Privacy Policy

VERSION 1.0 · EFFECTIVE 12 AUGUST 2026

1. Data controller

Kemphaan Consulting BV, trading as Birdie & Branding, registered at Spoorweglei 52, 2560 Nijlen, Belgium, company number BE 1017.706.578, is the controller for the personal data processed through this website and in the course of our services.

For any question about this policy or about the processing of your data, contact us at info@birdiebranding.eu or by post at the address above.

We are not required to appoint a data protection officer. Requests are handled directly by the company director.

2. Scope

This policy applies to the processing of personal data of visitors to birdiebranding.eu, people who join our waiting list or sample programme, customers, and contacts at golf clubs, pro shops and other business customers.

3. What we process, why, and on what legal basis

Category	Data	Purpose	Legal basis
Clubhouse list	Name, email address, stated interest, timestamp and a hashed form of your IP address	Notifying you of the launch and of launch pricing, and being able to demonstrate that you consented	Consent (art. 6.1.a GDPR)
Sample programme	Name, email address, submitted artwork, delivery address	Assessing and producing test pieces and sending you the result	Performance of contract and consent (art. 6.1.b and 6.1.a GDPR)
Orders	Name, billing and delivery address, email address, telephone number	Processing, producing, delivering and following up your order	Performance of contract (art. 6.1.b GDPR)
Business contacts	Contact name and role, club or company name, business contact details, VAT number	Preparing quotations, carrying out orders and invoicing	Performance of contract and legitimate interest (art. 6.1.b and 6.1.f GDPR)
Supplied artwork	Logos, crests, names, nicknames and other personalization details	Producing your product and enabling repeat orders	Performance of contract (art. 6.1.b GDPR)
Invoicing	Invoice and payment data	Meeting accounting and tax obligations	Legal obligation (art. 6.1.c GDPR)
Complaints and guarantee	Correspondence, photographs, order details	Handling complaints and defending our rights	Legal obligation and legitimate interest (art. 6.1.c and 6.1.f GDPR)

Providing data for an order is a contractual necessity. Without it we cannot perform the agreement. Joining the waiting list and taking part in the sample programme are entirely voluntary.

4. How we receive your data

4.1. This website contains no contact form that transmits data to a server. The forms on this site open your own email application with the details filled in. You send an ordinary email yourself, and no data is stored or transmitted by this website.

4.2. We also receive data directly from you, by email, telephone or in conversation.

4.3. We do not buy mailing lists and do not collect data through third parties.

5. Cookies and local storage

5.1. This website sets no cookies at all. No analytics cookies, no profiling, no advertising cookies, no tracking pixels. That is also why you will not find a cookie banner here.

5.2. We do keep one small technical item in your browser's local storage, named bnb_pop_v1. It holds only the moment you closed or completed our popup, so that it does not keep interrupting you. It contains no personal data, is never sent to us or to anyone else, and expires automatically after ninety days. You can clear it yourself at any time through your browser settings.

5.3. Fonts are served from our own server. This website makes no calls to external servers such as Google Fonts, content delivery networks or social media platforms. Simply visiting this website therefore transmits no data to any third party. When you submit the signup form, your details go to our own server first and only then to our email processor, so your browser never connects to a third party directly.

5.4. Our hosting is provided by Combell NV, with servers in the European Union. Server logs record technical data such as IP address, time and page requested. These logs are used solely for security and troubleshooting.

6. Recipients and processors

We do not sell or rent your data. We share data only where necessary, with:

• our hosting provider, to run this website;
• Brevo (Sendinblue SAS, Paris, France), our email processor, for managing the clubhouse list and sending our messages. Brevo processes your data within the European Union;
• carriers and postal services, to deliver your order;
• production partners, including embroidery partners, limited to the data needed to carry out your order;
• our accountant and, where legally required, the tax authorities;
• our bank and payment service providers, to process payments;
• legal advisers or competent authorities, where legally required or necessary to defend our rights.

We conclude data processing agreements under article 28 GDPR with processors acting on our behalf.

7. Transfers outside the European Economic Area

Our services are in principle designed for processing within the EEA. Where a service provider processes data outside the EEA, this takes place on the basis of an adequacy decision of the European Commission or the Standard Contractual Clauses, supplemented by appropriate additional safeguards. Materials are purchased from international suppliers without any customer personal data being transferred.

8. Retention periods

• Waiting list and sample programme: until you unsubscribe or withdraw consent, and in any event no longer than three years after the last contact.
• Quotations that do not lead to an order: two years from issue.
• Order and customer data: seven years after the end of the financial year, in line with accounting law.
• Invoices and accounting records: seven years, as required by law.
• Supplied artwork: two years after the last order, so repeat orders run smoothly, unless you ask us to delete it sooner.
• Complaint and guarantee files: ten years, given the limitation period for contractual claims.
• Server logs: a maximum of six months.

9. Security

9.1. This website is accessible only over a secure connection with TLS encryption.

9.2. We take appropriate technical and organisational measures, including limiting access to those who need the data, strong authentication, up to date software and regular backups.

9.3. In the event of a personal data breach posing a risk to your rights and freedoms, we notify the Belgian Data Protection Authority within seventy two hours and, where required, the individuals concerned.

10. Your rights

You have the following rights:

• Access: to know what data we process about you and to receive a copy.
• Rectification: to have inaccurate or incomplete data corrected.
• Erasure: to have your data deleted, insofar as we are not legally required to retain it.
• Restriction: to have processing restricted where you contest accuracy or have objected.
• Portability: to receive the data you provided in a structured, commonly used and machine readable format.
• Objection: to object to processing based on legitimate interest.
• Withdrawal of consent: to withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.

You exercise these rights by emailing info@birdiebranding.eu. We respond within thirty calendar days. For complex or repeated requests that period may be extended by two months, of which we will inform you in good time. We may ask for proof of identity where there is reasonable doubt as to who you are.

11. Automated decision making

We do not use automated decision making or profiling producing legal effects concerning you or similarly significantly affecting you.

12. Minors

Our services are not directed at people under sixteen. We do not knowingly collect data from minors without the consent of a parent or guardian. If you believe this has happened, contact us and we will delete the data.

13. Right to lodge a complaint

If you are unhappy with how we handle your data, you may lodge a complaint with the Belgian Data Protection Authority, Drukpersstraat 35, 1000 Brussels, telephone +32 2 274 48 00, email contact@apd-gba.be, website gegevensbeschermingsautoriteit.be. You may also contact the supervisory authority where you live.

14. Changes to this policy

We may update this policy when our practices or the applicable rules change, for example on introducing a webshop, a newsletter system or analytics. The version and date at the top indicate the current version. We will actively inform you of any significant change.