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Last change: March 24th, 2021

PRIVACY POLICY

We are aware that you place trust in us, and we want to be open and transparent about the processing of your personal data. This policy explains how your personal data is processed and protected.

Who is the controller of your personal data?
The Dutch company COG B.V. is the controller of the personal data that you provide us and is responsible for your personal data under the General Data Protection Regulation ("GDPR").
Visiting address: Baronieweg 13, 5321 JV in Hedel.
Postal address: Postbus 19, 5320 AA in Hedel.
Chamber of Commerce nr.: 32170384.

Where do we store your personal data?

The data that we collect from you is stored on the servers of Circle of Gentlemen located in the European Economic Area ("EEA").

Who has access to your personal data?
Only authorised employees of Circle of Gentlemen have access to the personal data and process the personal data on behalf of Circle of Gentlemen. Circle of Gentlemen will never forward, sell or exchange your data to/with third parties for marketing purposes. Data transmitted to third parties is only used to provide you with our services. The specific services are explained further below in the policy.

What is the legal basis for the processing of personal data?
For each specific processing of personal data that we collect from you, you will receive a message from us if:
- the transfer of personal data is required or required by law
- the transfer of personal data is necessary to conclude an agreement
We also indicate what happens if you choose not to provide it.

What rights do you have with regard to your personal data?
You have the right to access:
You have the right to request information about the personal data that we hold about you at any time. You can contact Circle of Gentlemen who will provide you with this personal data by email.

You have the right to portability:
When Circle of Gentlemen automatically processes your personal data on the basis of your consent or on the basis of an agreement, you have the right to receive a copy of your data in a structured, generally used and machine-readable format, transferred to you or to another party. This only applies to the personal data that you provide us.

You are entitled to correction:
You can request Circle of Gentlemen to have your personal data corrected in Circle of Gentlemen's systems if they are incorrect or complete.

You have the right to removal:
You have the right to have the personal data processed by Circle of Gentlemen removed at any time, with the exception of the following circumstances:
- a process with our customer service is still ongoing
- we are still processing an order that has not yet been sent or has been partially sent
- if you have made a purchase on our web store, we will keep your personal data in connection with your transaction for the benefit of accounting regulations.

You have the right to object to processing based on a legitimate interest:
You have the right to object to the processing of your personal data based on a legitimate interest of Circle of Gentlemen. Circle of Gentlemen will not continue to process personal data unless we can demonstrate a legal basis for the process that outweighs your interests and rights or as a result of legal claims.

You have the right to object to direct marketing:
You have the right to object to receiving direct marketing, including profile analysis for direct marketing purposes. Please follow the instructions included at the bottom of every email.

You have the right to restriction:
You can request Circle Of Gentlemen to restrict the processing of your personal data in the following circumstances:
- if you object to processing based on a legitimate interest of Circle of Gentlemen, Circle of Gentlemen restricts any processing of such data pending verification of the legitimate interest.
- if you have submitted a claim that your personal data is incorrect, Circle of Gentlemen must limit any processing of such data pending verification of the accuracy of the personal data.
- if the processing is illegal, you can object to the deletion of your personal data and instead request the restriction of the use of your personal data
- if Circle of Gentlemen no longer needs the personal data, but the personal data is necessary for you to submit defensive legal claims.

How can you exercise your rights?
We are aware that you place trust in us. That is why we have a dedicated customer service that will handle your questions regarding your rights. Please contact us at customerservice@circleofgentlemen.nl.

You have the right to submit a complaint to the supervisory authority:
If you believe that Circle of Gentlemen does not process your personal data correctly, please contact us. You also have the right to submit a complaint to a supervisory authority.

Updates to our privacy statement:
This privacy statement is tailored to the use of our services. Any adjustments and/or changes to this service can lead to changes in this privacy statement. It is therefore advisable to regularly view this website because the latest version of the privacy statement is always available online and updated here.

ONLINE PURCHASE

Why do we use your personal data?
We use your personal data to manage your purchase online at the web store, by processing your orders and returns via our online services and to inform you about the delivery status or any problems regarding the delivery of your items.
We use your personal data to manage your payments.
We also use your data to handle complaints and warranty issues for products.

What types of personal data do we process?
We process the following categories of personal data:
- contact details, such as name, address, email address and telephone number
- order details

Who has access to your personal data?
Your personal data will be forwarded to third parties and will only be used to provide you with your order. Your personal data will be forwarded to our logistics partner to pack and send your order.

What is the legal basis for the processing of your personal data?
The processing of your personal data is necessary to process and deliver your order at Circle of Gentlemen.

How long do we store your personal data?
We keep your data for as long as you are an active customer.

DIRECT MARKETING

Why do we use your personal data?
We only use your personal data to inform you about marketing offers, information surveys and send invitations with emails if you have explicitly consented to this.

What types of personal data do we process?
We process the following categories of personal data:
- all contact details and your email address

Who has access to your personal data?
Personal data is forwarded to our partner for email marketing and is only used for sending emails. We will never forward, sell or exchange your data to/with third parties for marketing purposes.

What is the legal basis for the processing of your personal data?
The processing of your personal data is based on your explicit permission to receive these emails.

The right to withdraw your consent.
You have the right to withdraw your consent at any time for the processing of your personal data and to object to direct marketing. You can opt out through the link at the bottom of every email.

CUSTOMER SERVICE
Why do we use your personal data?
We use your personal data to answer your questions, to handle your product complaints and warranty issues, and to handle your technical support issues via email, telephone or social media.

We can also contact you if there is a problem with your order.

What types of personal data do we process?
We process all data that you provide us, including the following categories:
- contact details, such as name, address, email address and telephone number
- order details
- all correspondence in this area

Who has access to your personal data?

Only employees of Circle of Gentlemen Customer Service have access to the above information.

What is the legal basis for the processing of your personal data?
The processing of your personal data is based on the legitimate interest of Circle of Gentlemen to answer your questions, to handle your product complaints and warranty issues and to handle your technical support issues via email, telephone or social media.

How long do we store your data?
We store your data in connection with telephone and email logs and correspondence for 100 days and your data in connection with case management for 12 months.

COMPETITION/EVENT

Why do we use your personal data?
We process your data when you participate in one of our competitions / events. Your personal data is used by Circle of Gentlemen to contact the participants about the competition / event, to identify the participants, to check the age of the participants, to contact the winners and to supervise the delivery of the prizes.

What types of personal data do we process?
We process the following categories of personal data:
- contact details, such as name, address, email address and telephone number
- age
- information provided for the competition

Who has access to your personal data?
Data can be forwarded to shipping companies, which are used for the delivery of the prizes.

What is the legal basis for the processing of your personal data?
The processing of your personal data is based on your consent when you choose to participate in a competition or event.

The right to withdraw your consent:
You have the right to withdraw your consent at any time for the processing of your personal data. If you choose this, you will no longer participate in the competition or event.

How long do we store your data?
We store your personal data for up to 45 days after the end of the competition.

PRIVACY STATEMENT COMPLIANCE WITH LEGAL OBLIGATIONS

Why do we use your personal data?
We use your personal data to comply with legal obligations, court rulings and decisions of authorities. This includes the use of your personal data to collect and verify accounting data in order to comply with accounting regulations.

What types of personal data do we process?
We process the following categories of personal data:
- client number
- order number
- name
- postal address
- transaction amount
- transaction date

Who has access to your personal data?
Only authorised employees of Circle of Gentlemen have access to the personal data and processes the personal data on behalf of Circle of Gentlemen.
We share your personal data with IT companies that offer solutions for accounting systems.

What is the legal basis for the processing of your personal data?
The processing of your personal data is necessary for Circle of Gentlemen to comply with its legal obligations.

How long do we store your personal data?
We store your data in accordance with accounting regulations.

PERSONAL DATA EMPLOYEES Circle of Gentlemen

Why do we use your personal data?
We use your personal data to implement the employment contract.

What types of personal data do we process?
We process the following personal data:
- name and address
- phone number
- email address
- date of birth
- salary details
- copy ID
- BSN number
- bank details

Who has access to your personal data?
Your data is accessible to the P&O department and is forwarded to relevant bodies such as the pension fund.

What is the legal basis for the processing of your personal data?
The processing of your personal data is necessary for Circle of Gentlemen for the implementation of the employment contract.

How long do we keep your personal data?
During the period that you have a contract and after that in the financial administration for a maximum of 7 years.

COOKIES
A cookie is a small text file that is stored on your computer or mobile device that is retrieved on subsequent visits to our website. If you use our website, we assume that you agree with the use of these cookies.

What do we do with cookies?
We use permanent cookies to store your desired homepage and to save your details if you select "Remember me" when logging in.
We use session cookies if you use the product filter and to check whether you are logged in or have placed an item in your shopping bag.
We use both direct and indirect cookies to collect statistical and user data in analysis tools to optimise our website and to provide you with relevant marketing material.
We collect data for research in order to gain a better understanding of our customers, so that we can tailor our services accordingly.
Some third-party cookies are set by services that appear on our pages and over which we have no control. These cookies are set by social media providers such as Twitter, Facebook and Vimeo and relate to the ability of users to share content on this site, as indicated by their respective symbol.

Removing cookies
Most browsers are set by default to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, it is possible that some functions and services, on our and other websites, will not function correctly if cookies are disabled in your browser. For instructions on handling and removing cookies, look under "Help" in your browser.

What types of personal data do we process?
We only connect your cookie ID with your personal data provided and collected with regard to your account if you are logged in to your account.

How long do we store your personal data?
Circle of Gentlemen does not store your personal data. You can easily remove cookies from your computer or mobile device through your browser. You can choose to disable cookies or to receive a message when a new cookie is sent to your computer or mobile phone. If you choose to disable cookies, you will no longer have access to certain content on the site.

QUESTIONS AND FEEDBACK
We regularly check whether we comply with this privacy policy. If you have any questions about this privacy policy, you can contact our Customer Service. You can reach us by email at customerservice@circleofgentlemen.com or call us on +31 73 22 00 344 during weekdays from 8.30 a.m. to 5 p.m.

Hedel Netherlands, 21 September 2018.

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