PRIVACY POLICY

(Version 7.0, May 2018)

When you make a purchase, write a review on 3count.co.uk or otherwise use our Website, we collect and process personal data about you. This document helps you understand what personal information we collect about you, how we collect it, what we use it for, and what rights you have regarding your personal data.

When we talk about “3count.co.uk,” “we,” “us” or “our,” we mean 3count.co.uk A/S and our affiliates. We also use “Policy” to refer to this Privacy Policy and “Website” to refer to our applications and all of 3count.co.uk’s related websites, social media channels and affiliates.

3count.co.uk A/S is the entity responsible for processing your personal data.

1 Personal data – what we collect and what we use it for

1.1 Master data

When you create an account on the Website 3count.co.uk (“Account”) and collect the following personal data about you (the “Master Data”):

Your full name

Your securely encrypted password

Your email address

Billing / shipping address details

Your order transaction history with us

Your contact phone number

This information is mandatory, which means that it will not be able to make a purchase on the Website without it.

You can choose to add further personal data to your profile. The additional data you can add is your fax number, newsletter subscription and wish list. All of this account information including your master date will not be made public profile unless you choose to write product reviews on our websites.

3count.co.uk has an open review platform and when we display your review we will connect it to your profile so that people can see who wrote the review. Therefore, please be aware that depending on the information you add to the review and your full name, you may or may not be anonymous. Please don’t share any sensitive personal information when writing reviews.

1.2 Information from other services, including social networks like Facebook (future release)

You can connect your 3count.co.uk profile with your profile on social networks, e.g. Facebook, and Google+ (“Social Network(s)”). When you use this option we automatically collect selected information about you from your Social Networks. The information we collect depends on what information you have made available on those Social Networks and your privacy settings for sharing such information on the Social Networks. Depending on your settings and selection, we will collect the following information:

Name and/or username

Email address

Profile photo

Who your social connections are

When you make a request to connect your 3count.co.uk profile with a Social Network profile, you will be informed about which information we will collect from the Social Network in question. You will receive this information before your request is carried out.

You can choose to disconnect your Social Network profile from your 3count.co.uk profile via your Account. At this point, 3count.co.uk will remove your Social Network unique ID, and disconnect/revoke 3count.co.uk from your Social Network. Your profile picture from your Social Network profile will remain on your 3count.co.uk profile.

1.3 Cookies

Our Website uses cookies. Cookies identify your computer or device rather than you as an individual user and are used for different purposes.

Read more about which cookies the Website uses in our cookie policy here.

1.4 Your IP address, browser settings and location

When you visit the Website, we register your computer’s IP address and browser settings. The IP address is the numerical address of the computer used to visit the Website. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of the Website. We also use the IP address to approximate your location (at city level) and so that we know which sets of our Terms & Conditions apply to your use of our Website.

1.5 Newsletters and promotional emails  

We collect the information you provide us with when you subscribe to receive our newsletters, digest emails or similar (we collect your name, email address and where relevant your newsletter preferences). If you no longer wish to receive our newsletters, digest emails or similar, you can unsubscribe by logging into your Account and changing your settings. Or alternatively by clicking on the unsubscribe link at the bottom of each newsletter email or alternatively you can request removal by contacting us at [email protected].

1.6 For what purposes do we use your personal information?

We will use the information you provide to us to:

Provide our services to you, including shipping your order/s to you displaying your reviews, and providing you with access to your account and our Website

Identify you as a registered user when you log in to the Website and re-visit the Website

Verify the legitimacy of your order

Improve the Website and our services

Invite you to leave more product reviews

Respond to your questions and provide related customer service

Send you our newsletters and promotional emails

Facilitate the social sharing function, including giving you the option to connect with members of your network who are both users of 3count.co.uk and users of one or more Social Networks

Engage in various internal business purposes, i.e. data analysis, audits, fraud monitoring and prevention, developing new products and services, improving or modifying the Website, or our services including identifying purchasing trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities

Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards and our internal policies

Enforce our website Terms & Conditions

Protect our operations or those of any of our affiliates

Protect our rights, privacy, safety or property and/or that of our affiliates, you or others

Allow us to pursue available remedies or limit any damages that we sustain

We will also use the information in other ways for which we provide specific notice at the time of collection.

1.7 On what legal basis do we process your personal data?

We need to process your personal information in order to:

Perform our contract with you (see Article 6.1.b of the GDPR)

Comply with our legal obligations (see Article 6.1.c of the GDPR) and operate an online retail platform in compliance with, for example, the Unfair Commercial Practices Directive, ICPEN’s guidelines on online reviews and endorsements, The Consumer Protection from Unfair Trading Regulations 2008.

Pursue legitimate business interests of our own related to operating the Website and providing our products and services to you, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests (see Article 6.1.f of the GDPR).

For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR)

Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal information.

In those limited circumstances where you have expressly given your consent to us to process your personal data (see Article 6.1.a of the GDPR), for example, when subscribing to our newsletters, you are free to revoke your consent at any time. However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.

You have the right to object to how we process your personal information or ask us to restrict the processing. Please see below for more details.

If you would like more information about our legal basis for processing your personal information, please contact our Data Protection Officer (DPO) – see below.

2 Disclosure of personal information

2.1 Disclosure of personal information on the Website

We do not disclosure your any of your personal information to the public unless you have chosen to write a public product review. This can reveal your identity in full or in part – unless you use a pseudonym.

We recommend that you exercise care in deciding which information you choose to include in the review body as this will be disclosed publicly on the Website and be aware that depending on the level of information provided, you may or may not be anonymous.

Master Data and other information

When you write a review on our Website and create an Account, your full name will be visible on the Website. All other Master data associated to your personal profile will not be disclosed.

Geo-location

When you write a review on the Website, we use your computer’s IP address (see 1.7 of this Policy, above) to approximate your location to the nearest city. This information is made available to other users of the Website.

2.2 Disclosure on services to which you connect your profile

If you choose to connect your 3count.co.uk profile with your profile on a Social Network, information provided by you on the Website or data compiled by us about your use of the service on the Website (e.g. you order history) will not be shared and displayed in connection with your profile on the Social Network.

2.3 Disclosures

In addition to the above, we disclose your personal information to the following parties and in the following circumstances:

To allow third party vendors, consultants and other service providers to perform services on our behalf

To Offset Media subsidiaries and other website within the 3count.co.uk group of companies

To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities

To cooperate with regulatory bodies and government authorities, including but not limited to Trading Standards Authority.

To third parties in connection with enforcement of our Terms & Conditions and Guidelines

To third parties in order for us to protect our operations or those of our affiliates

To third parties in order for us to pursue available remedies, or limit damages that we may sustain

To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our Website

To a third party in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).

3 Data controller

3.1 Information for which we are the data controller

We are the data controller of the Master Data. We are also the data controller of the information which is disclosed to other services.

3.2 Information for which you are the data controller

You are the data controller for the content you choose to disclose on the Website in product reviews, and for the personal data disclosed when you connect your Social Network profile(s) with your profile on the Website.

4 Links to websites

Our Website contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third-party websites and assume no responsibility for the third party or their policies or practices.

We encourage you to review the privacy policies for these third-party websites because their procedures for collecting, handling and processing personal data will be different from ours.

5 Data processors and transfer of personal information outside the EU

We use external companies to maintain and provide services of a technical nature for the Website and our associated services. These companies are data processors for the personal data for which we are the data controller. By accepting this Policy, you agree that we may also allow the data for which you are the data controller to be processed by these data processors.

We have data processing agreements in place with the data processors and it follows from these agreements that they must act solely in accordance with our instructions. By accepting this Policy, you authorize us to instruct the data processors to process data in accordance with the Policy and for the purposes of using the Website.

The data processors have taken reasonable technical and organizational measures to protect against the information being accidentally or illegally destroyed, becoming lost or deteriorating, and to protect against the information being disclosed to unauthorized persons, being misused, or in other ways being processed in violation of data protection laws.

On your request – and possibly in return for remuneration at the data processors’ applicable hourly rates at any time for such work – the data processors must supply you with sufficient information to demonstrate that the above-mentioned technical and organizational safety measures have been taken.

Some of these data processors and third-party services are located outside of the European Union, such as in the US. You consent to us using data processors in unsecure third countries provided that there is a legal framework governing the transfer of your personal data and ensuring adequate protection of it, for example if the data processor is part of the EU-US Privacy Shield framework.

6 Data retention

We keep the Master Data and other personal data you provide, including your reviews, for as long as you have an Account or as needed to provide you with our services. If you choose to delete your Account, please note that your order history will also be deleted. We will delete this information upon your request and we will only save a log with the following information: your name, email address and the date of the deletion of your Account. We will keep the log for 3 years. All other information will be deleted.

7 Security measures

We use reasonable organizational, technical and administrative measures to protect your personal information within our organization and we regularly audit our system for vulnerabilities. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of the information you transmit to us. Emails sent via the Website may not be encrypted, and we therefore advise you not to include any confidential information in your emails to us.

We are always working to improve our security practices and we will update this information as these practices evolve over time.

8 Access and insights into the personal data we have about you

If you have an Account on 3count.co.uk, you can log in to your Account and see what information we have about you, including your order history, and why we have that information.

If you don’t have an Account, you can email [email protected] and request information about your personal data. Upon receiving your request, we will let you know what personal information we have about you, how we collect the information, the purpose for which we process your personal data, and who we share your personal information with.

9 Correction and deletion of your personal data

If any of the Master Data or other personal information that we have about you in our capacity as a data controller is incorrect or misleading, you can correct most of the information yourself via your Account. We recommend that you make any the correction(s) yourself. Otherwise, you are welcome to ask us to assist with correcting your information.

You may at any time correct or delete any content and personal information on the Website for which you are the data controller (see 3.2). If you no longer wish to have an account on the Website, you can request for us to close and delete the information via email.

If your Account is deleted, all the data associated with your Account will be deleted, including your Master Data and reviews on the Website.

We reserve the right to block access to your Account and/or delete it if the Account or the content associated with your Account or your order history and review(s) on the Website is, in our assessment, discriminating, racist, sexually oriented, unethical, threatening, offensive, harassing or otherwise violates applicable laws, third party rights or our User Guidelines, or is inconsistent with the purpose of the Website. If we block access to or delete your Account, we will inform you of the reason for blocking or deleting your Account by sending an email to the address you provided when you created your Account.

10 Other rights

In addition to the rights set out above concerning your personal data, you also have the following rights:

You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.

In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.

If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing of data carried out before you withdrew your consent. You may withdraw your consent by emailing us at [email protected].

In some circumstances, these rights may be limited or conditional. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.

11  Children’s information

Our Website is not intended for children. If you become aware that a child under the age of 12 has provided us with their personal information, please contact us.

12  Our Data Protection Officer

We have a Data Protection Officer (DPO). If you have any questions about the data processing activities performed by us, you are welcome to contact our DPO by email at: [email protected].

13 Changes to this Policy

We reserve the right to make changes to this Policy. The date shown at the start of this Policy indicates when it was last revised. If we make material changes to it, we will provide notice through our Website, or by other means, to give you the opportunity to review the changes before they come into effect. If you object to our changes, you can close your account. Your continued use of our Website after we publish or send a notice about the changes to the Policy will mean that you accept and agree to the updated Policy.

14 Contact information and where to send questions or complaints

If you have questions or concerns about our Policy, how we process your personal information, or would like us to correct your personal information, feel free to contact us at: [email protected].

You can also reach us by post.

Our contact details are:

3 Count – Wrestling Merchandise,

“Stanmaur” Quakers Walk
London N21 2DE
United Kingdom

3 Count - Wrestling Merchandise
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