Privacy Policy
Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also briefly referred to as "data") we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").
The terms used are not gender-specific.
Status: April 26, 2026
Table of Contents
- Preamble
- Controller
- Overview of Processing Activities
- Relevant Legal Bases
- Security Measures
- Transmission of Personal Data
- International Data Transfers
- General Information on Data Storage and Deletion
- Rights of Data Subjects
- Business Services
- Use of Online Platforms for Offer and Sales Purposes
- Payment Procedures
- Provision of the Online Offering and Web Hosting
- Use of Cookies
- Registration, Login, and User Account
- Contact and Inquiry Management
- Newsletter and Electronic Notifications
- Promotional Communication via Email, Post, Fax, or Telephone
- Competitions and Contests
- Customer Reviews and Rating Procedures
- Presences in Social Networks (Social Media)
- Amendment and Update
- Definitions of Terms
Controller
Bettina Bussler BB LUXURYCHIC
Norden am Dorf 2, 27476 Cuxhaven
Email address: bbluxurychic@gmail.com
Overview of Processing Activities
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of Data Processed
- Inventory data.
- Payment data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication, and procedural data.
- Log data.
Categories of Data Subjects
- Service recipients and clients.
- Prospective customers.
- Communication partners.
- Users.
- Contest and competition participants.
- Business and contractual partners.
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Office and organizational procedures.
- Organizational and administrative procedures.
- Conducting contests and competitions.
- Feedback.
- Marketing.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Public relations.
- Sales promotion.
- Business processes and business management procedures.
Relevant Legal Bases
Relevant Legal Bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence or establishment may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National Data Protection Regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains special regulations, in particular, on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transfer as well as automated individual decision-making, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Security Measures
In accordance with legal requirements, and taking into account the state of the art, implementation costs, and the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability, and their separation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the erasure of data, and responses to data breaches. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.
Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt information transferred between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions comply with the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.
Transmission of Personal Data
In the course of our processing of personal data, it may occur that these are transmitted to other entities, companies, legally independent organizational units or persons, or disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe legal requirements and conclude appropriate contracts or agreements, which serve to protect your data, with the recipients of your data.
International Data Transfers
Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing/transmitting data to other persons, entities, or companies (which becomes apparent from the postal address of the respective provider or if the privacy policy explicitly refers to data transfer to third countries), this always happens in accordance with legal requirements.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated 10.07.2023. Additionally, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.
This dual protection ensures comprehensive protection of your data: the DPF forms the primary layer of protection, while the standard contractual clauses serve as additional security. Should changes occur within the DPF, the standard contractual clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.
For individual service providers, we will inform you whether they are certified under the DPF and whether standard contractual clauses exist. Further information on the DPF and a list of certified companies can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).
For data transfers to other third countries, corresponding security measures apply, in particular standard contractual clauses, explicit consents, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
General Information on Data Storage and Deletion
We delete personal data that we process in accordance with legal provisions as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original purpose of processing ceases to apply or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.
Our data protection notices contain additional information on the retention and deletion of data specifically applicable to certain processing procedures.
If there are multiple specifications for the retention period or deletion periods of data, the longest period is always decisive. Data that is no longer used for its originally intended purpose but is retained due to legal requirements or other reasons will be processed by us exclusively for the reasons justifying its retention.
Data retention and deletion: The following general deadlines apply for retention and archiving under German law:
- 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and the working instructions and other organizational documents required for their understanding (§ 147 para. 1 No. 1 i.V.m. para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 No. 1 i.V.m. para. 4 HGB).
- 8 years - Booking vouchers, such as invoices and expense receipts (§ 147 para. 1 No. 4 and 4a i.V.m. para. 3 sentence 1 AO and § 257 para. 1 No. 4 i.V.m. para. 4 HGB).
- 6 years - Other business documents: received trade or business letters, reproductions of dispatched trade or business letters, other documents insofar as they are relevant for taxation, e.g., hourly wage slips, cost accounting sheets, calculation documents, price markings, but also payroll documents, insofar as they are not already booking vouchers and cash register receipts (§ 147 para. 1 No. 2, 3, 5 i.V.m. para. 3 AO, § 257 para. 1 No. 2 and 3 i.V.m. para. 4 HGB).
- 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and usual industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Start of the period at the end of the year: If a period does not explicitly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the time of the effective date of termination or other termination of the legal relationship.
Rights of Data Subjects
Rights of data subjects under the GDPR: As a data subject under the GDPR, you have various rights, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you are processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw given consents at any time.
- Right of access: You have the right to request confirmation as to whether data concerning you are being processed and for information about this data as well as further information and a copy of the data in accordance with legal provisions.
- Right to rectification: You have the right, in accordance with legal provisions, to request the completion of incomplete data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: You have the right, in accordance with legal provisions, to demand that data concerning you be erased without undue delay, or alternatively, in accordance with legal provisions, to demand a restriction of the processing of the data.
- Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, or to demand its transmission to another controller, in accordance with legal provisions.
- Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.
Business Services
We process personal data of our contractual and business partners, such as customers, clients, interested parties, suppliers, and other cooperation partners (collectively "contractual partners"), for the initiation, execution, and settlement of contractual relationships and comparable legal relationships. This also includes pre-contractual measures that are taken upon request, as well as communication in connection with the respective contractual relationship.
The processing serves, in particular, the fulfillment of our primary and secondary contractual obligations. This includes the provision of agreed services, any update and information obligations, the handling of warranty and other performance disruptions, the processing of revocations, terminations of long-term contractual relationships, reversals, refunds, and the processing of other contract-related declarations and inquiries. Both one-time contracts and ongoing contractual relationships are covered.
Specifically, master data such as name, address, and, if applicable, company name, contact data such as email address and telephone number, contract and service data such as contract subject, contract term, order or transaction number, usage and service data, payment and billing data, as well as communication content and histories are processed. Where necessary, we also process data that is disclosed or transmitted to us in the course of performing an order.
In addition, we process the data to safeguard our rights and to fulfill legal obligations. This includes, in particular, retention obligations under commercial and tax law, documentation obligations, and, if applicable, proof and accountability obligations. Data is also processed based on our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as the protection of our business operations and our contractual partners against misuse, data breaches, disclosure of secrets, and other legal infringements. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors, or other vicarious agents, insofar as this is necessary for the execution of the contract or to fulfill legal obligations.
Personal data will only be disclosed to third parties if this is necessary for the performance of the contract, for the implementation of pre-contractual measures, for safeguarding legitimate interests, or for fulfilling legal obligations. We will inform you separately about further processing, in particular for marketing purposes, within the scope of this privacy policy.
We will inform our contractual partners which data is required in individual cases during data collection, for example, by appropriate marking in online forms or during personal contact.
The data will be deleted as soon as it is no longer required for the aforementioned purposes and no legal retention periods conflict with this. Legal retention periods, particularly under commercial and tax law, may require longer storage. Data transmitted within the scope of a specific order will be deleted after the order has been completed and any retention periods have expired, provided that no further legal or contractual obligations to store exist.
The legal basis for processing is Art. 6 para. 1 lit. b GDPR for the implementation of pre-contractual measures and for the fulfillment of the respective contractual relationship, as well as Art. 6 para. 1 lit. c GDPR for the fulfillment of legal obligations. Insofar as the processing is based on legitimate interests, it is carried out on the basis of Art. 6 para. 1 lit. f GDPR. Insofar as the processing is based on Art. 6 para. 1 lit. f GDPR, it is carried out to protect our legitimate interests in proper and efficient business organization, internal administration and documentation of business processes, enforcement and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, and the economic management and further development of our business operations. These interests consist in particular in ensuring a secure and legally compliant business operation as well as in maintaining our entrepreneurial freedom of action.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and e-mail addresses or telephone numbers); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
- Affected persons: Service recipients and clients; Prospective customers. Business and contractual partners.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Communication; Office and organizational procedures; Organizational and administrative procedures. Business processes and commercial procedures.
- Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Online shop, order forms, e-commerce and service fulfillment: We process our customers' data to enable them to select, purchase, or order the chosen products, goods, and associated services, as well as to process payments and provide or deliver or execute them. If necessary for the execution of an order, we use service providers, in particular postal, forwarding, and shipping companies, to carry out the delivery or execution for our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such within the order or comparable purchase process and includes the information required for delivery, provision and billing, as well as contact information to enable any consultation; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR).
Use of online platforms for offer and sales purposes
We offer our services on online platforms operated by other service providers. In this context, in addition to our data protection notices, the data protection notices of the respective platforms apply. This applies in particular with regard to the execution of the payment process and the procedures used on the platforms for reach measurement and interest-based marketing.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and e-mail addresses or telephone numbers); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
- Affected persons: Service recipients and clients. Business and contractual partners.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Marketing. Business processes and commercial procedures.
- Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- shopify: Platform through which e-commerce services are offered and carried out. The services and the processes carried out in connection with them include, in particular, online shops, websites, their offers and content, community elements, purchase and payment processes, customer communication, as well as analysis and marketing; Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 lit. f) GDPR); Website: https://www.shopify.com/de/. Privacy Policy: https://www.shopify.com/de/legal/datenschutz.
Payment procedures
Within the framework of contractual and other legal relationships, due to legal obligations, or otherwise based on our legitimate interests, we offer efficient and secure payment options to the data subjects and use other service providers in addition to banks and credit institutions (collectively "payment service providers"). Payment transactions are carried out exclusively via encrypted connections in accordance with the state of the art, so that the data entered is protected from unauthorized access during transmission.
The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the entered data is processed and stored only by the payment service providers. This means that we do not receive account- or credit card-related information, but only information with confirmation or negative information about the payment. In certain circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission is for the purpose of identity and credit checks. We refer to the terms and conditions and privacy policies of the payment service providers in this regard.
The terms and conditions and privacy policies of the respective payment service providers apply to payment transactions, which can be accessed on their respective websites or transaction applications. We also refer to these for further information and for asserting rights of revocation, access, and other data subject rights.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons). Contact data (e.g., postal and e-mail addresses or telephone numbers).
- Affected persons: Service recipients and clients; Business and contractual partners. Prospective customers.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Business processes and commercial procedures.
- Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- American Express: Payment services (technical integration of online payment methods); Service provider: American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR); Website: https://www.americanexpress.com/de/. Privacy Policy:https://www.americanexpress.com/de-de/firma/legal/datenschutz-center/online-datenschutzerklarung/.
- Apple Pay: Payment services (technical integration of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
- Google Pay: Payment services (technical integration of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR); Website: https://pay.google.com/intl/de_de/about/. Privacy Policy: https://policies.google.com/privacy.
- Klarna: Payment services (technical integration of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR); Website: https://www.klarna.com/de. Privacy Policy: https://www.klarna.com/de/datenschutz.
- Mastercard: Payment services (technical integration of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR); Website: https://www.mastercard.de/de-de.html. Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html.
- PayPal: Payment services (technical integration of online payment methods) (e.g., PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy Policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.
- Visa: Payment services (technical integration of online payment methods); Service provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, GB; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 lit. b) GDPR); Website: https://www.visa.de. Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
Provision of the online offer and web hosting
We process user data to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.
- Types of data processed: Usage data (e.g., page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons). Log data (e.g., log files regarding logins or data retrieval or access times).
- Affected persons: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal bases: Legitimate interests (Art. 6 para. 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Provision of online offering on rented storage space: To provide our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called "web host"); Legal bases: Legitimate interests (Art. 6 para. 1 lit. f) GDPR).
Use of cookies
The term "cookies" refers to functions that store and read information on users' end devices. Cookies can also be used for various purposes, such as the functionality, security, and convenience of online offerings, as well as the creation of analyses of visitor flows. We use cookies in accordance with legal requirements. For this purpose, we obtain the users' consent in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies when the storage and reading of information is essential to be able to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.
Notes on data protection legal bases: Whether we process personal data with the help of cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage duration: With regard to the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a website. Likewise, the user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. within the framework of obtaining consent), they should assume that these are permanent and the storage duration can be up to two years.
General information on revocation and objection (opt-out): Users can revoke their given consents at any time and also object to the processing in accordance with legal requirements, including via their browser's privacy settings.
- Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
- Data subjects: Users (e.g., website visitors, users of online services).
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing processes, procedures, and services:
- Processing of cookie data based on consent: We use a consent management solution that obtains users' consent for the use of cookies or for the procedures and providers mentioned in the consent management solution. This procedure serves to obtain, record, manage, and revoke consents, particularly in relation to the use of cookies and similar technologies used for storing, reading, and processing information on users' end devices. As part of this procedure, users' consents for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure, are obtained. Users also have the option to manage and revoke their consents. The consent declarations are stored to avoid re-querying and to be able to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies to be able to assign the consent to a specific user or their device. If no specific information is available about the providers of consent management services, the following general information applies: The duration of the storage of consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g., relevant categories of cookies and/or service providers) and information about the browser, system, and the end device used; Legal bases:Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Registration, Login, and User Account
Users can create a user account. During registration, users are informed of the required mandatory information, which is then processed for the purpose of providing the user account based on the fulfillment of contractual obligations. The data processed includes, in particular, login information (username, password, and an email address).
When using our registration and login functions and the user account, we store the IP address and the time of the respective user action. This storage is based on our legitimate interests as well as those of the users in protecting against misuse and other unauthorized use. This data is generally not passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users can be informed about events relevant to their user account, such as technical changes, via email.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts as well as related information, such as authorship or creation time); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Log data (e.g., log files regarding logins or data retrieval or access times).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organizational and administrative procedures. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion according to the information in the "General information on data storage and deletion" section. Deletion after termination.
- Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:
- Deletion of data after termination: If users have terminated their user account, their data related to the user account will be deleted, subject to legal permission, obligation, or user consent; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Contact and Inquiry Management
When contacting us (e.g., via mail, contact form, email, telephone, or social media) and within the framework of existing user and business relationships, the information of the inquiring persons is processed, insofar as this is necessary to answer the contact inquiries and any requested measures.
- Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts as well as related information, such as authorship or creation time). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion according to the information in the "General information on data storage and deletion" section.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing processes, procedures, and services:
- Contact form: When contacting us via our contact form, email or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This typically includes information such as name, contact information and, if applicable, further information that is communicated to us and is necessary for adequate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Newsletter and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter "newsletter") exclusively with the consent of the recipients or on the basis of a legal basis. If the content of the newsletter is specified during registration, this content is decisive for the users' consent. For registration to our newsletter, providing your email address is usually sufficient. However, to provide you with a personalized service, we may ask for your name for a personal address in the newsletter or for further information, if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We can store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove a formerly given consent. The processing of this data will be limited to the purpose of a potential defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is also confirmed. In the case of obligations to permanently comply with objections, we reserve the right to store the email address solely for this purpose in a blocklist (so-called "blocklist").
The logging of the registration process is based on our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider with the dispatch of emails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.
Contents:
Information about us, our services, promotions, and offers.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
- Data subjects: Communication partners. Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Direct marketing (e.g., by email or post). Provision of contractual services and fulfillment of contractual obligations.
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Right to object (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e., revoke your consents, or object to further receipt. A link to cancel the newsletter can be found either at the end of each newsletter or you can use one of the contact options given above, preferably email, for this purpose.
Further information on processing processes, procedures, and services:
- Prerequisite for using free services: Consent to the sending of mailings can be made a prerequisite for using free services (e.g., access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
Commercial communication via email, post, fax, or telephone
We process personal data for the purpose of commercial communication, which can take place via various channels, such as email, telephone, post, or fax, in accordance with legal requirements.
Recipients have the right to revoke given consents at any time or to object to commercial communication at any time free of charge via the contact options mentioned above.
After revocation or objection, we store the data required to prove the previous authorization for contact or sending for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Furthermore, on the basis of the legitimate interest to permanently comply with the revocation or objection of the users, we store the data necessary to prevent renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers). Content data (e.g., text or image messages and posts as well as related information, such as authorship or creation time).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Direct marketing (e.g., by email or post); Marketing. Sales promotion.
- Retention and deletion: Deletion according to the information in the "General information on data storage and deletion" section.
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Contests and Competitions
We process personal data of participants in contests and competitions only in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, execution and settlement of the contest, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the contest or the protection of our interests against misuse by possible collection of IP addresses when submitting contest entries).
If contributions from participants are published within the framework of the contests (e.g. as part of a vote or presentation of the contest entries or the winners or reporting on the contest), we point out that the names of the participants may also be published in this context. Participants can object to this at any time.
If the contest takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the terms of use and data protection regulations of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by the participants in the context of the contest and inquiries regarding the contest should be addressed to us.
Participant data will be deleted as soon as the sweepstakes or contest has ended and the data is no longer required to notify winners or because no further inquiries regarding the sweepstakes are expected. In principle, participant data will be deleted no later than 6 months after the end of the sweepstakes. Winner data may be retained longer, for example, to answer questions about prizes or to fulfill prize obligations; in this case, the retention period depends on the type of prize and is, for example, up to three years for items or services, for example, to process warranty cases. Furthermore, participant data may be stored longer, for example, in the form of reporting on the sweepstakes in online and offline media.
If data was collected for other purposes within the scope of the sweepstakes, its processing and retention period will be governed by the data protection notices for that use (e.g., in the case of subscribing to a newsletter as part of a sweepstakes).
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers). Content data (e.g., textual or pictorial messages and posts, as well as information relating to them, such as authorship or time of creation).
- Data subjects: Sweepstakes and contest participants.
- Purposes of processing and legitimate interests: Running sweepstakes and contests.
- Retention and deletion: Deletion according to information in the "General information on data storage and deletion" section.
- Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Customer reviews and rating procedures
We participate in review and rating procedures to evaluate, optimize, and promote our services. If users rate us or provide other feedback via the involved rating platforms or procedures, the general terms and conditions of use and the data protection notices of the providers also apply. As a rule, a rating also requires registration with the respective providers.
To ensure that the reviewers have actually used our services, we transmit the necessary data regarding the customer and the service used (including name, email address, and order number or item number) to the respective rating platform with the customer's consent. This data is used solely to verify the authenticity of the user.
- Types of data processed: Contract data (e.g., subject matter of contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
- Data subjects: Service recipients and clients. Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via online form). Marketing.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, procedures, and services:
- Rating widget: We integrate so-called "rating widgets" into our online offering. A widget is a functional and content element embedded in our online offering that displays variable information. It can, for example, be displayed in the form of a seal or similar element, sometimes also called a "badge". The corresponding content of the widget is displayed within our online offering, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the respective current rating. For this purpose, a data connection must be established from the website accessed within our online offering to the server of the widget provider, and the widget provider receives certain technical data (access data, including IP address) that are necessary for the content of the widget to be delivered to the user's browser. Furthermore, the widget provider receives information that users have visited our online offering. This information can be stored in a cookie and used by the widget provider to recognize which online offerings participating in the rating procedure have been visited by the user. The information can be stored in a user profile and used for advertising or market research purposes; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Presences in social networks (Social Media)
We maintain online presences within social networks and process user data in this context to communicate with active users there or to offer information about ourselves.
We point out that user data may be processed outside the European Union. This can result in risks for users, as, for example, the enforcement of user rights could be made more difficult.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and resulting interests. The latter may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. Therefore, cookies are usually stored on the users' computers, in which the user behavior and the interests of the users are stored. In addition, data independent of the devices used by the users can also be stored in the user profiles (especially if they are members of the respective platforms and logged in there).
For a detailed description of the respective processing forms and the possibilities of objection (opt-out), we refer to the data protection declarations and information of the operators of the respective networks.
Even in the case of requests for information and the assertion of data subject rights, we point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can directly take appropriate measures and provide information. Should you still need help, you can contact us.
- Types of data processed: Contact data (e.g., postal and email addresses or phone numbers); Content data (e.g., textual or pictorial messages and posts, as well as information relating to them, such as authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Communication; Feedback (e.g., collecting feedback via online form). Public relations.
- Retention and deletion: Deletion according to information in the "General information on data storage and deletion" section.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, procedures, and services:
- Instagram: Social network that allows sharing photos and videos, commenting on and liking posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy:https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
Changes and Updates
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or any other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting them.
Definitions of Terms
In this section, you will find an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations are primarily intended to aid understanding.
- Inventory Data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems, by enabling clear assignment and communication.
- Content Data: Content data includes information generated during the creation, editing, and publication of all types of content. This category of data can include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not only limited to the actual content but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
- Contact Data: Contact data are essential information that enables communication with individuals or organizations. They include, among other things, telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
- Meta, Communication, and Process Data: Meta, communication, and process data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information describing the context, origin, and structure of other data. It can include information about file size, creation date, author of a document, and modification histories. Communication data records the exchange of information between users across various channels, such as email traffic, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission paths. Process data describes the processes and workflows within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used to track and review operations.
- Usage Data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and how they navigate through an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
- Personal Data: "Personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Log Data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to generate performance reports.
- Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, be it collection, evaluation, storage, transmission, or deletion.
- Contract Data: Contract data are specific information relating to the formalization of an agreement between two or more parties. They document the conditions under which services or products are provided, exchanged, or sold. This data category is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include contract start and end dates, the type of services or products agreed upon, pricing agreements, payment terms, termination rights, renewal options, and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
- Payment Data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is critical for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers, and billing information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.