ltd., take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR). This privacy notice aims to give you information on how Srixon Sports Europe Ltd. collects and processes your personal data through your use of this site and any data you may provide if you contact us regarding our products and services. We have appointed a data protection officer (DPO) who is responsible for monitoring and providing guidance with our GDPR status. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the contact information laid out in section 10 of this privacy notice.

2. Lawful Basis of Processing Personal Information

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:

• The data subject (you) has given consent to the processing activity taking place
• If the processing is necessary for the performance of a contract or fulfilment of a sales order
• If the processing is necessary for compliance with a legal obligation to which the controller is subject
• If the processing is necessary for the purpose of the legitimate interest pursued by us or our partners

3. What Information do we collect and where from?

We collect personal information from you, for example if you register to our website, request product information, call us or use any of our services. The categories of personal information that we may collect, store and use about you may include:

• Name, address, telephone number, email,
• Payment information such as credit card details
• IP address

In some cases additional personal information may be collected (typically only collected for employees/contractors):

• Your country of birth and nationality
• Date of birth and gender
• Passport details and national insurance number

We may also collect your data through third parties such as golf clubs and sports goods retailers.

3.1 Use of ‘Cookies’

Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognise a device or browser and may come in many different forms. We use the following types of cookies:

3.1.1 ESSENTIAL/NECESSARY COOKIES

These cookies are essential for the functioning of our website. This includes, for example, the issuing of anonymous session IDs to summarise multiple queries to a web server or ensuring fault-free functioning of registrations and orders.

3.1.2 FUNCTIONALITY COOKIES

These cookies help us to save your chosen settings or support other functions when you are navigating our website. They allow us, for example, to remember your preferred settings for your next visit or save your login data for certain areas of our website.

3.1.3 PERFORMANCE/STATISTICS COOKIES

These cookies collect information about how you use our website (e.g. which Internet browser you use, how often you visit our website, which pages you open, or how long you stay on our website). These cookies do not store any information that enables visitors to be personally identified. The information collected with the help of these cookies is aggregated, and thus anonymous. You can accept or decline cookies – including those used for website tracking – by selecting the appropriate settings for your browser. You can set your browser to notify you when you receive a new cookie, or to decline cookies altogether. However, if you choose to decline cookies you may not be able to use all the features of our website. Your browser also offers you the option to delete cookies (e.g. via the Clear Browsing History function). For further information, please refer to the user help function under Settings in your web browser.

3.1.4 ANONYMISED WEBSITE TRACKING

To align this website better to our customers’ needs, we analyse how our customers interact with the site. We anonymise your IP address (and possibly similar information exchanged with our site by your computer or device during standard Internet use) and then use it to analyse data such as the pages at https://www.srixon.co.uk visited by your browser and your computer. Again, we use cookies for this purpose. Our cookies contain only one unique number by which we can re-identify you on our websites, but not however, on third-party websites. We use the stored data for statistical purposes only. In particular, the IP address will not be associated with any individual user. The data will not be shared with third parties.

3.1.5 USE OF GOOGLE UNIVERSAL ANALYTICS

This website uses Google Universal Analytics, a web analysis service offered by Google Inc. (“Google”). Google Universal Analytics uses cookies, text files stored on your computer, to help us analyse how you use our website. The information generated by the cookie about your use of this website (including your IP address) is transferred to Google servers in the USA and saved there. We have activated IP anonymisation on this website, so that the IP address of users within EU Member States or other States party to the Agreement on the European Economic Area will be truncated by Google beforehand. Only in exceptional cases is the full IP address sent to Google servers in the USA and truncated there. On behalf of the website provider, Google will use this information for the purpose of analysing your use of the website, compiling reports on website activity, and providing us with other services relating to website activity and internet usage. Google will not associate the IP address transmitted by your browser within the operations of Google Universal Analytics with any other data held by Google. You may prevent cookies from being installed by selecting the appropriate settings on your browser. However, please note that in this case you may not be able to use the full range of functions of this website. Furthermore, you can prevent Google from collecting and using the data regarding your use of the website generated by the cookies (including your IP address) by downloading and installing the browser plugin from the following link: https://tools.google.com/dlpage/gaoptout?hl=. For more detailed information on the conditions of use and data privacy, go to https://www.google.com/analytics/terms/gb.html and/or https://policies.google.com/privacy. Please note that this website uses Google Universal Analytics with the code extension “anonymizeIp” to ensure anonymised recording of IP addresses (known as IP masking) and exclude direct personal references.

3.1.6 QUANTCAST

This website uses the Quantcast services for user measurement and advertising purposes. As part of these services, the Quantcast site allows anonymous browser data to be collected and analysed using standard Internet cookies. This anonymous data is in no case used to personally identify the visitors of the website. Learn more about Quantcast’s commitment to confidentiality and privacy in the Quantcast Privacy Policy. You can opt-out of advertising and data collection through Quantcast on the Quantcast opt-out page or through the more advanced opt-out service provided by the European Digital Advertising Alliance.

3.1.7 EMBEDDING OF SOCIAL PLUGINS

Our website uses buttons for the following social Networks

• Facebook, Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA
• Instagram, Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA
• Twitter, Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA
• YouTube, LLC, 901 Cherry Ave., San Bruno CA 94066, USA

The buttons show the logos of the individual social networks. However, the buttons are not standard social plugins, i.e. plugins provided by social networks, but links with button icons. These buttons are only activated by deliberate actions (clicking). If you do not click the buttons, no data will be transferred to the social networks. By clicking the buttons, you accept communication with the servers of the social network, thereby activating the buttons and establishing the link. Once clicked, the button functions as a share plugin. The social network then obtains information about the site you have visited, which you can share with your friends and contacts. You need to be logged in to “share” information. If you are not logged in, you will be forwarded to the login page of the social network you have clicked, thereby leaving the pages of www.srixon.co.uk. If you are logged in, your “like” or recommendation of the article in question will be transmitted. When you activate the button, the social networks will also receive the information that you accessed on the respective page of our website and when you did so. In addition, information such as your IP address, details about the browser you used, and your language settings may be transmitted. If you click the button, your click will be transferred to the social network and used according to their data policy. When you click the button, we have no control over the data collected and the data-processing operations. We are not responsible for this data processing, nor are we the “controller” as defined in the GDPR. Neither are we aware of the full extent of data collection, its legal basis, purposes and storage periods. Given this, the information provided here is not necessarily complete. The data will be transmitted irrespective of whether you actually have an account with this provider or whether you are logged in there. If you are logged in with the provider, your data will be assigned directly to your account. Providers may also use cookies on your computers to track you. As far as we know, these providers store this data in user profiles which they use for advertising, market research and/or demand-oriented website design. This type of analysis is performed (also for users who are not logged in) to present demand-oriented advertising and inform other users of the social network of your activities on our website. You have the right to object to the creation of these user profiles. To exercise your right of objection, please contact the relevant provider. Please consult the information provided by the following social media sites for details of the purpose and scope of data collection and of further processing and use of the data by the respective social network, and for your rights and privacy settings: Facebook: https://www.facebook.com/about/privacy Instagram: https://help.instagram.com/519522125107875?helpref=page_content Twitter: https://twitter.com/privacy YouTube: https://www.youtube.com/intl/en-GB/about/policies/#community-guidelines If you do not wish social networks to obtain data about you, do not click the button.

4. How long do we keep information for?

We pride ourselves on ensuring that your personal data is retained for the period that Srixon Sports Europe Ltd. needs it for. All personal information collected has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see “additional information” in section 10 of this policy.

5. Security of personal information

Srixon Sports Europe Ltd. is committed to handling your personal information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfil their job responsibilities. At Srixon Sports Europe Ltd. we have also ensured that all employees have enough information security training and have a data protection policy which helps maintain, enforce and communicate best practices surrounding information security throughout the business. If you would like more details on this, please see “additional information”, in section 10 of this policy.

6. Children’s information

Srixon Sports Europe Ltd. does not knowingly collect information on children without consent from a responsible parent. If Srixon Sports Europe Ltd. have collected personal information on a child, please see section 10 immediately, so we can remove this information without any undue delay.

7. Your individual rights

In this section, we have summarised the rights that you have under the General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. Your principal rights under General Data Protection Regulation are:

• Right to Access
• Right to Rectification
• Right to Erasure
• Right to Restrict Processing
• Right to Object
• Right to Data Portability
• Right to Contest Automated Decision Making (Automated decision making is not carried out by Srixon Sports Europe Ltd.)

You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee (£10). You as a data subject have the right to rectification, which will allow you as the data subject to modify/change any personal information to the purpose of ensuring that the information we process is up to date. The right to erasure or right to be forgotten will allow you as the data subject to inform us that you no longer want Srixon Sports Europe Ltd. to continue to store or process your personal information. Please be aware that we may decline your right for a number of reasons, which are not limited to, having a lawful basis to process your information or us needing your information for the performance of a contractual obligation. As a data subject, you have the right to stop any processing of your personal information. Please be aware that you must provide us with a legitimate reason for us to stop processing. Any request made that doesn’t conform to the GDPR will be rejected. On occasion Srixon Sports Europe Ltd. may send you marketing emails to make you aware of new products that we believe can benefit you, the data subject, and in situations where you have consented to this activity. As you have the right to object, you can click the unsubscribe link on all our emails to inform us that you no longer want to receive marketing emails from us. The right to data portability will allow you as the data subject to have your personal information securely transferred to another organisation for processing. At Srixon Sports Europe Ltd. we place this responsibility on you, the data subject. When you make this request, we will export all information about you and securely transfer it to yourself. You, the data subject, will be able to give this information to your chosen organisation. If you have any questions about these rights, please see “additional information”, in section 10 of this policy.

8. Data transfers/Third parties

8.1 Providing your information to others

Srixon Sports Europe Ltd. may disclose your personal data, listed in section 3 to some third parties in so far as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Third parties that we use are listed below.

8.2 Third Parties

A full list can be requested from section 10 of this policy.

• Logistics (most commonly UPS)
• Credit Checking and Collection Services (including Credit Safe, Credit Circle, Wilkes, Credit Reform and STA International)
• External Auditors (KPMG)
• IT Services (including Microsoft, and AWS for email services)
• Other Suppliers as needed to fulfil customised orders

8.3 Information security with Transfers

In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). We may share personal information to third parties outside of the European Economic Area (EEA). In such cases, we would ensure that a high standard of information security would be used to protect any personal information. This would include the use of encryption in transit and ensuring that data protection laws are being pursued. All information that is being transferred within the EEA will follow our strict Document and Data Management Policy, which can be requested from section 10 of this policy.

9. Right to complaint

We take any complaints about our collection and use of personal information very seriously. If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concerns about our data processing, please raise this with us in the first instance. To make a complaint, please contact us via email on dpo@srixon.co.uk In line with GDPR article 27, we also have a European Union legal representative on behalf of Srixon Sports Europe Ltd. The contact email is legal@sumitomo-rubber.de Alternatively, you can make a complaint to the Information Commissioner’s Office (ICO registration reference is Z8773988):

• By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
• By Website: Click Here
• By Email: Click Here
• By Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate)

10. Additional information

Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact our DPO via email on dpo@srixon.co.uk In line with GDPR article 27, we also have a European Union legal representative on behalf of Srixon Sports Europe Ltd.

11. REVIEW OF THIS POLICY

We keep this Policy under regular review. This Policy was last updated on 10 March 2020.

11.1 Amendments

We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.