At Airofin Athletic Limited we are aware of the trust you place in us and our responsibility to protect your information.

This privacy policy is designed to inform you and help you understand how we collect and use your personal data in the following circumstances:

• your use of our website, airofin.com (Website), including any data you provide when you purchase products on our Website; or
• if you are a retailer advertising and selling your products on our Website.

We keep our privacy policy under regular review and reserve the right to amend or modify this privacy policy at any time, including in response to changes in applicable data protection and privacy legislation. This version of the policy was last updated on 18 June 2021.

It is important that you read our privacy policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Our privacy policy is provided in a layered format so you can click through to the specific areas set out below:

Who we are and how to contact us

What information we process and how we use it

What the information is used for

Marketing

Who we share your information with

Where personal data is stored and transferred

How long we will keep information about you

Your rights in relation to your personal data

Your requirement to provide information

Third Party Links

How to complain

 

1 – Who we are and how to contact us

Airofin Athletic Limited (Airofin, we, us, or our) is the controller and responsible for your personal data. 

 

2 – What information we process and how we use it

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.

It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.

We only collect, use and store your information where we have a lawful basis to do so. We currently collect and process the following types of personal data about you:

• Name
• Title
• Date of birth
• Billing address and delivery address
• Email address and telephone numbers
• Bank account and payment card details
• Details about payments to and from you and details of products you have purchased from retailers on our Website
• Profile data, including your username and password for your account, purchases or orders made by you, your interests, preferences, feedback and survey responses
• Technical data, including your internet protocol address, your login data, browser type and version
• Information about how you use our Website, products and services
• Your preferences in receiving marketing from us and our third parties and your communication preferences

Information collected from you

Where we have collected information directly from you it will usually be obvious what this is, as you will have given it to us. However, we use different methods to collect personal data from and about you including:

• Through direct interactions, including where you:
  • create an account on our Website;
  • subscribe to our marketing;
  • correspond with us by post, phone, email or otherwise;
  • fill in forms on our Website;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.

• Where you are a retailer on our Website. In this case, we will collect personal data about you that you provide to us through direct interactions, or which your employer provides to us as part of our contractual arrangements or as otherwise set out in the table below.

• Through automated technologies or interactions. As you interact with our Website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this data using cookies and other similar technologies. Please see our Cookies Policy for further details.

Cookies

You can set your browser to refuse all or some browser cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy.

We collect IP addresses to monitor who is accessing our website as well as to detect and prevent fraudulent activity.

Information collected from others

We also obtain information about you from third parties who may sometimes provide us with personal information, as set out below:

• our payment services providers;
• our retailers;
• if you are a retailer on our Website, PayPal;

Such information will only be obtained from reputable sources which operate in accordance with the General Data Protection Regulation (GDPR).

3 – What the information is used for

We have identified four lawful bases which we use to collect and process data. Explanations of each of these are provided below, and beneath the title of each section regarding what the information is used for we have listed the lawful basis which is applicable to that purpose.

‘Contract’ – the information is needed to perform the contract we are about to enter into or have entered into with you (including where necessary to manage your account, product or service)

‘Legal obligation’ – where we need to comply with a legal obligation or we are required by law to process your information e.g. to verify your identity

‘Legitimate interest’ – where it is necessary for our legitimate interests (or those of a third party) and on balance, your interests and fundamental rights do not override our legitimate interests

‘Consent´- in some cases we may obtain your consent to use information in a particular way or where the law requires consent to be obtained

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely upon to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity	Type of personal data	Lawful basis for processing
Website users (including customers)
To register you as a new customer	Name, email address, date of birth, telephone number	Necessary for our legitimate interests (in order to recognise you as a customer when you return to our Website and to provide you with excellent customer service, to allow you to keep track of the orders you make through our Website)
To facilitate your order, including:   ·       Disclosing your order and delivery details to the retailer you have selected to purchase goods from; ·       Facilitating payments, fees and charges; ·       Facilitating any refunds and/or returns you may request	Name, address (billing and shipping), email address, date of birth, telephone number	Performance of a contract with you
To manage our relationship with you which will include:   ·       Notifying you about changes to our terms or privacy policy; ·       Asking you to leave a review or take a survey	Name, email address, date of birth, telephone number	Necessary to comply with a legal obligation   Necessary for our legitimate interests (to study how customers use our products/services)
To manage your customer account	Name, address (billing and shipping), email address, date of birth, telephone number	Necessary for our legitimate interests (to ensure that the status of your orders and information is up-to-date and accurate and to deal with any queries you may have)
To enable you to partake in a prize draw, competition or complete a survey	Name, email address, date of birth, telephone number	Performance of a contract with you   Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Retailers
To on-board you and register you with an account as a retailer on our Website	Name, address, company registration number (if applicable), VRN (if applicable), email address, telephone number	Performance of a contract with you
Administering the contract we have with you (including managing invoices and any disputes)	Name, address, company registration number (if applicable), VRN (if applicable), email address, telephone number	Performance of a contract with you   Necessary for our legitimate interests (to ensure that we take appropriate steps to protect ourselves in the event of a dispute)
To manage our relationship with you	Name, address, company registration number (if applicable), VRN (if applicable), email address, telephone number	Necessary for our legitimate interests (to ensure our relationship is managed effectively)
Website users, customers and retailers
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	IP addresses	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To use data analytics to improve our website, products/services, marketing, relationships and experiences	IP addresses, cookies	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)

 4 – Marketing

Marketing emails, social media content and messages

We may contact you about products or services that relate to products that you currently hold with us, products you have held in the past, or products you have expressed an interest in. You will receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted-out of receiving that marketing.

We will never contact you about products that are not similar, and if you receive calls or post that you do not wish to receive, you can ‘opt-out’ at any point, by sending an email to info@airofin.com.

5 – Who we share your information with

When using the information we hold we may share it with other people or organisations for the purposes set out above:

• Service providers that help us to run and maintain our Website and provide IT and administration services, such as hosting providers including Shopify;
• Payment service providers, to enable you to pay for the products purchased from retailers;
• Retailers you are purchasing products from;
• Professional advisers, including lawyers, bankers, auditors and insurers who provide professional services to us;
• HM Revenue and Customers, regulators and other authorities, who require reporting of processing activities in certain circumstances; and
• Third parties to whom we may choose to sell, transfer or merge parts of our business or 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’ll treat the information we hold as confidential and may share information with the above who are also required to keep your information confidential, safe and secure.

6 – Where personal data is store and transferred

We do not anticipate that we will need to transfer your data to countries outside the UK and the European Economic Area (EEA). However, if we do need to transfer your personal data outside the UK and the EEA we will take all steps reasonably necessary to ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your personal data.  Please contact us if you wish to find out more; if we ever transfer your personal data outside the EEA you can ask us for a copy of the relevant safeguards implemented in relation to the transfer.

7 – How long we will keep information about you

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.  We may keep your personal data for longer in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, and the applicable legal, regulatory, tax, accounting or other requirements.

We will also retain data in an anonymous form for statistical and analytical purposes after this date, without further notice to you.

8 – Your rights in relation to your personal data

The right to be informed

The right to be informed requires us to provide you with information about the purpose of us collecting and processing your personal data, how long we keep the information for, and who we will share this information with. This document has been created in order to provide you with this information. If you have any further queries about anything contained within this document, please contact our Compliance Officer whose details can be found at the bottom of this page.

The right of access

This right enables you to ask us to confirm whether or not we process personal data about you, and if we do, certain information about the processing, including what the information is, why we’re holding it and the ways in which we use it. You also have a right to request a copy of this information. You can exercise this right by contacting our Compliance Officer whose details can be found at the bottom of this page.

The right to rectification

This right allows you to request any inaccurate or incomplete personal data we hold on you is rectified. Should anything be inaccurate or incomplete, please contact us and we will make any corrections necessary, although note that we may need to verify the accuracy of any new data you provide to us.

The right to erasure

This right allows you to ask us to erase or delete information where you consider there is no longer any justification for us continuing to process it, either because:

• The personal data is no longer necessary in relation to the purposes for which we collected it
• We processed your personal data based on your consent, which you have now withdrawn and where there is no other lawful basis for us to process your data
• You have previously objected to a way in which we use information
• We have been using the information unlawfully
• There is a legal obligation on us to erase the information

Please note that we may not always be able to comply with your request for erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

The right to restrict processing

This right allows you to request a restriction on the way your personal data is processed by us where:

• You have challenged the accuracy of the personal data we hold and we are in the process of verifying this
• You have objected to our use of your personal data but we are considering whether our legitimate interests override your objection
• We have been processing your information unlawfully but you want us to restrict the use of your personal data rather than erase it
• We no longer need the information for the purposes of processing but you have asked us to hold it because of legal claims you’re involved in

The right to data portability

This right allows you to request a copy of the personal data you provided to us in a structured, commonly-used, machine-readable format. You have the right to receive this information yourself, or transfer to a third party. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.

The right to object

This right allows you to object to the way in which your data is processed. This right is only applicable where we have confirmed that the lawful basis used in order to process your data is based on our  ‘legitimate interests’ or those of a third party and in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.

Withdraw consent

You have the right to withdraw consent at any time where we are relying on consent to processing your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

What we may need from you and time limits

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. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9 – Your requirement to provide information

Where you do not provide the personal information we need in order to provide the service you are asking for, or under the terms of a contract we have with you or in order to fulfil a legal requirement, and you fail to provide that information where requested to do so, we will be unable to provide the service you have requested, or may be unable to perform the contract we have or are trying to enter into with you.

We will tell you why we need the information when we ask for it, and notify you if this is the case at the time.

10 – Third Party Links

Our Website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control those third party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

11 – How to complain

If you are unhappy with any way we are using your personal information, you should first contact us so we can understand your issue and try and resolve it. 

Email: infoe@airofin.com