Privacy Statement

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from golfwang.com (the “Site”).

Personal information we collect

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information, email address, and phone number. We refer to this information as “Order Information”.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

How do we use your personal information?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

- Communicate with you;

- Screen our orders for potential risk or fraud; and

- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

Sharing you personal Information

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Behavioural advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

- Facebook: https://www.facebook.com/settings/?tab=ads

- Google: https://www.google.com/settings/ads/anonymous

- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Do not track

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

Your rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

Data retention

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Contact us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us via our Customer Support Channel.

UK PRIVACY STATEMENT

This Privacy Statement applies to the processing of personal data relating to individuals based in the United Kingdom. It describes how your personal information is collected, used, and shared when you visit or make a purchase from golfwang.com (the “Site”). Golf Wang UK Limited is the controller for the personal data processing described in this Privacy Statement. You can contact us at [customerservice@golfwang.com] should you have any queries or issues in relation to anything set out in this statement.

Personal information we collect

The categories of information that we may collect and process may vary according to your relationship with us. Types of information that we may collect generally include contact details such as names, email addresses, telephone numbers and addresses (if you are a representative of one of our service providers or vendors, this may be your business contact information).

If you are an online customer or otherwise use our Site, we may collect and process:

login and account information, including your unique user ID and password;
personal details including your date of birth and gender;
order information, including billing and shipping addresses, payment or credit card information;
personal preferences including your marketing and cookie preferences;
content you may provide via online forms on the Site; and
information about your device, including information about your web browser, IP address, time zone.

If you are a visitor to our Soho store, we may collect and process:

payment or credit card information and, where placing an order in-store, billing and shipping addresses;
information about your marketing preferences;
photographs, if you use the in-store photobooth; and
audio and video footage collected by our on-premises CCTV system.

How do we use your personal information?

We only process your personal data when we have a legitimate business purpose and a lawful basis under the UK GDPR to do so. The table below sets out each of the purposes for which we process personal data and the relevant lawful basis we rely on for doing so.

Purpose	Lawful basis
Fulfilling orders and processing customer transactions.	Necessary for performance of a contract
Capturing CCTV footage and using it to protect against/ identify instances of crime and to monitor in-store standards.	Legitimate interests (protecting against loss or damage to stock, identifying other criminal activity, and ensuring that staff are maintaining expected standards).
Responding to queries received from customers via our contact channels.	Necessary for performance of a contract Legitimate interests (providing effective customer service)
Generating photographs via the in-store photobooth and uploading to the Site	Consent
Sending electronic marketing messages promoting our products and services to individuals who opt-in	Consent
Sending electronic marketing messages promoting products and services that are similar to those individuals have already purchased or enquired about.	Legitimate interests (promoting the products and services we offer that we think you will love).
Protecting against fraud.	Legal obligation Legitimate interests (protecting Golf Fraud’s business)
Management and administration of user accounts	[Necessary for performance of a contract] Legitimate interests (ensuring users can easily manage their preferences and orders),
Managing our relationships with our vendors and service providers	Legitimate interests
Website analytics	Legitimate interests (gaining insight into customer behaviour and the success of our marketing activities).

Please note that where we require you to provide us with information in order to perform a contract with you and you fail to provide that information, we will not be able to honour the contract and you may miss out, for example, on the products you wish to purchase.

Sharing you personal Information

Your rights

Under the UK GDPR, in certain circumstances you have the right to request:

access to your personal data;
receipt of a copy of the personal data you have provided to us in a structured, commonly used and machine-readable format (“data portability”) and to have that data transmitted to another controller, where possible;
the rectification or completion of personal data in our possession;
the erasure of personal data;
the restriction of our processing of your personal data,

You also have the right to object to our processing at any time if our processing is undertaken in reliance on the legitimate interests lawful basis, unless we can demonstrate compelling legitimate interests for continuing our processing. You may also object to our processing of your personal data for direct marketing purposes.

Where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time. We will immediately cease processing your personal data if we receive notification that you have withdrawn consent but this will not affect the lawfulness of the processing we undertook prior to this withdrawal.

Please see the ‘Contact Us’ section below for details on how you can contact us if you would like to exercise any of your rights.

Although we would appreciate the opportunity to rectify any issues you have with respect to our processing of your personal data, you have the right to make a complaint about our processing to the Information Commissioner’s Office (www.ico.org.uk)

International transfers

We transfer some personal data to the USA, [either to other Golf Wang entities or to our service providers]. To ensure that your personal data receives an adequate level of protection when in the USA, we have put in place an international data transfer agreement with the importer[s]. We also undertake risk assessments for our transfers of personal data to the USA, to establish whether we need to implement any further measures to protect your personal data. In the event that a risk assessment highlights risks that cannot be sufficiently mitigated by additional safeguards, we will not transfer your personal data.

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider:

The amount, nature and sensitivity of the personal data.
The potential risk of harm from unauthorised use or disclosure of your personal data.
The purposes for which we process your personal data and whether we can achieve those purposes through other means.
The applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use that information without further notice to you. Changes