Effective July 22, 2020
1.1 E. Arthur Brown Company, Inc. (“EABCO”) owns and manages the https://www.eabco.com website (the “Website”). EABCO sells online through the Website, and through other distribution channels, various firearms, parts, accessories and related products described on the Website (“Products”).
1.2 We are committed to safeguarding the privacy of individuals who visit our Website or otherwise provide their personal data to us.
1.5 In this policy, “we”, “us", “our” and “EABCO” refer to E. Arthur Brown Company, Inc. [For more information about us, see Section 17.]
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of data that we may (i) process using automated technology and/or (ii) analyze through non-automated review (such processing and analysis are referred to in this document generally by the noun “Processing” and the verb “Process”);
(b) the purposes for which we may Process or disclose data; and
(c) the legal bases of the Processing.
2.2 We may Process data about your use of our Website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Website navigation paths, as well as information about the timing, frequency and pattern of your visits to our Website. The source of the usage data is our analytics tracking system. This usage data may be Processed for the purposes of analyzing the use of the Website. The legal basis for this Processing is your consent. A separate and independent legal basis for this Processing is completing orders for Products that you place with us.
2.3 We may Process your order data ("order data"). The order data may include your name, physical address, telephone number, email address, payment information, and other similar information that you submit to us over the Website, in addition to information about the Products you purchase from us. The order data may be Processed for the purposes of operating our Website, facilitating your purchase of Products, shipment to you of the Products, keeping proper records of those transactions, ensuring the security of our Website, maintaining back-ups of our databases, and communicating with you. The legal basis for this Processing is your consent. A separate and independent legal basis for this Processing is completing orders for Products that you place with us.
2.4 We may Process information contained in any enquiry you submit to us regarding our Products or your purchases from us ("enquiry data"). The enquiry data may be Processed for the purposes of facilitating the shipment to you of Products you have purchased or are seeking to purchase. The legal basis for this Processing is your consent. A separate and independent legal basis for this Processing is completing orders for Products that you place with us.
2.5 We may Process information contained in or relating to any communication that you send to us ("communication data"). The communication data may include the communication content and metadata associated with the communication. The communication data may be Processed for the purposes of communicating with you, updating you regarding our Products, and record-keeping. The legal basis for this Processing is your consent.
2.6 We may Process, and if we deem necessary disclose, any of your data identified in this policy when appropriate for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. We may also disclose your data to law enforcement or administrative authorities. The legal basis for this Processing and/or disclosure is your consent. A separate and independent legal basis for this Processing and/or disclosure is our legitimate interests, namely the protection and assertion of our legal rights, obligations and business interests, your legal rights, and the legal rights and obligations of others.
2.7 We may Process any of your data identified in this policy when necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this Processing is your consent. A separate and independent legal basis for this Processing is our legitimate interests, namely the proper protection of our business against legal, financial and other risks.
2.8 In addition to the specific purposes for which we may Process your data set out in this Section 2, we may also Process any of your data when such Processing is necessary for compliance with any legal obligation to which we are subject.
3. Providing your data to others
3.1 We may disclose your data to any employee or agent of EABCO who is responsible for activities related to completing the steps necessary to ship your purchases, communicate with you and respond to your enquiries, and manage and operate our Website.
3.2 We may disclose your data to third party sub-processors that provide services related to the operation and performance of our Website.
3.4 We may disclose your data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. We may also disclose your data to law enforcement or administrative authorities on request.
3.5 In addition to the specific disclosures of data set out in this Section 3, we may disclose your personal data when such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your data when such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your data
4.1 In this Section 4, we provide information about the circumstances in which your data may be transferred to countries outside the European Economic Area (“EEA”) if you reside within the EEA.
4.2 We are based in the U.S., and our processors are based in the U.S. We will not transfer your personal data, if you reside in the EEA, outside the U.S. and any EEA country.
5. Retaining and deleting data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of data.
5.3 Notwithstanding the other provisions of this Section 5, we may retain your data when such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of EasyExport or another natural person.
6. Security of data
6.1 We will take appropriate technical and organizational precautions to secure your data and to prevent the loss, misuse or alteration of your personal data.
6.2 We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
6.3 You acknowledge that the transmission of unencrypted or inadequately encrypted data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.4 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our Website confidential. We will not ask you for your password (except when you log in to our Website).
7. Your rights
7.2 If you are located in the EEA your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict Processing - you can ask us to restrict the Processing of your personal data;
(e) the right to object to Processing - you can object to the Processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organization or to you;
(g) the right to complain to a supervisory authority - you can complain about our Processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our Processing of your personal data is limited only to your consent, you can withdraw that consent.
The rights listed in this Section 7 are subject to our obligations to comply with U.S. and international laws and regulations regarding purchases you have made from us and/or consents you have previously provided to us. If we are required by U.S. or international laws and regulations to retain personal data that you consented to provide to us in connection with purchases you previously made from us, you will not be able to withdraw that consent after the purchases have been completed.
7.3 If you are located in the EEA you have the right to confirmation as to whether or not we Process your personal data and, when we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the Processing, the categories of personal data concerned and the recipients of the personal data. Provided the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 If you are located in the EEA you have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the Processing, to have any incomplete personal data about you completed.
7.5 If you are located in the EEA, in some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise Processed; you withdraw consent to consent-based Processing; you object to the Processing under certain rules of applicable data protection law; the Processing is for direct marketing purposes; or the personal data have been unlawfully Processed. However, there are exclusions of the right to erasure. The general exclusions include when Processing is necessary for compliance with a legal obligation, or for the establishment, exercise or defense of legal claims.
7.6 If you are located in the EEA, in some circumstances you have the right to restrict the Processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; Processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our Processing, but you require the personal data for the establishment, exercise or defense of legal claims; and you have objected to Processing, pending the verification of that objection. When Processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise Process it: with your consent; for the establishment, exercise or defense of legal claims; in compliance with a legal obligation; for the protection of the rights of another natural or legal person (for example, the operators of EasyExport); or for reasons of important public interest.
7.7 If you are located in the EEA you have the right to object to our Processing of your personal data on grounds relating to your particular situation, but not to the extent that the legal basis for the Processing is that the Processing is necessary for: the performance of a task carried out in the public interest or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will provide you with a written explanation describing the legitimate grounds for the Processing which override your interests, rights and freedoms, or explaining that the Processing is for the establishment, exercise or defense of legal claims.
7.8 If you are located in the EEA you have the right to object to our Processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If we Process your personal data for direct marketing purposes and you make such an objection, we will cease to Process your personal data for this purpose.
7.9 If you are located in the EEA you have the right to object to our Processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the Processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our Processing of your personal data is:
(a) consent; or
(b) that the Processing is necessary for the performance of a contract between you and us or in order to take steps at your request prior to entering into a contract,
and such Processing is carried out by automated means, if you are located in the EEA you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply when it would adversely affect the rights and freedoms of others.
7.11 If you consider that our Processing of your personal data infringes data protection laws, you may contact us directly so that we have an opportunity to address your concerns. You also may have a legal right to lodge a complaint with a supervisory authority responsible for data protection. If you are in an EU member state, contact the Data Protection Authority in your country, your country of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our Processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of Processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us.
8. Third party websites
8.1 Our Website includes hyperlinks to, and details of, third party Websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
9.1 Our Website and services are not directed at children. We do not knowingly collect information from persons under 16 years of age. Please notify us if you are under 16 years of age and provide us with evidence of the consent of your adult parent or legal guardian before making any purchases on our Website.
9.2 If we have reason to believe that we hold personal data of a person under 16 years of age in our databases, we will delete that personal data except when retention of some or all of that personal data is necessary for compliance with a legal obligation to which we are subject, or in order to protect that person’s interests or the vital interests of another natural person. We may also retain such personal data when such retention is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in administrative or out-of-court procedures.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either persistent cookies or session cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
13. Cookies used by our service providers
14. Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
14.2 Blocking all cookies will have a negative impact upon the usability of many Websites.
14.3 If you block cookies, you will not be able to use all the features on our Website.
15. Cookie preferences
16.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
16.3 We may notify you of significant changes to this policy by email or by a notice on our Website.
17. Our details
17.1 This Website is owned and operated by E. Arthur Brown Company, Inc.
17.2 We are registered in the United States of America.
17.3 You can contact us by asking for our Data Privacy Manager:
(a) by telephone at the contact number published on our Website; or
(b) by mail at the following address: Privacy Manager, E. Arthur Brown Company, Inc., 4088 County Road 40 NW, Garfield, MN 56332;
(c) by email at email@example.com