Privacy Policy

Privacy Policy

Welcome to Dirbie’s privacy policy. Dirbie respects your privacy and is committed to protecting your personal data.

 

  1. A Brief Introduction

This privacy policy tells you how Dirbie use your personal data when you visit our website, interact with us, and buy our goods and services. It also tells you about your privacy rights and how the law protects you. It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data. This privacy policy was last updated on 24th of March 2022. If you have any questions, or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See How to contact Dirbie about privacy below.

 

  2. Our website

Our website at dirbie.com and respective subdomains sell golfing garments and accessories aimed at golfers. This website is not intended for children and we do not knowingly collect data relating to children. Dirbie is constituted as this single legal entity as follows: VALLERRET AS, Bavallsvegen 48, 5710 Skulestadmo, Voss, Norge. CAAST HOLDING AS (data controller) is responsible for securing all personal data collected by or on behalf of Dirbie.

 

  3. The Information we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We collect a variety of information about our customers and visitors to the Dirbie website. This personal data falls into these categories:

Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website, products and services.

Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.

Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. To provide better content and service, Dirbie's website uses SumoMe web analytics service. SumoMe records mouse actions and scrolling movement, as well as basic interactions with website forms. SumoMe does not track your browsing habits across other third-party websites and the service collects no personal data about you.

 

  4. How is your personal data collected?

We use different methods to collect data from and about you including through: Direct interactions You may give us your data by ordering a product or corresponding with us by email or through chat or social media. This includes personal data you provide when you:

• sign up to receive the Dirbie Newsletter;
• create an account on our website;
• order our products or services;
• engage with us on social media;
• enter a competition, promotion or survey;

Automated technologies or interactions As you interact with us, including via the dirbie.com website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on third party websites).

Third parties or publicly available sources We may receive personal data about you from various types of third parties, including:

• Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers such as Google Analytics;
• Contact, Financial and Transaction Data from providers of payment and fraud prevention services;
• Identity and Contact Data from data partners; and
• Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.

We will only use your personal data when the law allows us to.

 

  5.  How we use your personal data

• Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the check-out process.
• Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.

 

6. How to Access or Correct your communication preferences

We may use your personal data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you and tell you about them. This is what we call direct marketing. We may carry out direct marketing by email. For example, you might have the Dirbie Newsletter hit your inbox with a cool promotion regarding a certain product. On our website, we work hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to the Dirbie Newsletter or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and say no thank you and opt out. The easiest way to opt out is to use the "manage preference" link or "unsubscribe" link at the bottom of the communication.  

 

7. Marketing without using your personal data

Of course, there are lots of different ways you may see adverts for Dirbie out and about, and not all of these are based on using personal data – sometimes it is simply advertising space on websites and social media. If you see Dirbie’s adverts on other websites and in social media, these may not be directed specifically at you, we might just have bought the space or the website may be an assigned affiliate partner. We work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media. Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new customers of Dirbie. The cookies used for this purpose are often placed on our website by specialist organisations – like Facebook and Instagram etc. This includes retargeting.

 

  8. Why and How we use Cookies

Cookies are a tool which we (and everyone one else who operates online) uses for a smooth consumer experience and for advertising. Cookies help dirbie.com work better and provide lots of help in the background to make the process of being a Dirbie customer a lot easier. You’d miss a lot of these things if they were gone – like it being easy to log in and move from page to page, and things staying in your cart while you go off and look at other pages. There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests. They are usually placed by advertising networks (like Facebook, Google etc.) with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation. All the cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the Digital Advertising Alliance (United States), the Digital Advertising Alliance of Canada and the European Interactive Digital Advertising Alliance. We do not control cookies which are set by advertising networks. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

  9. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it. We may share personal data with the following categories third parties:

• Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);
• auditors and professional advisers like bankers, lawyers, accountants and insurers; and
• government, regulators and law enforcement.

We also share data with third parties connected to advertising, retargeting and analytics. We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

  10. Payment information

Dirbie uses third party payment processors Shopify Payments, Stripe and PayPal to process payments made for products and services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!) and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors - Dirbie never sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page. For Shopify Payments and Stripe Payments, if on the payment page you have requested that your card details be remembered and the payment was successful, Dirbie stores the card type, a Masked PAN (only the first 6 and last 4 digits) and the card’s expiry date as well as an associated token. We store this information so that you and we can identify your stored card and use it for further payments at dirbie.com. This stored information can be deleted via the payment form on the Website should you wish to do so. For PayPal we only store the tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.

 

  11. How we protect your data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  12. How long we keep your data

We will only keep your personal data for as long as necessary to fulfill the purposes we collected it for, 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 unauthorized 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, and the applicable legal requirements. By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers for tax purposes. In some circumstances you can ask us to delete your data; see Your legal rights below for further information. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

13. International transfer of data

Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are: The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission. We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”). 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 and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses. We share your personal data withinVALLERRET AS, which will involve transferring your data outside the European Economic Area. Many of our external third-party providers are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.

  14. Your legal rights

If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:

• The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing that in this privacy policy);
• The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
• The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
• The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal
• reason we need to keep it);
• The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
• The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
• The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
• Rights in relation to automated decision-making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.

If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager on support@dirbie.com

 

  16. How to contact Dirbie regarding your data

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at support@dirbie.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. If you need help about our products and services, or this website generally, please contact us at support@dirbie.com

 

  17. Changes to this privacy policy

The General Data Protection Regulation is new and the ICO is still issuing new bits of guidance about how businesses should follow it. So, you may see little updates to our privacy policy over the coming months. Be sure to check in and have read every now and then.

Thank you. Now back to the fun Golfing stuff.

© Dirbie 2022