The Data Controller for the data covered in this statement is BROWNELLS BENELUX SARL (which will be referred to as we or us in the following sections), represented by its manager. Any enquiry regarding matters of personal data and its processing by either BROWNELLS BENELUX, or any other processor doing so on behalf of BROWNELLS BENELUX, can be addressed to:Brownells Benelux s.à.r.l.
In order to run and maintain a functioning website, as well as protect ourselves from cyberattacks, we process a certain amount of data from any visitor to our services. In order to ensure the necessary technical expertise, this processing is done by contracted 3rd parties on our behalf.
We serve requests through a Content Delivery Network (CDN) provided by CLOUDFLARE INC. All metadata necessary to the proper routing of the requested packets (IP-address, ISP of the requester, geographical location of the IP-address, amongst others) will be processed in order to ensure an efficient routing, as well as protect our servers from surges in traffic.
Our servers are hosted by INNOCHANGE GmBH (Morgenbergstr. 19 - 08525 Plauen - Germany). Any request made to our servers is stored in a logfile, recording data relevant to the request itself (time of request, amount of data requested, which page was requested, amongst others). This data is anonymized and processed within the scope of regular operation of the website, including maintaining the servers, troubleshooting, or planning for infrastructural upgrades.
Whenever an order is placed, personal details such as address and contact information, will be asked from our customers. As we cannot fulfill our obligations towards the sale without this data, it needs to be provided accurately before concluding the contract. The personal data provided this way will exclusively be processed within the scope of upholding our contractual obligations stemming from the sale, communicating with the customer about the status of his order, or according to our legal obligations.
The deliveries themselves, as well as other tasks related to the logistics of the delivery, are contracted to third party professionals. They will receive and process the data strictly necessary for them to fulfill their role, within (and strictly limited to) the scope of the related sales contract.
For payments to be processed, customers will need to enter payment details relating to the payment method they chose. As with the data necessary for the delivery, this payment data is necessary to conclude the contract. This data is sent and processed directly by our service provider for payments, NETS A/S (601, Klausdalbrovej, DK-2750 Ballerup, Denmark), who process it strictly within the scope of ensuring the payment, as agreed to in the resulting contract, is carried out correctly. We do not store nor process this data ourselves.
As a private business localized in Luxembourg, we must abide by Luxembourgish laws and practices regarding commerce and accounting. In addition, due to the nature of some of our products, we must abide by Luxembourgish law, as well as by US Export regulations, regarding the sale and distribution of firearms and accessories pertaining to firearms.
As BROWNELLS LUXEMBOURG, we resell products originating from BROWNELLS, a company localized in the United States of America. These products can only be sold if they are allowed for export from the United States of America to the customer. Any product we import thusly must comply to current US Export regulation. As part of this compliance, upon any order, personal data from the customer such as name, address, date of birth or company name, as provided by the customer either through account registration or settings, or through providing a delivery address, has to be screened through a blacklist. If the thusly processed data matches no entry on the blacklist, it will be automatically deleted. If the thusly processed data matches an entry on the blacklist it will be kept until further manual processing has been completed. This screening is carried out using CSI Watchdog Elite, a cloud-based screening service provided by COMPUTER SERVICES INC. (CSI) (3901 Technology Drive, KY 42001, Paducah, United States of America).
When ordering products that are restricted for sale in, and export out of, Luxembourg (such as firearms and firearm parts), the order is put on hold and the requesting customer will be asked further information. The exact nature of the thusly requested information is dependent on the product initially requested for order. This requested data will be transmitted to the Luxembourgish Ministry of Justice, which will verify its validity, confirm whether the sale is allowed, and record that information indefinitely. The records are kept to maintain proper control over the distribution of restricted objects by the Ministry of Justice of Luxembourg, as a matter of public interest.
We keep any records about orders made by our customers as necessary to comply with local laws on commerce, bookkeeping and customer protection. The processing of this data is limited to this scope, and data will be deleted when no longer necessary. The applicable law on this matter is Luxembourgish law.
When a user registers a customer account or changes information concerning an owned customer account, the data provided by the user will be kept on our website. The purchase history made through the account is also stored on our website. The data provided this way is processed within the scope of providing the user a more convenient browsing experience, as well as giving us more avenues to contact the customer should it be pertinent for an action requested by the customer. By registering an account, you implicitly consent to this processing. You can revoke this consent at any time by contacting us, which will result in the deletion of your registered customer account, and all data related to the account, provided the deletion does not breach our previously mentioned legal obligations. In that case, the data will be deleted only after it is no longer required for the relevant legal obligations.
When a user sends us a message directly using e-mail or the website's contact form, the data provided by the user will be kept and processed within the context provided by the message's content. If pertinent to that context, we will cross-reference it with accounting data or an existing customer account for the user. The data will be kept indefinitely, in order to provide a better customer service, as well as to protect our legitimate interest in case of disputes.
Users have the option of subscribing to our newsletter, either through the newsletter subscription popup or through settings in the customer account. Through subscribing to our newsletter, users consent to receiving our newsletter, containing promotional material. Users can retract their consent at any time by unsubscribing from the newsletter, either through their customer account settings, or by following the unsubscribe link in the newsletter.
Data provided this way is transmitted to a third party, APSIS (Stormgatan 11, 211 20 Malmö, Sweden), which is contracted to handle our newsletter. The contracted third party processes the data strictly within the scope of sending our newsletter.
Our webshop uses the Apsis Ecom plug-in provided by APSIS (Stormgatan 11, 211 20 Malmö, Sweden). This plug-in gathers data such as e-mail address, IP address, browsed articles or articles in the shopping basket, from visitors and registered users. This data is processed within the scope of providing targeted advertisement to users through the website interface as well as, provided the user also subscribed to the newsletter, the contents of the newsletter. Users can consent to this processing through the storefront Privacy pop-up. Users can at any time revoke their consent by clearing the cookies stored in their browser and choosing the appropriate settings in the storefront Privacy pop-up that will appear upon loading a webpage from our site afterwards.
Our website uses the integrated LiveChat system provided by ZENDESK INC (1019 Market St
San Francisco, CA 94103, USA). The ZENDESK LiveChat system overlays itself to our website to provide a chat window through which customers can directly chat with customer support.The system gathers data such as IP address and thereof derived geolocalization, active webshop user session and the contents typed within the system. The system can cross-reference any customer data on our system such as order history, contact information and communication history. This data is processed solely within the scope of providing an adequate solution to requests made by customers through contacting our customer support.
Our webshop uses the AddThis tool provided by ORACLE CORPORATION (AddThis-HQ: 1900 Oracle Way, VA 20190 Reston, USA/Oracle HQ: 500 Oracle Parkway, CA 94065 Redwood Shores, USA). The AddThis tool overlays itself to our website and provides buttons to the user, allowing to share content across different social networks. This tool gathers data such as IP and thereof derived geolocalization, browsing and sharing behavior of users and keywords entered in the tool. This data is stored and processed in an anonymized fashion by ORACLE CORPORATION. ORACLE CORPORATION does not save or process any data from visitors which are localized in EU/EEA, Switzerland or the United Kingdom (except for the minimally necessary processing to assess this status).
For a visual reference to the buttons provided by AddThis, please visit their website on the following page:
For more information about the handling of gathered data by the AddThis tool, you can refer to:
Our webshop uses the functionalities of Google Analytics provided by GOOGLE LLC (1600 Amphitheatre Parkway, CA 94043 Mountain View, USA). Google Analytics provides us with reports on the manner our website is accessed and navigated through. For this purpose, data such as browser ID, IP address, origin of traffic and browsing history on our webshop is gathered. The data is sent to, stored and processed by GOOGLE in an anonymized fashion.
You can opt-out or opt-in by setting (or removing) an "Opt-Out"-cookie for Google Analytics. Google Analytics checks for the existence of such a cookie in an user's browser, and only gathers data about the user should that cookie be absent. You can set or remove this cookie by following the appropriate link below:
Deactivate Google Analytics tracking of your movements in our Web Shop (OPT-OUT).
Activate Google Analytics tracking of your movements in our Web Shop (OPT-IN).
For more information about the handling of data gathered by Google Analytics, please refer to:https://support.google.com/analytics/answer/6004245?hl=en
For more general information about the handling of data gathered by GOOGLE services, you can refer to: