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PRIVACY POLICY FOR DORMY

1 DORMY SAFEGUARDS YOUR PRIVACY

Dormy Golf & Fashion Aktiebolag, company no. 556486-7637, (“Dormy”) ensures that your personal data is processed in a secure manner with a high level of protection and in accordance with applicable data protection legislation.

This privacy policy describes how Dormy processes personal data and applies to our website Dormy.com (the “Website”), when you purchase goods and services from Dormy, when you make contact with Dormy and for members of Dormy Club. Depending on your relationship with Dormy, only certain parts of this Privacy Policy may apply to you.

If you have any questions about Dormy’s privacy protection, you are always welcome to contact us. Dormy's contact details are shown below under the heading “Contact information”.

2 PERSONAL DATA CONTROLLER

Dormy is the personal data controller for the processing of your personal data and is therefore responsible for ensuring your data is handled in a correct and secure way in accordance with applicable legislation.

For sales outside Sweden, the sale is made via a local Dormy company. In Netherlands, Spain and Ireland the sale is made via Dormy Golf International AB Sweden (“Dormy International”). Dormy is, together with Dormy International, the joint data controller for the processing of personal data about you as a customer and/or member of Club Dormy. We have organised the joint personal data responsibility so that the processing of your personal data is always done in a secure manner. If you have any questions or comments about the processing of personal data that occurs under this joint personal data responsibility or wish to exercise your rights as a data subject (see more details under the heading “Your rights” below), you can always contact Dormy (see contact information below under the heading “Contact information”).

3 WHAT PERSONAL DATA DOES DORMY PROCESS?

Personal data is all information and any kind of information that can be directly or indirectly attributed to a living person. It is information about you and your person. Examples of personal data are name, contact details, pictures of you and your IP address.

Processing refers to any type of action taken with personal data such as the collection, storage, use, processing and transfer of personal data.

As a rule, your personal data is collected directly from you, e.g. via email, our social media or other communication channels, or, where applicable, from the company or organisation you represent. Dormy may also receive personal data about you from other companies within the group that Dormy is part of or from Dormy's other partners. Dormy may also use external information services to supplement existing information, e.g. with position and contact information, if necessary.

3.1 Customers

Dormy collects and stores the following information about you that Dormy needs in order to be able to contact you and fulfil Dormy's commitments to you as a customer.

  • Personal and contact information, such as name, national identity number, address, telephone number and email address.
  • Information you provide to Dormy by email, through our social media channels or through other communication channels.
  • Payment and purchase history.
  • Payment information, such as bank details, account number and, where applicable, IBAN, SWIFT, etc.
  • Information about complaints and warranty cases.
  • Data from customer surveys and customer evaluations.
  • Where applicable, details of telephone calls with Dormy’s switchboard or customer service. <br>

3.2 Dormy Club Members

  • Personal and contact information, such as name, national identity number, address, telephone number and email address.
  • Information you provide to Dormy by email, through our social media channels or through other communication channels.
  • Payment and purchase history.

3.3 Company representatives for e.g. customers, suppliers and partners

Dormy collects and stores the following information about you that Dormy needs in order to contact representatives of a company or organisation.

  • Personal and contact information, such as name, address, telephone number, email address, title, occupation and employer.
  • Information you, as a company representative, provide to Dormy by email, through our social media channels or through other communication channels.
  • Where applicable, details of telephone calls with Dormy’s switchboard or customer service.
  • Where applicable, information on dietary preferences, possible allergies and/or disabilities (e.g. due to company events or meetings).

3.4 Potential customers and company representatives of potential customers, suppliers and partners

Dormy may collect and store the following information about you as a potential customer of Dormy or as a company representative of a potential customer, supplier or partner of Dormy.

  • Personal and contact information, such as name, address, telephone number, email address, title, occupation and employer.

3.5 Visitors to Dormy's website

When you visit the Website, we collect the following information about you that Dormy needs in order to improve, streamline, simplify and develop our website.

  • Technical data, such as IP address, MAC address, URL, unique device ID, network and device performance, browser, language and identification settings, geographical location, operating system, other data from cookies or similar mechanisms (device information).

4 OUR PROCESSING OF YOUR PERSONAL DATA

The purposes for which we intend to process your personal data and the legal basis for each processing instance are set out in the table below.

Purpose

  1. Manage orders, deliveries and other commitments to you as a customer.
  2. Receive payment when purchasing Dormy products, services and facilities.
  3. To meet regulatory requirements, such as security and accounting requirements.
  4. To enable marketing and communication about Dormy’s brand and Dormy’s products (e.g. sending newsletters and other marketing materials, invitations to Dormy’s events, meetings and other gatherings, etc.).
  5. Address and compensate customers for complaints, warranty cases and service matters.
  6. Manage customer service matters, in addition to complaints and warranties, as well as other service matters.
  7. Keeping in touch with a representative of the customer (when the customer is a company), the supplier or the partner (e.g. when the delivery of goods or services is to take place or in case of complaints, warranty cases and service cases).
  8. To conduct surveys regarding Dormy products and customer buying experience.
  9. To analyse purchase history in order to offer customers the right products and marketing.
  10. Provide joint functions within the Dormy Group, such as marketing and finance.
  11. To improve the quality of Dormy’s switchboard and customer service.
  12. To ensure the operation of the Website and Dormy’s other websites and to be able to develop such websites to better adapt them based on how they are used. <br>

Legal basis

  1. The processing is necessary to fulfil the contract with the customer.
  2. The processing is necessary to fulfil the contract with the customer.
  3. The processing is necessary to meet Dormy’s legal obligations.
  4. The processing is necessary for Dormy’s legitimate interest in marketing our brand, goods and other similar goods to you as a customer or to the company that you as a company representative represent (balance of interests).
  5. The processing is necessary to fulfil the contract with the customer. <br>
  6. The processing is necessary for Dormy's legitimate interest in assisting customers and potential customers in matters other than complaints and guarantees (balance of interests).
  7. The processing is necessary for Dormy's legitimate interest in having contact with you for the purpose of fulfilling the contract with the company that you represent (balance of interests).
  8. The processing is necessary for Dormy’s legitimate interest in evaluating, developing and improving its brand, products and marketing (balance of interests).
  9. The processing is necessary for Dormy’s legitimate interest in offering its customers relevant marketing with regard to the customer’s previous purchases (balance of interests).
  10. The processing is necessary for Dormy’s legitimate interest in operating, developing and improving the Dormy Group, the brand and our products and services (balance of interests).
  11. The processing is necessary for Dormy's legitimate interest in quality assurance and ensuring efficient management of the switchboard and customer service (balance of interests).
  12. The processing is necessary for Dormy's legitimate interest in improving, streamlining, simplifying and developing its website and in order to attract more customers/partners and to increase the proportion of recurring customers/partners (balance of interests). <br>

5 DORMY CLUB MEMBERS

For Dormy Club members, in addition to the processing of your personal data carried out in your capacity as a customer, we will process your personal data for the purposes and on the legal basis set out below.

Purpose

  1. Administer your Dormy Club account and provide you with access to the services associated with Dormy Club, for example, to provide you with information about and process your purchases on the Website, to provide offers and other benefits related to your personal membership, and to collect and analyse information about your purchases, which we base on offers and marketing of both a general and targeted nature
  2. To send invitations for events and celebrations.

Legal basis

  1. Processing is necessary to fulfil the Dormy Club membership agreement (Member Terms & Conditions).
  2. The processing is necessary for Dormy’s legitimate interest in marketing our brands, products and other similar goods to you as a customer (balance of interests).

6 SPECIFIC INFORMATION ABOUT DIRECT MARKETING AND PROFILING WITHIN DORMY CLUB

6.1 Direct Marketing

Dormy will process your personal data for marketing purposes. Your details may be used for direct marketing, newsletters, customer surveys and for statistical purposes and can be used to send direct mail, email and text messages to you up until the point when you close your account or decline further communication. You can choose through which channels you wish to be contacted by Dormy at any time by changing your settings on the Website or by contacting customer services.

6.2 Profiling

Dormy will process your personal data in order to analyse your purchase history, your purchasing behaviour and your behaviour on the Website in order to gather more knowledge about you as a customer and our customers in general and in order to improve our offers (profiling). For the same purposes, we may also process any personal requests or preferences you have given us, e.g. information that you are interested in a particular product category. We do this by analysing which purchases you have made previously and which products you have looked at or placed in your cart on the Website. Based on this information we are able to send you specific offers. By agreeing to this privacy policy you hereby also consent to the profiling of your personal data.

7 SOCIAL MEDIA

With regard to the personal data that is shared and processed on social media, we refer users to the respective service’s policy for information about how they process personal data. According to Dormy, the purpose of the processing is for representatives of existing customers, potential customers and partners of Dormy to be able to interact and have contact with Dormy via social media. This is to facilitate good relationships with customers and partners and to make Dormy’s customer service and product easily accessible through multiple channels. The processing is necessary for Dormy's legitimate interest in marketing its brand and products to existing and potential customers as well as to partners (balance of interests).

8 HOW LONG DO WE STORE YOUR PERSONAL DATA?

Your personal data will be stored for as long as there is a need to retain it in order to fulfil the purposes for which the data was collected in accordance with this Privacy Policy. After that, your data will be deleted.

Certain personal data will, for the purpose of complying with relevant accounting legislation, be retained for seven years, counted from the end of the calendar year in which the financial year to which the information belonged, ended.

Contact details of company representatives are stored for the time Dormy deems the data necessary for maintaining the relationship with the company/organisation. Deletion shall take place when Dormy becomes aware that the information is no longer adequate or relevant for the purpose, or at the request of the contact persons.

As a Dormy Club member, your personal data is stored for as long as you remain a member. Information about your purchases is only stored for 60* months after the latest purchase. You can contact us at any time and cancel your membership and ask that we remove your personal data.

For more information about how long Dormy stores specific personal data, please contact Dormy. Contact details are shown below under the heading “Contact information”.

*Reasons that we might store data about your purchases for 60 months after your last purchase is that our products are durable goods with a longer lifespan. To provide you with the best service even after your latest purchase we have chosen this time horizon.

9 WHO DOES DORMY SHARE YOUR PERSONAL DATA WITH?

Dormy does not share any personal data with third parties, except in situations where this is required to comply with a legal obligation or to fulfil Dormy’s obligations to you, customers and/or partners. Your personal data will not be sold to third parties for advertising purposes.

The table below lists situations in which your personal data may be shared with third parties.

Third Party

Other companies within the Dormy Group

Personal data may need to be transferred to other companies within the group because central functions such as marketing and finance are managed jointly within the group to which Dormy belongs.

Cloud service provider

Personal data may be disclosed to cloud service providers as Dormy stores certain information in cloud services.

Suppliers and partners

Dormy may share your personal data with different suppliers and/or partners if such suppliers or partners need your personal data in order to carry out their tasks for Dormy.

Companies that provide financing solutions for customers

In cases where a customer is interested in a financing solution for their purchase, Dormy shares information about the customer to financing companies that Dormy cooperates with, who in turn enter into agreements and communicate directly with the customer.

Authorities

Personal data may be provided to authorities when required to comply with legal obligations.

Disposal

If Dormy intends to transfer all or part of Dormy’s business, personal data may be shared with a potential buyer.

10 TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

Dormy strives to process your personal data within the EU/EEA. If your personal data is transferred to a country outside the EU/EEA, Dormy will take the necessary measures to ensure that the transfer of the personal data is legal and that your personal data is processed in a secure manner and with a level of protection equivalent to that within the EU/EEA, for example by entering into the EU Commission’s standard contract clauses with the recipient.

11 YOUR RIGHTS

A summary of your rights under applicable law is shown in the table below.

Right of access

You have the right to access your personal data and to obtain a copy of the personal data relating to you that Dormy processes.
Right to correction If the personal data that Dormy processes about you is inaccurate, incomplete or out of date, you have the right to ask us to correct it.

Right to erasure

You have the right to request that we delete your personal data. If Dormy does not have a legal basis to continue processing the personal data, it must be deleted.

Right to object

In certain circumstances, you have the right to object to Dormy processing your personal data.

Right to restrict processing

In some cases, you have the right to require that Dormy restrict the processing of your personal data. This means that only under certain conditions may Dormy process the personal data in a manner other than by storing it.

Right to data portability

Where the personal data is processed with your consent or under contract with you, you have the right to obtain your personal data in a machine-readable format and transfer the personal data to another controller.

Right to withdraw consent

If Dormy processes your personal data on the basis of your consent, you can withdraw your consent to allow us to process your personal data at any time. However, the withdrawal does not affect the lawfulness of Dormy’s personal data processing that was carried out before the consent was withdrawn.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint about Dormy’s processing of your personal data with the Swedish Authority for Privacy Protection, Box 8114, 104 20 Stockholm, Sweden, or with another relevant national data protection authority. Contact details for the data protection authorities within the EU/EEA can be found here.

You can always contact Dormy to exercise your rights as described above (see contact information below under the heading “Contact Information”).

12 DORMY'S WHISTLEBLOWER SCHEME

Acting ethically and taking action to prevent irregularities is an important part of Dormy’s culture. Dormy’s whistleblower scheme aims, as a complement to the company’s other risk management measures and control functions, to create ample opportunity to catch unethical or illegal behaviour.

Examples of irregularities to report: Fraud or questionable accounting, violations of law or regulatory requirements, pressure on employees to break the law, our policies or regulatory requirements, unethical relationships with business partners or colleagues and discrimination against employees, various forms of harassment.

Irregularities should be reported to [email protected]. All messages to this address go directly to an external whistleblower manager, who has a good level of knowledge about Dormy but at the same time is independent and thus free to act on the information provided. The whistleblower manager must confirm receipt and then reply with information about the investigation within seven days. If the reporting person wishes to report verbally, this is notified in the report and an agreement on making a verbal report is drawn up. When reporting verbally, the information is documented by the whistleblower manager.

All the personal data of the person reporting a concern and the accused/purported party/parties will be treated in strict confidence and in accordance with the General Data Protection Regulation (GDPR).

13 THE PROTECTION OF YOUR PERSONAL DATA

Sie sollten sich immer sicher fühlen, wenn Sie Ihre personenbezogenen Daten mit uns teilen. Dormy hat daher die notwendigen Sicherheitsmaßnahmen ergriffen, um Ihre personenbezogenen Daten vor unbefugtem Zugriff, Veränderung oder Löschung zu schützen. Wir werden Ihre Daten nur dann an Dritte weitergeben, wenn dies in dieser Datenschutzrichtlinie ausdrücklich vorgesehen ist.

14 COOKIES

Dormy uses cookies-like technologies in order to provide certain features of the Website, to improve the Website and to deliver a better and more personalised service. The information is stored in the form of a file containing encrypted login data. Dormy uses cookies in accordance with Dormy’s cookies policy.

15 IF YOU DO NOT PROVIDE YOUR PERSONAL DATA TO DORMY

If you do not provide your personal data to Dormy, Dormy will not be able to fulfil its legal or contractual obligations to you.

16 CHANGES

Dormy has the right to change the Privacy Policy at any time. In the event of changes to this Privacy Policy, Dormy will post the amended Privacy Policy on the Website with details of when the changes will take effect. Dormy may also inform customers and partners appropriately.

This Privacy Policy has been set by Dormy as of 05/02/2024.

17 CONTACT INFORMATION

Please do not hesitate to contact Dormy if you have any questions about this Privacy Policy, the processing of your personal data or if you wish to exercise your rights under this Privacy Policy or applicable law.

Dormy Golf & Fashion AB

Company no. 556486-7637

Postal address: Salamandervägen 29, 702 36 Örebro, Sweden

Telephone: +4619-20 95 00

Email: [email protected]