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Privacy policy
Effective Date: 22-09-2025
Last Updated: 22-09-2025
Austin Gamble V.O.F. values your privacy and handles your personal data carefully, securely, and transparently in accordance with the General Data Protection Regulation (GDPR).
1. Data Controller
Austin Gamble V.O.F.
Registration Number (KvK): 94226466
VAT ID: NL866683951B01
Email: contact@austingamble.com
Phone: +31 6 43472464
Address: Dennenweg 161, 7545WD Enschede, Netherlands
2. What Personal Data Do We Process?
We only process personal data that is necessary for our services.
Contact Information
- First and last name
- Email address
- Phone number
- Billing and shipping address
Order and Transaction Data
- Ordered products and services
- Order dates and purchase history
- Payment information processed by external payment providers
- Invoice data
Technical Data
- IP address
- Browser type and version
- Device information
- Website behavior and preferences
- Cookies and similar technologies
Communication Data
- Correspondence via email, phone, or contact forms
- Customer service chat conversations
- Review and feedback data
3. Processing Purposes and Legal Basis
| Purpose | Legal Basis | Retention Period |
|---|---|---|
| Processing and fulfilling orders | Performance of contract (Art. 6(1)(b) GDPR) | 7 years |
| Customer service and support | Performance of contract and legitimate interest | 7 years |
| Newsletter and marketing communications | Consent (Art. 6(1)(a) GDPR) | Until withdrawal of consent |
| Legal obligations VAT and accounting | Legal obligation (Art. 6(1)(c) GDPR) | 7 years |
| Fraud prevention and website security | Legitimate interest (Art. 6(1)(f) GDPR) | 2 years |
| Website analysis and optimization | Consent or legitimate interest | 26 months |
| Processing contact forms | Consent or legitimate interest | 2 years |
| Customer reviews via WebwinkelKeur | Legitimate interest | According to WebwinkelKeur policy |
| Localisation and Markets EU languages | Legitimate interest (Art. 6(1)(f) GDPR) | 2 years |
| Territorial scope enforcement EU-only delivery | Legitimate interest (Art. 6(1)(f) GDPR) | 2 years |
4. Data Sharing with Third Parties
We share your data exclusively with trusted partners that are necessary for our services. Data Processing Agreements are in place with all processors in accordance with Article 28 GDPR. Data is not processed outside the EU without adequate protection measures.
Payment Processing
- Mollie B.V. Netherlands for secure payment processing
- Shopify Payments where applicable
- Other certified EU payment providers
Shipping and Logistics
We fulfil orders only to delivery addresses within EU member states.
- Carriers: PostNL Netherlands and DHL within the EU, and where needed other EU-based carriers
- Purpose: shipping, tracking updates, delivery notifications, and returns handling
- We do not ship to non-EU countries. Orders to non-EU delivery addresses are not accepted
IT Services
- Shopify Inc. e-commerce platform
- EU hosting providers
- Cloud service providers with GDPR compliance
- IT security services
Professional Services
- Accounting and administration
- Legal advisory when necessary
Marketing and Analytics
- Google Analytics with privacy settings
- Email marketing tools such as Klaviyo or similar
- Social media platforms for advertising based on your consent and settings
Reviews - WebwinkelKeur
We collect reviews via the WebwinkelKeur platform. If you leave a review via WebwinkelKeur, you are required to provide your name and email address. WebwinkelKeur shares this data with us so we can link the review to your order. WebwinkelKeur also publishes your name on their own website. In some cases, WebwinkelKeur may contact you to provide clarification on your review.
In the event that we invite you to leave a review, we share your name and email address with WebwinkelKeur. They use this data solely for the purpose of inviting you to leave a review. WebwinkelKeur has implemented appropriate technical and organizational measures to protect your personal data. WebwinkelKeur reserves the right to engage third parties for the purpose of providing services, for which we have given permission to WebwinkelKeur. All the above safeguards regarding the protection of your personal data also apply to the parts of the service for which WebwinkelKeur engages third parties.
5. Cookies and Tracking Technologies
Essential Cookies
- Shopping cart functionality
- Login credentials and sessions
- Security and fraud prevention
- Website performance and stability
Analytics Cookies (with consent)
- Google Analytics for website statistics
- Heatmaps and user behavior analysis
- A/B testing for website optimization
Marketing Cookies (with consent)
- Social media integrations
- Personalized advertisements
- Retargeting and remarketing
- Affiliate tracking
You can manage your cookie preferences through our cookie banner or by contacting us.
6. International Data Transfers
We primarily process your data within the EU or EEA. For certain services, data may be transferred to countries outside the EU with adequate protection measures.
- Adequacy decision by the European Commission
- Standard Contractual Clauses (SCCs)
- Other legally recognized safeguards
Specific third country transfers:
- Shopify Inc. (Canada): Adequacy decision applies
- Google Analytics (United States): Standard Contractual Clauses with additional safeguards
- Social media platforms: Based on your consent and the applicable platform privacy policies
7. Data Security
We implement appropriate technical and organizational security measures.
Technical measures:
- SSL/TLS encryption for all data transmissions
- Firewalls and intrusion detection
- Regular security updates
- Encrypted data storage
- Secure backup procedures
Organizational measures:
- Access control and authorization
- Privacy by design principles
- Security awareness training
- Incident response procedures
- Periodic security audits
8. Your Rights Under GDPR
You have the following rights regarding your personal data:
- Right of access (Art. 15)
- Right to rectification (Art. 16)
- Right to erasure (Art. 17)
- Right to restriction (Art. 18)
- Right to object (Art. 21)
- Right to data portability (Art. 20)
- Right to withdraw consent at any time
To exercise your rights, email contact@austingamble.com. We respond within one month. We may ask for identification where necessary.
9. Data Retention Periods
We do not retain your data longer than necessary:
- Customer and order data: 7 years (legal retention obligation)
- Newsletter subscriptions: Until unsubscribe or 3 years of inactivity
- Contact forms: Maximum 2 years
- Website analytics: Maximum 26 months
- Security logs: 1 year
- Marketing cookies: According to your cookie settings
10. Data Breaches and Incidents
If a data breach is likely to result in risks to your rights and freedoms, we will notify the Dutch Data Protection Authority within 72 hours and inform affected users without undue delay. We take immediate measures to limit the impact.
11. Automated Decision Making
We do not use fully automated decision making including profiling that produces legal effects or similarly significant effects for you.
12. Minors
Our services are not directed at persons under 16 years of age. We do not knowingly collect personal data from minors without parental or guardian consent.
13. SMS and Mobile Communications
For SMS marketing:
- Consent: Explicit opt-in required
- Unsubscribe: Send STOP to our number
- Costs: Your carrier rates apply
- Processor: Klaviyo (GDPR compliant)
- No sharing with other parties for marketing purposes
14. Changes to this Privacy Policy
We may modify this privacy policy to comply with legal requirements or changes in our services. For substantial changes, we will inform you by email or a prominent notice on our website. The most current version is always available on our website.
15. Contact and Complaints
Questions about this privacy policy:
- Email: contact@austingamble.com
- Phone: +31 6 43472464
- Mail: Dennenweg 161, 7545WD Enschede, Netherlands
Complaints:
- Dutch Data Protection Authority (Autoriteit Persoonsgegevens)
- Website: www.autoriteitpersoonsgegevens.nl
- Phone: +31 88 180 5250
16. Jurisdiction Specific Rights
For California Residents (CCPA):
- Right to know what personal information is collected
- Right to delete personal information
- Right to opt-out of the sale of personal information
- Right to non-discrimination
For UK Residents:
- All GDPR rights continue to apply under UK GDPR
- Complaints can be submitted to the Information Commissioner's Office
17. Territorial Scope of Orders
We accept and fulfil orders to delivery addresses within EU member states only. We do not process or ship orders to non-EU countries.