1. THE COLLECTED DATA AND THEIR USE

Collection of your personal data

We collect various personal data from the customers of our webstore as well as other unregistered users of our website. We collect customer data from customers of our webstore, such as:

• First and last name
• Contact details
• We collect other customer data from customers of our webstore, such as:
• Information relating to purchases and claims
We collect identification data when contacting our customer service by email, and we may process the following personal data:
• First and last name
• Contact details
• IP address
• Communication between you and the customer service
• Other information you have disclosed in the reference
We also collect technical data from all the users of our website, such as:
• IP address
• Operating system and device;
• The products searched for on our website, page history of our website and other possible analytics data.
When you visit our website the technical data collected from you cannot be linked to you. The technical data may, however, be linked to your IP address whereupon the data in considered to be personal data. We collect the majority of the customer data when you become a loyal customer or when you buy products in our webstore. In order for your information to be up to date, we may update your personal data by exploiting public registers, updating services or the information relating to your orders.

Legitimate grounds for processing of your personal data and purposes of processing

We process your data to pursue our legitimate interest to run our business operations, improve your customer or visitor experience and conduct direct marketing. We do not, however, use your data for direct marketing purposes without your consent. We process your personal data in order to fulfill the contractual obligations based on the customer relationship when you buy products in our webstore. We process your personal data for the following purposes:
• In order to maintain the customer relationship, such as in order to inform you about our web services and products.
• In order to handle payment transactions
• In order to target marketing
• In order to develop the quality of our web services by analyzing for instance the products you have viewed and purchased, the feedback you have provided and the sections you have visited.

2. STORAGE OF YOUR DATA

Storage and transfer of your data
Headstrong may disclose information relating to customers (such as name and email) to advertising network service providers in order to conduct targeted marketing. The recipient of the personal data is in that case Headstrong’s authorized service provider which processes the personal data transferred by Headstrong in order to offer marketing services to Headstrong. Our advertising network service providers may store the data outside of the EU/EEA. If personal data is transferred outside the EU/EEA, we will ensure that appropriate contractual measures (e.g. using standard contractual clauses of the EU Commission) are applied to the transfer, the transfer is lawful and that the processing and confidentiality are in compliance with the applicable laws. Headstrong does not transfer your personal data outside of our organization apart from the following situations:
• You have given your consent to the transfer
• The transfer is based on law
• The personal data is transferred to an authorized service provider of Headstrong and the terms of processing of personal data have been agreed with the service provider

Erasure of your data

We store the personal data relating to your purchases and claims as long as it is necessary for instance for legal claims or for complying with bookkeeping and legal obligations. The analytics data of our website are stored for 26 months. An example of analytics data are the products you have searched for on our website. You may, at any time, unsubscribe from our mailing list and prohibit us from sending you electronic direct marketing.

3. YOUR RIGHTS

Your right to receive your data. You have the right to know which data relating to you is processed by Headstrong. In addition, you may require us to provide you with a report regarding the following matters:
• Why is your data processed
• Who we have disclosed your data to or who we plan to disclose your data to
• How long we store your data If it is not possible to communicate the accurate storage time, we will inform you about the criteria for defining the storage time. Such criteria may be based for instance on a certain law or industry-specific instructions.

Your right to rectify your data

If the data relating to you is incorrect you have the right to require the rectification of such data. You may ask us to rectify your data by contacting our customer service the contact details of which are set forth in section 4 of this privacy statement.

Your right to require the erasure of your data

If the data relating to you is incorrect you have the right to require the rectification of such data. You have the right to ask us to erase your data. You may ask us to erase your data by contacting our customer service the contact details of which are set forth in section 4 of this privacy statement. If you ask us to erase your personal data, we aim at erasing all data relating to you as soon as possible. We store your data despite your erasure request only if there is a legitimate ground to store the data, such as a legal obligation.

Right to object and limitation of processing

You have the right to object to processing of your data or profiling when your data is used for direct marketing. You have the right to require the limitation of processing of your personal data for instance when the data relating to you are incorrect. In addition, you have, in certain special circumstances, the right to object the processing of your personal data based on your particular situation. You may invoke your objection and limitation rights by contacting our customer service the contact details of which are set forth in section 4 of this privacy statement.

Right to transfer your data from one system to another

You have the right, at your discretion, to transfer your data to another organization. If you wish to transfer the data from one system to another, Headstrong will disclose such data to you in a structured and electronic format. In case you have further questions regarding the above right, you may contact our customer service. The contact details of our customer service are set forth in section 4 of this privacy statement.

Your right to lodge a complaint

You have the right to lodge a complaint with the competent national supervisory authority if you find the personal data processing activities of Headstrong to be non-compliant with data protection legislation.

4. Contact details

If you have a request, notification or you have something else to ask regarding the processing of personal data, you may contact our customer service in the following ways: • by sending an email to the address support@Headstrong.eu

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