Policies

This Privacy Notice states how Drifa ehf., ID Number 480173-0159, Suðurhrauni 10, 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 Icewear´s website, 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 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.

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.

• 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.

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 support@icewear.is. We wish that the inquiry follows a completed form. 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.

Suðurhraun 10

210 Garðabæ

+354 555 7400

support@icewear.is

Review of our Privacy Notice

Our Privacy Notice is reviewed regularly and updated if needed. The Notice was last updated on September 10th, 2020.

Icewear’s equality policy ensures equal working conditions, respect, and fairness for all employees in a safe and supportive work environment.

Icewear’s equal pay policy applies to all employees of the company. The equal pay policy stipulates that all employees enjoy equal pay and the same benefits for the same or equally valuable work so that no gender-based pay gap exists in accordance with the Act on Equal Status and Equal Rights of the Genders No. 150/2020

Icewear emphasizes the importance of providing a positive and supportive working environment for all employees at every workplace location. The company’s policy is to employ competent, motivated, and responsible staff, thereby fostering a strong team spirit and a positive workplace culture.

The following are Icewear's key policy principles:

• The company employs and retains qualified sta­ who meet the requirements for knowledge, experience, and skills.

• Equal opportunities are guaranteed in all areas, and great emphasis is placed on ensuring that all employees enjoy human rights, regardless of origin, nationality, religion, political opinions, gender, sexual orientation, age, economic status, disability, or health. See Icewear’s Equality Policy for further details. See Icewear’s Equality Policy for further details.

• Equal pay is ensured within the company, where all employees receive comparable pay for equally valuable work, considering seniority and experience. The company operates in accordance with a certified equal pay system.

• Career development is a joint responsibility of the company and its employees. The company emphasizes providing opportunities for professional development.

• Diversity in the workplace is considered essential for success and innovation. Through a professional recruitment process, emphasis is placed on the competence of applicants, seeking the most qualified individuals for each role.

• The company ensures proper working conditions, health, and safety in accordance with legal requirements. Employee well-being and health are mutual interests guiding the company’s e­orts.

• The company places great emphasis on ensuring that employees feel good at work, fostering open communication, a positive work atmosphere, and well-being. It is a shared responsibility to create a workplace free of bullying, prejudice, and sexual harassment. See Icewear’s EKKO Action Plan for further information.

• Employees are supported in balancing work and family life to the greatest extent possible.

• Confidentiality applies to all information related to the interests of the company and its customers. Employees make decisions based on good business practices, laws, regulations, and integrity, and show courtesy and respect in their interactions with colleagues, customers, and others in their work.

• Icewear respects human rights and does not tolerate child labor, forced labor, or other human rights violations in its operations. Partners, suppliers, and stakeholders are subject to the same requirements, and Icewear reserves the right to terminate business relationships if any such violations occur.

The goal of the sustainability policy is to set the company's standards and goals in sustainability matters, i.e. environmental, social and governance issues.

Icewear plays an important social role that relates to the company's goals of promoting increased outdoor activities. Icewear's focus is therefore to have a wide selection, high-quality products and fair prices that ensure access to a healthy lifestyle for as many people as possible.

Upcoming technological and climate changes will affect Icewear's entire operating environment and society as a whole. These changes affect Icewear's customers, employees and production, and the company therefore aims to operate in a responsible and sustainable manner in its operations and thus have a positive impact on the environment and society.