Privacy Notice

1. Who we are

KJK Sports is a sporting goods company focused on the active outdoor sporting goods segment with existing investments in Elan Group (winter sports and sailing), Tahe Outdoors Group (water sports), Leader 96 and Baltik Vairas (bicycles).

2. What personal data are we collecting, how we will treat them, what purposes we collect them for and what is the legal basis for their processing

Data type	Personal data	What are we using it for	Legal basis for the processing
Contact details	Name, Company, Address, City, Country, Telephone	Contact for inquiries	Consent
Cookies	IP address	To help analyze how visitors use the website	Consent

You provide us with your personal data for the purposes of concluding a contract with you or to complete the order you make with us on any of our websites or in stores, which means that you are obliged to provide us with such data as your contractual obligation or obligation for the purposes of concluding a contract. If you do not provide us with this personal data, we might not be able to fully or in part provide you with our services connected thereto.

In case you decide to provide us with your personal data for the purposes of direct marketing, we will process them on the basis of your consent which you can at any time revoke as described below.

COOKIES

Cookies are small files stored on your device (PC, smartphone, etc.) to remember specific, related device information. They are used to improve your website experience (for example, storing login data). Second, they collect statistical website data and analyzes them in order to improve your experience. You can influence the cookie’s behavior. Most browsers can limit the storage of cookies or completely prevent the use of cookies entirely. However, user experience without cookies will be reduced.

Learn more about many US online ad cookies at: http://www.aboutads.info/choices/ or for the EU countries here: http://www.youronlinechoices.com manage.

GOOGLE ANALYTICS

The Services uses Google Analytics, a web analytics service provided by Google Inc. ( „Google“). Google Analytics uses Cookies, text files which are stored on users‘ computers, to help analyze how visitors use the Services. The information generated by the Cookie are usually transmitted to a Google server in the USA and stored there.

If IP anonymization is used on the Services, the IP address will be truncated within Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. The IP-anonymization is active on this website. On behalf of the operator of this website, Google will use this information to evaluate the site users, to compile reports on website activity, and other website and internet related activities to the Vendor.

It is generally understood as part of Google Analytics that your IP address will not be merged with other data from Google. The user may refuse the use of cookies with its browser settings; However, disabling the Cookies will affect the performance of Vendor’s Services. The user can also prevent the data generated by the Cookie about your use (incl. Your IP address) from being sent to Google and the processing of these data by Google, by going to the following link to download and install the browser plugin: https://tools.google.com/dlpage/gaoptout.

3. Information sharing

However, we may share your personal data with trusted third parties that perform business functions or provide services to us (for example for the purposes of delivery of our products). All such third parties will be required to adequately safeguard your personal data, subject to agreements that correspond to the requirements of applicable laws. Your personal data may also be shared for investigations (e.g. disclosure to prevent crime or fraud, or to comply with a court order or legislation).

4. Security measures and data retention

In our company, different security measures are in place, such as premises access control (24-hours surveillance, limited access into the buildings, locking and blocking the doors and gates), electronic documents control and measures to prevent data revealing.

Your personal data will be stored for the entire period of our contractual relationship and until you or us could have any claims deriving from such relationship or until we are required to do so by relevant legislation or authorities. Personal data processed on the basis of your consent will be deleted upon your revocation of such consent.

5. International transfers of personal data

Your personal data will not be transferred to third countries, unless so required in order to provide you with our services (for example to deliver the ordered products). Given the above, we will make sure that the data will only be transferred to trusted third parties in countries outside the European Economic Area whose laws may not afford the same level of protection of your personal data. Where necessary, KJK Sports will ensure that adequate safeguards are in place to comply with the requirements for the international transfer of personal data under applicable privacy laws. For transfers of personal data outside the European Economic Area, KJK Sports will use Commission approved mechanisms, such as the Privacy Shield certification, and Standard Contractual Clauses as safeguards, such as the “(EU-)controller to (Non-EU/EEA-)controller” Decision 2004/915//EC (see Article 46 GDPR).

6. Your rights

You have the following rights in relation to your personal data and their processing:

• right to access – means you may ask us whether or not we process any of your personal data and, if so, receive access to that data in the form of a copy and get additional information in relation thereto;
• right to rectification – means You have the right to have your data rectified in case of inaccuracy or incompleteness;
• right to erasure – means that you can, in cases listed under Article 17 of the GDPR, request us to delete your personal data, and we will, to the extent possible make sure, that these data is also delete by other controller which have been provided with your information;
• right to restriction of processing – means we can temporarily stop the processing of your personal data, for example in cases where the accuracy of your personal data was contested but some time is needed for us to verify their (in)accuracy.
• right to object – means that in case we process your personal data on the basis of our legal interests (as defined in point 2 above), you can object to such processing and request we stop such processing; and
• right to data portability – means you can request us to provide you with your personal data in a structured, commonly used and machine-readable format and to have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible we will transmit your personal data directly to the other controller.

The above-mentioned rights can be enforced in line with the Regulation (EU) 2016/679 of European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”).

7. Right to revoke the consent to processing

Where the legal basis for the processing of your personal data is your consent, you can at any time revoke this consent by sending us the wish on revocation by using the contact details below.

Revocation of the consent for processing does not influence the legality of processing made up until the date of revocation.

8. Right to file a complaint with the supervisory authority

You also have the right to file a complaint with the supervisory authority.

Its contact details are:

Commission Nationale pour la Protection des Données
1, avenue du Rock’n’Roll
L-4361 Esch-sur-Alzette
Tel. +352 2610 60 1
Fax +352 2610 60 29
e-mail: info@cnpd.lu

You can also file a complaint with your local supervisory authority, which you can find on this list.
The above mentioned right can be enforced in accordance with the GDPR.

9. Updates to this notice

This notice was last updated on September 3, 2019 and it replaces all previous versions. We will update this notice from time to time and inform you on any important changes. We suggest you review this notice from time to time in order to be informed on the latest version of the notice.

10. Contact details

KJK Sports
9, rue Jean-Pierre Sauvage
L-2514 Luxembourg

Or you can contact KJK Sports via contact form on the website.