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1. Identity and contact details of the controller

2. Contact details of our data protection officer

3. Data processing for fulfilling of contract and correspondence

4. Data processing for customer care

5. Careers

6. E-mail newsletter and advertising

7. Website

8. Cookies and similar technologies

9. Social media plugins

10. Recipients of data

11. Storage period

12. Your rights

13. Right to withdraw and right to object

14. Website security

15. Updates to the privacy policy

In this Data Protection Notice we are informing you of the way in which your personal data are processed when you use our website and order via our online shop, by phone or via email.

Personal data comprise information referring to an identified or identifiable person. They include particularly all information making it possible to conclude your identity, for instance your name, telephone number, address or e-mail address. Statistical data, which we collect for example when someone visits our website, do not fall under the meaning of personal data.

You can print or save this privacy policy by using your browser’s usual functions.

1. IDENTITY AND CONTACT DETAILS OF THE CONTROLLER

The so-called controller for the processing of your personal data under the General Data Protection Regulation (“GDPR”) is

Hurlingham Polo 1875
2 Hardman Boulevard
Manchester
M3 3AQ

(hereafter “Hurlingham Polo 1875“, “we“ or “us“)

BY EMAIL

info@hurlinghampolo1875.com

2. CONTACT DETAILS OF OUR DATA PROTECTION OFFICER

If you have any questions concerning data privacy regarding our products or the use of this website, you can also contact our data protection officer at any time:

Data Protection Coordinator
Hurlingham Polo 1875
2 Hardman Boulevard
Manchester
M3 3AQ
UK

Or email info@hurlinghampolo1875.com

3. DATA PROCESSING FOR FULFILLING OF CONTRACT AND CORRESPONDANCE

3.1 ORDER AND SHOPPING DATA

When you order via our online shop, by phone or via email we collect your order and shopping data. Order and shopping data include, for example:

• details about the items you ordered, such as model, size, colour, price, etc.

• delivery and billing address

• returns, exchanges and replacement items

• if you wish to collect from store

• sales ID

• customer ID

• delivery status (“sent” or “returned”)

We process your data to fulfil your order, to deliver your order and to handle returns and exchanges if applicable.

When we process your data in this way, we call upon the legal basis of "the performance of a contract" (Art. 6 (1) b) GDPR).

3.2 MY ACCOUNT

When you order via our online shop you can register or create a customer account. For registration the following data is required:

• e-mail address

• self-chosen password

After you created your account you can log into at “MY ACCOUNT” using your e-mail address and password.

We process your data so you can view and manage your details, your wishlist, your shopping bag your current orders and your payment details.

When we process your data in this way, we call upon the legal basis of "the performance of a contract" (Art. 6 (1) b) GDPR).

3.3 YOUR CONTACT DETAILS AND CORRESPONDANCE

You can provide your telephone numbers so that we can contact you quickly if there is a query on your order. This is voluntary.

The legal basis for the above mentioned data processing is Art. 6 (1) a) GDPR.

You can contact us using e-mail, the contact form, live-chat or mail. We process your data including content of you messages solely to communicate with you, e.g. to solve any problems or concerns you may have.

When we process your data in this way, we call upon the legal basis of "the performance of a contract" (Art. 6 (1) b) GDPR).

To assist with training and to maintain and improve our customer service we sometimes record incoming telephone calls. However this is voluntary.

If you do not wish the call to be recorded please tell the agent as soon as your call is answered.

The legal basis for the above mentioned data processing is Art. 6 (1) a) GDPR.

3.3.1 LUCKY ORANGE

Our website uses the Lucky Orange chat program, a service of Lucky Orange, 8680 w. 96th Street, Suite 200, Overland Park, KS 66212  (“Lucky Orange") to improve communication with visitors.

You can ask questions via live chat. For example about our products or if you have problems with your order.

In this context we process your data solely to communicate with you.

When you use the live chat, the IP address of the device and the address of the subpage from which you access our website are recorded.

When we process your data in this way, we call upon the legal basis of "the performance of a contract" (Art. 6 (1) b) GDPR).

For further information please refer to Lucky Orange’s Privacy Policy.

3.4 PAYMENT DATA

You can pay your order by card or Paypal, in some locales bank transfer and invoice are also available.

Depending on the chosen payment method we securely transmit your payment data to the assigned bank or the payment service provider assigned by us.

When we process your data in this way, we call upon the legal basis of "the performance of a contract" (Art. 6 (1) b) GDPR).

4. DATA PROCESSING FOR CUSTOMER CARE

4.1 COMPETITIONS AND SURVEYS

If you take part in one of our surveys, we shall use your data for market and opinion research. We shall use them only in anonymised form and for internal purposes.

Insofar in the exceptional case as data are not evaluated anonymously, such data will be collected only with your consent.

GDPR does not apply to anonymous surveys.

In the exceptional case of evaluations with a personal reference the legal basis is the said declaration of consent under Art. 6 (1) a) GDPR .

In the course of competitions we shall use your data to run the competition and to notify the winner(s).

You will find detailed notes in any Terms & Conditions of Participation for the competition in question.

When we process your data in this way, we call upon the legal basis of "the performance of a contract" (Art. 6 (1) b) GDPR).

5. CAREERS

You can see our current vacancies under "CAREERS".

The purpose of the data collection is that of applicant selection for providing possible employment.

If you want to apply please send your CV to: info@hurlinghampolo1875.com

When we process your data in this way, we call upon the legal basis of "the performance of a contract" (Art. 6 (1) b) GDPR).

For further information please refer to privacy policy for applicants.

6. EMAIL NEWSLETTER AND ADVERTISING

6.1 EMAIL NEWSLETTER

You have the possibility of ordering our Email Newsletter, in which we tell you regularly of the latest news about our products and campaigns.

We shall store your e-mail address, the time of registration and the IP address used for the registration for such time until you cancel the Newsletter.

This storage serves only the purpose of sending you the Newsletter and being able to provide your registration.

If you do not wish to receive any further email messages from us, please write to us at

Data Protection Coordinator
Hurlingham Polo 1875
2 Hardman Boulevard
Manchester
M3 3AQ
UK

Or click the unsubscribe link in the newsletter or email us at info@hurlinghampolo1875.com.

When we process your data in this way, we call upon the legal basis of "the performance of a contract" (Art. 6 (1) b) GDPR).

In our Newsletter we use technologies usual in the market by which the interactions with the Newsletter can be measured (e.g. opening of the e-mail, links clicked).

We use these data in pseudonymised form for general statistical evaluations and to optimise and develop our contacts and customer communication further.

This is done with the aid of graphics which are embedded in the Newsletter (so-called pixels). This data is collected only in pseudonymised way, and in addition the data once collected are not combined with your personal data.

The legal basis for the above mentioned data processing is our foregoing legitimate interest under the terms of Art. 6 (1) f) GDPR

We wish via our Newsletter to share subjects with our customers which are of maximum relevance to them and to understand better what our readers are actually interested in.

If you do not wish your user pattern to be analysed, you can cancel the Newsletter or disable graphics in your e-mail program in a standard way.

We wish via our Newsletter to share subjects with our customers which are of maximum relevance to them and to understand better what our readers are actually interested in.

If you do not wish to receive any further email messages from us, please write to us at

Data Protection Coordinator
Hurlingham Polo 1875
2 Hardman Boulevard
Manchester
M3 3AQ
UK

Or click the unsubscribe link in the newsletter or email us at info@hurlinghampolo1875.com.

7. WEBSITE

7.1 FEEDBACK TO OUR WEBSITE

You can give us feedback about our website. We process your experiences during your visit of our website, your name and your e-mail address.

The legal basis for the above mentioned data processing is Art. 6 (1) a) DSGVO.

7.2 USE OF OUR WEBSITE

Every time our website is used, we collect the access data which your browser automatically transmits to make your visit to the website possible.

These access data comprise in particular:

• IP address of enquiring device

• Date and time of enquiry

• Address of the website called up and of the website enquiring

• Information on the browser and operating system used

• Online identifiers (e.g. device identifiers, session IDs)

The processing of these access data is necessary in order to make the visit to the website possible and to ensure the permanent functionality and security of our systems.

The access data are in addition saved for the foregoing purposes in internal logfiles, in order to develop our website further with regard to the usage patterns of our visitors (e.g. if the proportion of mobile devices on which the pages are called up rises) and in order to administer our website in a general way.

The legal basis for the above mentioned data processing is Art. 6 (1) b) DSGVO.

The information saved in the logfiles allows no direct conclusion to be drawn about you as a person – in particular, we save the IP addresses only in abbreviated, anonymised form.

The logfiles are saved for 30 days and archived following subsequent anonymisation.

8. COOKIES AND SIMILAR TECHNOLOGIES

Please see our Cookie Policy here.

9. SOCIAL MEDIA PLUGINS

Our website uses social-media plug-ins ( “Plugins”) of the social network Facebook and Google+.

Facebook is operated by Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA ("Facebook").

An overview of the plugins of Facebook and their appearance can be found here.

Should personal data be transmitted to the USA, Facebook has acceded to the EU-US Privacy Shield.

Google+ is operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

An overview of the plugins of Google and their appearance can be found here.

Should personal data be transmitted to the USA, Google has acceded to the EU-US Privacy Shield.

When visiting a page of our website that contains such a plugin, your browser creates a direct connection to the servers of the providers.

The content of the plugin is transmitted by the providers directly to your browser and integrated into the page.

By this integration the providers receive the information that your browser has called up the corresponding page of our website, even if you do not have an account with the respective provider or are not currently logged in there.

This information (including your IP address) is transmitted directly from your browser to a server of the respective provider in the USA and stored there.

If you are logged in with the provider, the provider can immediately assign the visit of our website to your account.

If you interact with the plugins, for example by clicking the "Like" button or making a comment, this information is also transmitted directly to a server of the respective provider and stored there.

The information is also published on your account and displayed to your friends or followers.

The purpose and scope of the data collection and the further processing and use of the data by the providers as well as your relevant rights and setting options for the protection of your privacy can be found in the data protection information of the providers:

Privacy Statement of Facebook.

Privacy Statement of Google.

If you do not want Google or Facebook to associate the data collected via our website directly with your profile in the respective service, you must log out of the respective service before activating the plugins.

You can also completely prevent individual plug-ins from loading with add-ons for your browser, e.g. the Facebook plug-ins with the "Facebook Blocker".

The legal basis of the above mentioned data processing is Art. 6 (1) f) GDPR, based on our justified interest in you sharing our contents via social media and in our expanding our reach in this way.

10. RECIPIENTS OF DATA

Data which we have collected are passed on only if:

• You have given an express declaration of consent for this, pursuant to Art. 6 (1) a) GDPR,

• Further transmission is necessary, pursuant to Art. 6 (1) f) GDPR, for bringing, exercising or defending legal claims, and no reason exists to suppose that you have a predominant and properly protected interest in preventing your data from being passed on,

• We have a legal duty to pass on your data pursuant to Art. 6 (1) c) GDPR, or

• This is legally permissible and requisite, pursuant to Art. 6 (1) b) GDPR, for the handling of contracts with yourself or for the execution of precontractual actions which are being carried out at your request.

A part of the data processing may be effected through via service providers.

Along with the service providers stated in this Data Protection Notice, these may include in particular computer centres which store our website and databases, IT service providers which maintain our system, and consultancy firms.

Should we pass data on to our service providers, this data may only be used for performance of their tasks.

We select and commission these service providers carefully.

They are bound contractually to follow our instructions, have suitable technical and organisational measures for the protection of the rights of data subjects, and are monitored by ourselves on a regular basis.

Further transmission may also be made in connection with requests by government authorities, decisions of the courts and legal proceedings if it is necessary for prosecution or execution at law.

11. STORAGE PERIOD

We store personal data only for as long as is necessary to fulfil contractual or statutory duties for which the data were collected.

We then erase the data immediately, unless we still need these data until expiry of the statutory period of limitation for purposes of evidence in civil claims or due to statutory duties of storage.

For purposes of evidence we must still store contact data for five years from the end of the year in which business relations with you end.

Any claims will expire, under the normal statutory period of limitation, no earlier than at this time.

Thereafter we must also store some of your data for purposes of book-keeping.

We have an obligation to do so under statutory duties of documentation which may arise.

12. YOUR RIGHTS

Under the respective legal requirements you have the following legal data privacy rights:

• Right of access (Art .15 GDPR)

• Right to erasure (Art. 17 GDPR)

• Right to rectification (Art. 16 GDPR)

• Right to restriction of processing (Art. 18 GDPR)

• Right to data portability (Art. 20 GDPR)

To exercise your rights as described above, you may at any time contact us using the contact details mentioned under "IDENTITY AND CONTACT DETAILS OF THE CONTROLLER”.

You also have the right to lodge a complaint with a supervisory authority responsible for us.

You may also exercise this right before a supervisory authority in the member state you are staying, working or the location of alleged infringement.

In UK the supervisory authority responsible is:

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

You can exercise this right at a regulatory authority in the member country of your place of residence, of your workplace, or of the place of alleged breach.

13. RIGHT TO WITHDRAW AND RIGHT TO OBJECT

Under Article 7 (3) GDPR you have the right to withdraw your consent given to us at any time.

This will have as a consequence that in future we no longer continue the data processing based on this consent.

Through this revocation of consent the legality of the processing carried out until the said revocation will not be affected.

Insofar as we process your data on the basis of legitimate interests under Art. 6 (1) f) GDPR, you have the right under Article 21 GDPR to object to processing of your data insofar as grounds exist arising from your particular situation or the objection is directed towards direct advertising.

In the latter case you have a general right of objection which will also be implemented by us without your stating reasons.

If you wish to make use of your right to withdraw or object, a notification without set form to the contact details mentioned under " IDENTITY AND CONTACT DETAILS OF THE CONTROLLER” will be sufficient.

14. WEBSITE SECURITY

The security of your personal details is our utmost concern - that is why we have taken a number of measures to ensure your details are protected.

We use the most up to date security system and our site is regularly scanned for vulnerabilities by a third party to ensure it remains secure.

We don't keep your details online, our website uses a SSL encrypted secure internet connection to protect your personal and payment details.

This means all the details you supply and any responses are encrypted before they are sent over the internet.

If you are still not confident shopping via the internet, please email on the email address provided under “IDENTITY AND CONTACT DETAILS OF THE CONTROLLER“.

15. UPDATES TO THE PRIVACY POLICY

We may update this privacy policy from time to time, for example when we adapt our website or legal requirements change.

© Hurlingham Polo 1875 – Version: 1.0

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