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This Privacy Notice states how Drifa ehf., ID Number 480173-0159, Miðhrauni 4, 210 Garðabæ (here after „Icewear“, „the company“ og „we“), processes Personal Data of Data Subjects (here after also „you“). This Notice addresses the processing of Personal Data when individuals: • Shop in our online store • Request for technical support through our website • Create an account on our website • Visit our shops or warehouses • Contact us, via e-mail, telephone or social media • Visit our website, www.icewear.is • Use free WiFi in our stores Icewear processes Personal Data in accordance with current privacy regulation in Iceland at any time, as well as relevant acts of the Agreement on The European Economic Area (EEA). We value your Privacy Icewear values privacy highly and respects the rights of individuals as well as ensuring that processing of Personal Data is in accordance with current regulations and best practices at any given time. Which Data do we collect and for what purposes We emphasize on only processing Personal Data that is necessary in relation to the purpose for which it was collected. We do not process Personal Data for unrelated purposes unless you have been notified and given your consent. Icewear processes, as relevant, the following Personal Data: • name • e-mail • telephone number • address and postal code • country of origin • card/payment information, but only to the extent necessary to enable the appropriate payment institution to process payments for the purchase of goods. Such information is not stored by Icewear. • Digital footprint (such as internet behavior) • IP address • Identification information, when individuals make an account on our website • Information regarding business history It is our policy not to collect sensitive Personal Data, information about criminal offenses or information about children under the age of 13. We process Personal Data mainly in order to: • Fulfil an online order • Collect unpaid bills in the case of an account transaction • Conduct property and safety management (surveillance cameras etc.) • Do marketing and analysis • Respond to inquiries, complaints and compliments • Fulfil legal requirements • Manage information regarding business relations When you use our website www.icewear.is, we collect information about your usage, i.e. IP address, type and version of browser, timing and duration of visit and what subpages you visit through our website . Here you can find further information about our use of cookies (www.icewear.is/us/data-protection-policy ). Legal basis for collection and processing of Personal Data We collect and process your Data based on the following legal basis: • Performance of a contract. This legal basis mainly applies when individuals shop online through our website. • Legal obligation. This legal basis mainly applies in relation to bookkeeping. • Legitimate interests. This legal basis mainly applies in relation to camera surveillance in our stores and warehouse, as well as the collection of unpaid debts. • Consent. This legal basis mainly applies in relation to marketing material. Individuals can always withdraw their consent to receiving marketing material by clicking the button unsubscribe which can be found in all of our marketing e-mails. Withdrawal of consent does not affect processing of Personal Data that took place before the withdrawal. How long do we store your Data? We store Personal Data for as long as necessary in relation to the relevant legal basis. For example, Data collected through surveillance cameras is stored for 90 days. Accounting files are kept for seven years under The Accounting Act No. 145/1994. Review of Data retention is performed once per year and if it is concluded that processing of Data is not necessary, we stop processing. From whom do we collect your Personal Data? We collect your Personal Data from you and in certain circumstances from external sources, but in such case you will be informed about the origin of the Data. 3. When do we share your Personal Data with a third party and why? Icewear does not under any circumstances sell your Personal Data. Icewear only discloses Data to third parties if required by law or in the case that the third party is a service provider, agent or contractor. Third parties can, for example, perform the following tasks: • Mail distribution in the purpose of delivering products • Perform analytics and submit targeted ads online • Administrate e-mail addresses and mailing lists • Hosting computer systems • Able us to communicate with customers through our website • Web hosting service If the third party is a Data Processor, Icewear will have a Data Processing Agreement in place with the relevant party. Such agreements include the obligations for the processor to keep Personal Data safe and not to use them for any other purposes. Icewear can also discloses Personal Data to third parties when such is needed to protect our legitimate interests, such as collecting a default claim. Our Privacy Notice does not cover processing by third parties. We have no control over, neither bear responsibility of the use, publication or any other processing on their behalf. We encourage you to read privacy policies of relevant third parties, including web hosting providers of sites that can refer to our website, software companies such as Facebook, Google and Microsoft, along with the payment service you choose to use. Personal Data security and breach notification Personal Data protection is important to Icewear and we have taken appropriate technical and organizational security measures to ensure the protection of your Personal Data in line with our security policy. In the event of a security breach involving your Personal Data and a risk regarding your liberty and rights, we will notify you without undue delay. A security breach is an event that leads to your Personal Data being lost or destroyed, changed, displayed or accessed by an unauthorized individual or individuals. Keep in mind that Personal Data you choose to share with us on social media, such as Facebook or Instagram, is considered public information and we have no control over such Data. If you do not wish to share Data with other users or the social media provider, we recommend that you do not share Data on our social media. We also encourage you to read the privacy policies of these parties, Facebook, Google, Microsoft etc. Your rights Subject to the conditions set out in the applicable Data protection legislation, you enjoy the following rights: • The right to request access to your Personal Data • The right to rectification of your Personal Data • The right to erasure of your Personal Data • The right to restriction of processing • The right to Data portability • The right to objection to the processing of your Personal Data • The right to objection of automated decision-making, including profiling • The right to withdraw you consent, when processing is based on that legal basis If you wish to exercise your rights, you can send a written inquiry at [email protected] We wish that the inquiry follows a completed form, which can be found on our website: www.icewear.is/us/contact. We will confirm receiving the request and aim to respond within a month of receipt. If we cannot respond within a month, we will inform you about the delay within a month. A fee is not charged when individuals exercise their rights in accordance with what was previously defined except in cases where the inquiry is considered excessive or obviously unpretentious. You also have the right to lodge a complaint with the competent supervisory authority, in Iceland the authority is Persónuvernd. Further information may be found on their website, www.personuvernd.is Further information If you have further questions regarding your Personal Data, please contact our office. Drífa ehf. Miðhrauni 4 210 Garðabæ +354 555 7400 [email protected] Review of our Privacy Notice Our Privacy Notice is reviewed regularly and updated if needed. The Notice was last updated on February 8th, 2019.

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