Privacy Policy

Effective Date: [Date, e.g., 7th June 2025]

Garrison Point ("we," "us," or "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website ([Your Website URL]), interact with us, or make a purchase.

We process your personal data in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and the Data Protection Act 2018 (DPA 2018).

1. Who We Are

• Company Name: Garrison Point
• Registered Address: [Your Full Registered Address]
• Contact Email: [Your Customer Service Email Address]
• Data Protection Officer (DPO) / Contact for Privacy Concerns: [Name or "The Data Protection Team" / Email Address if different from above]

2. What Personal Data We Collect

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data: First name, last name, title, date of birth, gender.
• Contact Data: Billing address, delivery address, email address, telephone numbers.
• Financial Data: Payment card details (though processed by secure third-party payment gateways, not stored directly by us), bank account details (for refunds if applicable).
• Transaction Data: Details about payments to and from you and other details of products and services you have purchased from us.
  
• Technical Data: Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  
• Usage Data: Information about how you use our website, products, and services.
  
• Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.
  
• Verification Data: Copies of identity documents (e.g., driving licence, passport) and utility bills provided during age or exemption verification processes for restricted items (as detailed in our T&Cs). This data is collected and processed strictly for legal compliance.

3. How We Collect Your Personal Data

We use different methods to collect data from and about you, including:

• Direct Interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
  
  
  • Create an account on our website.
    
  • Place an order for our products.
    
  • Subscribe to our newsletter or marketing communications.
    
  • Enter a competition, promotion, or survey.
  • Give us feedback or contact us.
  • Participate in age or exemption verification processes (e.g., video calls for ID verification).
• Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, Browse actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for more details.
  
• Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and public sources, such as:
  
  • Technical Data from analytics providers (e.g., Google Analytics).
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services (e.g., PayPal, Stripe, shipping carriers).
  • Identity and Contact Data from publicly available sources (e.g., Companies House, electoral register) where relevant for verification.
  • Verification data from official databases (e.g., UKARA for airsoft exemptions).

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• To perform the contract we are about to enter into or have entered into with you: This means processing your order, managing your account, and delivering your products.
  
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests: This includes improving our services, preventing fraud, and ensuring security.
  
• Where we need to comply with a legal or regulatory obligation: This is particularly relevant for age verification and VCR Act exemption checks for restricted items.
• Where you have given consent: For example, for sending you marketing communications.

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Purpose/Activity

Type of Data

Lawful Basis for Processing

To register you as a new customer

Identity, Contact

Performance of a contract with you

To process and deliver your order, including:

Identity, Contact, Financial, Transaction

Performance of a contract with you

* Managing payments, fees, and charges

Necessary for our legitimate interests (to recover debts due to us)

* Collecting and recovering money owed to us

To manage our relationship with you, which includes:

Identity, Contact, Profile, Marketing and Communications, Usage, Technical

Performance of a contract with you

* Notifying you about changes to our terms or privacy policy

Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

* Asking you to leave a review or take a survey

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To enable you to partake in a prize draw, competition or survey

Identity, Contact, Profile, Usage, Marketing and Communications

Performance of a contract with you; Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business andthis website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)

Identity, Contact, Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Identity, Contact, Profile, Usage, Marketing and Communications, Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences

Technical, Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To perform mandatory age verification for restricted items (knives/edged weapons)

Identity, Contact, Verification

Necessary to comply with a legal obligation (e.g., Offensive Weapons Act, age verification laws)

To perform mandatory exemption verification for Realistic Imitation Firearms (RIFs) under the VCR Act 2006

Identity, Contact, Verification

Necessary to comply with a legal obligation (Violent Crime Reduction Act 2006)

To comply with law enforcement requests and legal processes

All types of data, as required

Necessary to comply with a legal obligation

Export to Sheets

5. Marketing Communications

We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you.

You will receive marketing communications from us if you have requested information from us or purchased goods from us and you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at [Your Customer Service Email Address].

6. Disclosure of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes described in the table above:

• Internal Third Parties: Other companies in our group acting as joint controllers or processors and who provide IT and system administration services.
  
• External Third Parties:
  
  
  • Service providers acting as processors based in the UK who provide IT and system administration services, payment processing, shipping services, and marketing support.
    
  • Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
    
  • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
    
  • Specific verification partners (e.g., UKARA database for airsoft RIF exemptions, or third-party age verification services if used).
  • Law enforcement agencies if legally required.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International Transfers

We primarily store and process your personal data within the UK and the European Economic Area (EEA). If we transfer your personal data outside the UK/EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK government.
  
• Where we use certain service providers, we may use specific contracts approved for use in the UK/EEA which give personal data the same protection it has in the UK/EEA (e.g., Standard Contractual Clauses).
  
• Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Data Privacy Framework (or equivalent UK-US framework) which requires them to provide similar protection to personal data shared between the UK/EEA and the US.
  

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For example, by law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes. Data related to age/exemption verification for restricted items will be retained for the minimum period required by law to demonstrate compliance.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data (commonly known as a "data subject access request").
  
• Request correction of the personal data that we hold about you.
  
• Request erasure of your personal data.
  
• Object to processing of your personal data.
  
• Request restriction of processing of your personal data.
  
• Request the transfer of your personal data to you or to a third party.
  
• Withdraw consent at any time where we are relying on consent to process your personal data.
  

If you wish to exercise any of the rights set out above, please contact us at [Your Customer Service Email Address].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Right to Lodge a Complaint

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

12. Changes to This Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated on the date stated at the beginning of the policy. Historic versions can be obtained by contacting us.