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1. An overview of data protection

General information

On this website, we, Croozer GmbH, provide information about our products and services. The protection of your personal data is very important to us. Therefore, we collect and process your personal data exclusively in accordance with data protection law. On this page, we provide all relevant information on data protection in accordance with Articles 13 and 14 of the EU General Data Protection Regulation (GDPR) on the collection and processing of your personal data.

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Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

2. Hosting and Content Delivery Networks (CDN)

We are hosting the content of our website at the following provider:

Shopify

The provider is the Shopify International Limited, Victoria Building, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland (hereinafter: “Shopify”).

Shopify is a tool for creating and hosting websites. When you visit our website, Shopify collects your IP address and information about the device and browser you use. Shopify also analyses the number of visitors, visitor sources and customer behavior and compiles user statistics. When you make a purchase on our site, Shopify also collects your name, email address, shipping and billing addresses, payment information and other information related to the purchase (e.g., phone number, number of sales made, etc.). Shopify stores cookies in your browser for the purpose of analysis.

Please see the Shopify privacy policy for details: https://www.shopify.de/legal/datenschutz.

The use of Shopify is based on Art. 6(1)(f) GDPR. We have a legitimate interest the most reliable presentation of our website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.


Cloudflare

We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as “Cloudflare”).

Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose.

The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible (Art. 6(1)(f) GDPR).

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details and further information on security and data protection at Cloudflare can be found here: https://www.cloudflare.com/privacypolicy/.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5666.

3. General information and mandatory information


Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

Croozer GmbH
An der Hasenkaule
D - 50354 Hürth

Phone: 02233 - 95991-0
E-mail: datenschutz@croozer.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).


Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Designation of a data protection officer

We have appointed a data protection officer.

Croozer GmbH
An der Hasenkaule
D - 50354 Hürth

Phone: 02233 - 95991-0
E-mail: datenschutz@croozer.com

Information on the data transfer to third-party countries that are not secure under data protection law and the transfer to US companies that are not DPF-certified

We use, among other technologies, tools from companies located in third-party countries that are not safe under data protection law, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). If these tools are enabled, your personal data may be transferred to and processed in these countries. We would like you to note that no level of data protection comparable to that in the EU can be guaranteed in third countries that are insecure in terms of data protection law.

We would like to point out that the US, as a secure third-party country, generally has a level of data protection comparable to that of the EU. Data transfer to the US is therefore permitted if the recipient is certified under the “EU-US Data Privacy Framework” (DPF) or has appropriate additional assurances. Information on transfers to third-party countries, including the data recipients, can be found in this Privacy Policy.

Recipients of personal data

In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Encrypted payment transactions on this website

If you are under an obligation to share your payment information (e.g. account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments.

Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account) are processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the communication with us is encrypted, third parties will not be able to read the payment information you share with us.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

Which cookies and services are used on this website can be found in this privacy policy.

Consent with Cookiebot

Our website uses consent technology from Cookiebot to obtain your consent to the storage of certain cookies on your end device or for the use of certain technologies and to document this in a data protection-compliant manner. The provider of this technology is Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter “Cookiebot”).

When you enter our website, a connection is established with the Cookiebot servers to obtain your consent and provide you with other explanations regarding the use of cookies. Cookiebot will then store a cookie in your browser to identify the consent you have given or its revocation. The data collected in this way is stored until you request us to delete it, delete the Cookiebot cookie itself or the purpose for which the data is stored no longer applies. Mandatory legal storage obligations remain unaffected.

Cookiebot is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

• The type and version of browser used
• The used operating system
• Referrer URL
• The hostname of the accessing computer
• The time of the server inquiry
• The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

Use of Chatbots

We use chatbots to communicate with you. Chatbots have the capability to respond to your questions and other entries without the assistance of humans. To do this, chatbots analyze your entries and other data to give matching responses (e.g., names, email addresses and other contact information, customer numbers and other identification, orders, and chat progresses). The chatbot can also register your IP address, log files, location information and other meta data. The data is archived on the servers of the chatbot provider.

It is possible to generate user profiles based on the recorded data. Moreover, the data can be used to display interest-related advertising if the other legal requirements are met (in particular if consent has been obtained). Moreover, it is possible to link chatbots to analytical and advertising tools.

The recorded data can also be used to improve our chatbots and their response patterns (machine learning).

We or the chatbot operator retain the data you enter until you ask us to delete it, revoke your consent to archive it or if the purpose for the data storage is no longer in effect (e.g., once your inquiry has been fully processed). This does not affect mandatory statutory provisions – in particular, retention time frames.

The legal basis for the use of chatbots is Art. 6(1)(b) GDPR, if the chatbot is used to negotiate a contract or in conjunction with the fulfillment of a contract. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time. In all other cases, the use is based on our legitimate interest in the most effective client communication possible (Art. 6(1)(f) GDPR).

eTermin

On our website you have the option to make appointments with us. We use eTermin for the reservation of these appointments. The provider is the eTermin GmbH, Im Wiesengrund 8, 8304 Wallisellen, Switzerland (hereinafter referred to as “eTermin”).

To book an appointment, you enter the requested data and the desired meeting time into the respective screen. The entered data will be used to plan, implement and, if applicable, follow up on the appointment. Moreover, eTermin records logfiles (number and time the page was accessed, browser, browser version and operating system as well as an anonymized IP address).

eTermin saves the appointment data on our servers, whose privacy policy you can view here: https://www.etermin.net/online-terminbuchung-datenschutz. Responsible is eTermin Limited, Ipeirou 10A, 8010 Paphos, Cyprus.

The data you enter will remain with us until you ask us to delete it, delete the consent cookie yourself or the purpose of data archiving is no longer valid. This does not affect mandatory statutory retention periods.

The legal basis for data processing is Art. 6(1)(f) GDPR. We have a legitimate interest in a depiction of our website that is as reliable as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

5. DEALER SECTION

We have a dealer section on our website for the dealers with whom we work and the dealers who are interested in working with us. The dealer section can also be reached via our website. From the dealer section, it is possible to reach us via a contact email and to subscribe to our newsletter.

a. Form for New Dealers

At https://www.croozer.com/pages/dealer-information, interested dealers can find a form that they can fill out and return to us via email or fax. In order to get to know your business better, we ask for further information: e.g. information on your business (including the billing and shipping address and details about the branches where products should be sent, on the distribution channels (stationary and online), on the products you sell and on sales figures), on the owner of the business and on communication (contact persons).

The processing of your personal data is required in this context in order to take steps at your request prior to entering into a contract and – if a contract with you is concluded – for the fulfilment of the contract between you and Croozer GmbH (Art. 6 para. 1 lit. b of the GDPR). For us, it is important that the respective contact persons can be quickly and easily reached; the processing of the personal data of your employees (whom you can name as contact persons) is performed on the basis of overriding, legitimate interests (Art. 6 para. 1 lit. f GDPR).
The data will be stored for the duration of the contractual relationship with Croozer GmbH and subsequently for the retention period required by law; when changes are made to the information (e.g. on the owner or the contact persons), the old information will be deleted. If no partnership results, then the data will be deleted in accordance with the retention period required by law.

b. Dealer Contact Form

In addition, our dealers have the possibility to contact us via a dealer contact form. This form can be opened in the dealer section; it is also possible to open the form on the website https://www.croozer.com (via “Contact”) (you are then redirected to the respective page).

The required fields on this form are your message, the subject of your message, your title, your surname/company, the address of your company and the email address of your company. You can voluntarily provide your first name, additional names/company names and telephone and fax numbers. We only process your data as required to answer your inquiry. After we have responded to your inquiry, this data will be deleted insofar as there is no retention period required by law.
We need the data in order to quickly forward your inquiry to the responsible employee at our company so that your inquiry can be answered without delay. In this sense, the data provided by you is processed on the basis of overriding, legitimate interests (Art. 6 para. 1 lit. f GDPR).

c. Newsletter

After a dealer agreement has been concluded, our dealers have the opportunity to subscribe to our email newsletter in order to stay up to date on news from our company. For this purpose, we will ask you for your email address. You can also voluntarily provide us with your first name and surname (as well as title) if you would like the newsletter to be personally addressed to you. We use the data that you provide to us for the newsletter subscription exclusively for the purpose of sending you the newsletter. In this context, we work with an external service provider for the technical implementation: This website uses Cleverreach for the sending of newsletters. The provider is the CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany(hereinafter“CleverReach”). CleverReach is a service that can be used to organize and analyze the sending of newsletters. This company has been carefully selected and contracted to us in accordance with data protection law.
Prior to the first newsletter, we require your consent (Art. 6 para. 1 lit. a of the GDPR). You can withdraw your consent at any time by using the unsubscribe link included in every newsletter. For this purpose, simply use the unsubscribe function in the newsletter or contact us directly using the contact details provided above.

6. SURVEYS AND CUSTOMER DIALOGUE

a. Customer dialogue

As a manufacturer, we have a legitimate interest in optimising our products for the best possible customer benefit. Therefore, we maintain a lively exchange with our customers about our products - the so-called customer dialogue. For the customer dialogue it is necessary to collect personal data. These can be, for example, personal data, socio-demographic data or data on usage behaviour and statistical data on product satisfaction. All information is always voluntary.

All this data can be collected by telephone, in personal interviews - if necessary with the support of recording devices (tape or video) - or workshops, or in written form, e.g. by digital survey via our website or by post. In some cases we create user profiles, these help us to understand what product improvements are needed and how we can communicate these in a way that is easy to understand. Personal data that we collect in customer dialogue is only used for the development and marketing of Croozer products. This data is not passed on to any third party and is only used internally and, after a statistical evaluation, is made available in anonymised form, e.g. to the product development department and the marketing department.

As part of your participation in the customer dialogue, you may receive discount vouchers by e-mail. Furthermore, these discount coupons can also be made available to you in after-sales or in the area of further marketing cooperations and activities.

b. Surveys

We regularly invite our customers - these can be dealers as well as end consumers - to participate in a survey regarding the use of our products and for statistical evaluation of product satisfaction. The list of recipients is compiled on the basis of a statistical survey of product purchases and/or on the basis of the consent of registered persons to customer dialogue.

There are often incentives to participate in a dialogue, such as free accessories. However, this is not obligatory. For the purpose of excluding illegal behaviour, such as multiple participation in a survey, we reserve the right to provide a survey with a code that serves to match an answer sheet and the associated redemption of an incentive. In this case, the survey is referred to as a pseudonymous survey. However, the content of the answer sheet is still kept anonymous and no personal data is assigned.

The statistical evaluation of a survey can take place manually in-house at Croozer or with the help of carefully selected service providers. For the technical implementation of an online survey we use the survey tool MS Forms.

A special URL leads from our website to the URL of the survey. The following data is collected there, which is technically necessary for us to display the website and the survey:

• Date and time of access
• Source/reference from which you reached the page
• Browser used
• Operating system used
• IP address used (in anonymised form)

This processing is carried out in accordance with Art. 6 Para. 1 lit. f DSGVO on the basis of our legitimate interest and to ensure the functionality of the website. This data is provided to us by the survey tool for statistical evaluation. The data is not passed on or used in any other way. We reserve the right to check the server log files retrospectively if there are concrete indications of illegal use. To protect the transmission of personal data and other confidential content, SSL or TLS encryption is used at all times. An encrypted connection can be recognised by the string “https://“ and the lock symbol in your browser line.

c. Survey invitation by e-mail to registered customer dialogue participants.

Only the e-mail address is required for registration as a participant in our customer dialogue. The provision of further data is voluntary and will only be used for a possible personal address. The registration procedure works with the so-called double opt-in procedure. After entering your email address in the registration field and activating the “Register now” button, we will send you a confirmation email asking you to confirm that you actually wish to receive the newsletter in future by clicking on a corresponding link. By activating the confirmation link, you give us your consent for the use of your personal data in accordance with Art. 6 Para. 1 lit. a DSGVO. When you register for the newsletter, we store your IP address entered by your Internet service provider (ISP) as well as the date and time of registration in order to be able to trace any possible misuse of your e-mail address at a later date. The data we collect for customer dialogue when you register for the newsletter is used exclusively for the purposes of product satisfaction analysis and contacting you for invitations to customer dialogue (e.g. workshop, interview, survey).

For the execution of an e-mailing, we use the following technical service provider, to whom we pass on your data provided during the newsletter registration. This transfer takes place in accordance with Art. 6 Para. 1 lit. f DSGVO and serves our legitimate interest in using a secure and user-friendly newsletter system that complies with the legal standard according to EU-DSGVO:

CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany

For more information about Cleverreach and the privacy policy of the company in question, please click on the following link:
https://www.cleverreach.com/en/privacy-policy/

The following usage data is collected:

• the page from which the file was requested
• the description of the type of web browser used
• the IP address of the requesting computer, which is shortened in such a way that a personal reference can no longer be established

This consent to customer dialogue and the associated use of the e-mail address can be revoked at any time in the future by clicking on the link provided in an e-mailing or by unsubscribing from the following e-mail address zgd@croozer.com. After unsubscribing, your e-mail address will be immediately deleted from our newsletter distribution list, unless you have expressly consented to further use of your data or we reserve the right to use your data in a way that goes beyond this, which is permitted by law and about which we inform you in this declaration.

d. Survey invitation by postal direct mailing to existing customers and e-mailing for advertising purposes in the AfterSalesService

When purchasing goods in our online shop, you have provided us with your e-mail, shipping and billing address. In doing so, we reserve the right to regularly send you offers for similar goods or services, such as those already purchased, from our product range by e-mail or to invite you to participate in product satisfaction surveys. In accordance with Section 7 (3) of the German Unfair Competition Act (UWG), we do not need to obtain your separate consent for this. In this respect, the data processing is carried out solely on the basis of our legitimate interest in personalised direct advertising in accordance with Art. 6 Para. 1 lit. f DSGVO. In the context of contacting you or inviting you to take part in the survey by post, personal data is processed which has been collected and stored from previously placed online orders and the associated purchase contract, in particular the delivery address and evaluation of the order content are meant here and are processed for the purpose of creating a correct list of recipients. This data is stored and used exclusively for this purpose and the associated technical administration. The legal basis for the processing of this data is our legitimate interest in, among other things, a product satisfaction survey in accordance with Art. 6 Para. 1 lit. f DSGVO. Within the scope of contacting or inviting to the survey by post, personal data is processed which has been collected and stored from previously placed online orders and the associated purchase contract, in particular the delivery address and evaluation of the order content are meant here and are processed for the purpose of creating a correct recipient list. This data is stored and used exclusively for this purpose and the associated technical administration. The legal basis for the processing of this data is our legitimate interest in, among other things, a product satisfaction survey in accordance with Art. 6 Para. 1 lit. f DSGVO. An invitation to participate in a survey is sent by post to existing customers and/or invitations are sent using our digital social media channels. Participation is voluntary at all times. If you object to the use of your email address for this purpose, no further mailings will be made by us. You are also entitled to object to the use of your e-mail address for the aforementioned advertising purpose at any time with effect for the future by notifying the responsible person named at the beginning or by using the link provided for this purpose in a mailing. You will only incur transmission costs for this in accordance with the basic rates.

We reserve the right to cooperate with various external logistics partners for shipping, these are carefully selected and integrated in accordance with data protection law, e.g. the German Post or other shipping service providers such as Postfactory.

Contact details: POSTFACTORY GmbH represented by its managing director, Ms. Rita Knuf, Vitalisstr. 312a, 50829 Cologne, Tel. 049-221-99228-0, Fax 049-221-99228-333, E-Mail: info@postfactory.org
Cologne Local Court HRB57866, VAT ID No. DE 250095625.

e. Newsletter - e-mailing for advertising purposes

Newsletter data

This website uses Cleverreach for the sending of newsletters. The provider is the CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany(hereinafter “CleverReach”).Cleverreach services can, among other things, be used to organize and analyze the sending of newsletters. The data you enter for the purpose of subscribing to the newsletter are archived on Cleverreach’s servers in Germany.Data analysis by Cleverreach

Cleverreach enables us to analyze our newsletter campaigns. For instance, it allows us to see whether a newsletter message has been opened and, if so, which links may have been clicked. This enables us to determine, which links drew an extraordinary number of clicks.

Moreover, we are also able to see whether once the e-mail was opened or a link was clicked, any previously defined actions were taken (conversion rate). This allows us to determine whether you have made a purchase after clicking on the newsletter.

Cleverreach also enables us to divide the subscribers to our newsletter into various categories (i.e., to “cluster” recipients). For instance, newsletter recipients can be categorized based on age, gender, or place of residence. This enables us to tailor our newsletter more effectively to the needs of the respective target groups.
If you do not want to permit an analysis by Cleverreach, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message. Moreover, you can also unsubscribe from the newsletter right on the website.
For detailed information on the functions of Cleverreach please follow this link:
https://www.cleverreach.com/en/features/reporting-tracking/.

Legal basis

The data is processed based on your consent (Art. 6(1)(a) GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.
Storage period
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.
For more details, please consult the Data Protection Regulations of Cleverreach at
https://www.cleverreach.com/en/privacy-policy/.
Execution of a contract data processing agreement: We have executed a contract with Sendinblue, in which we require Newsletters2Go to protect our customers’ data and to refrain from sharing such data with third parties.

Discount vouchers

In the context of your participation in the Customer Dialogue programme, you may be offered discount vouchers. In addition, these discount coupons could also be made available to you in the context of after sales or other marketing cooperation programmes and activities.

7. Social media

Facebook

We have integrated elements of the social network Facebook on this website. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.

An overview of the Facebook social media elements is available under the following link: https://developers.facebook.com/docs/plugins/.

If the social media element has been activated, a direct connection between your device and the Facebook server will be established. As a result, Facebook will receive information confirming your visit to this website with your IP address. If you click on the Facebook Like button while you are logged into your Facebook account, you can link content of this website to your Facebook profile. Consequently, Facebook will be able to allocate your visit to this website to your user account. We have to emphasize that we as the provider of the website do not receive any information on the content of the transferred data and its use by Facebook. For more information, please consult the Data Privacy Policy of Facebook at: https://de-de.facebook.com/privacy/explanation.

The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum,
https://de-de.facebook.com/help/566994660333381
and https://www.facebook.com/policy.php.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/4452.

Instagram

We have integrated functions of the public media platform Instagram into this website. These functions are being offered by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

If the social media element has been activated, a direct connection between your device and Instagram’s server will be established. As a result, Instagram will receive information on your visit to this website.

If you are logged into your Instagram account, you may click the Instagram button to link contents from this website to your Instagram profile. This enables Instagram to allocate your visit to this website to your user account. We have to point out that we as the provider of the website and its pages do not have any knowledge of the content of the data transferred and its use by Instagram.

The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook or Instagram. The processing by Facebook or Instagram that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook or Instagram tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook or Instagram products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook or Instagram directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum,
https://privacycenter.instagram.com/policy/
and https://de-de.facebook.com/help/566994660333381.

For more information on this subject, please consult Instagram’s Data Privacy Declaration at: https://privacycenter.instagram.com/policy/.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/4452.

LinkedIn

This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Any time you access a page of this website that contains elements of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this website to your user account. We have to point out that we as the provider of the websites do not have any knowledge of the content of the transferred data and its use by LinkedIn.

The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/help/linkedin/answer/a1343190/datenubertragung-aus-der-eu-dem-ewr-und-der-schweiz?lang=de.

For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5448.

Pinterest

We use elements of the social network Pinterest on this website. The network is operated by Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.

If you access a site or page that contains such an element, your browser will establish a direct connection with Pinterest’s servers. During this process, the social media element transfers log data to Pinterest’s servers in the United States. The log data may possibly include your IP address, the address of the websites you visited, which also contain Pinterest functions. The information also includes the type and settings of your browser, the data and time of the inquiry, how you use Pinterest and cookies.

The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.

For more information concerning the purpose, scope and continue processing and use of the data by Pinterest as well as your affiliated rights and options to protect your private information, please consult the data privacy information of Pinterest at: https://about.pinterest.com/en/privacy-policy.

8. Analysis tools and advertising

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place.

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://privacy.google.com/businesses/controllerterms/mccs/.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

IP anonymization

Google Analytics IP anonymization is active. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

Google Ads

The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://policies.google.com/privacy/frameworks
and https://business.safety.google/controllerterms/.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

Meta Pixel (formerly Facebook Pixel)

To measure conversion rates, this website uses the visitor activity pixel of Facebook/Meta. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.

This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.

For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the data for its own promotional purposes in compliance with the Facebook Data Usage Policy (https://www.facebook.com/about/privacy/). This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.

Within the meta pixel, we are using the expanded alignment function.

The expanded alignment allows us to transfer to Meta (Facebook) different types of data (e.g., place of residence, federal state, zip code, hashed email addresses, names, gender, date of birth or phone number) of our customers and prospects we collect through our website. As a result of this activation, we can tailor the offers presented in our advertising campaigns on Facebook to individuals interested in what we offer even more precisely. Moreover, this expanded alignment optimizes the allocation of website conversions and expands custom audiences.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum
and https://de-de.facebook.com/help/566994660333381.

In Facebook’s Data Privacy Policies, you will find additional information about the protection of your privacy at: https://www.facebook.com/about/privacy/.

You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook.

If you do not have a Facebook account, you can deactivate any user-based advertising by Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/4452.

TikTok Pixel

We have integrated TikTok pixel on this website. The provider is TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland (hereinafter TikTok).

With the help of TikTok Pixel, we can display interest-based advertisements on TikTok to website visitors who have viewed our offers (TikTok Ads). At the same time, TikTok Pixel allows us to determine how effective our advertising is on TikTok. This allows us to evaluate the effectiveness of the TikTok Ads for statistical and market research purposes and to optimize them for future advertising efforts. For this purpose, various usage data are processed, such as IP address, page views, time spent, operating system used and origin of the user, information about the ad on which a person clicked on TikTok or an event that was triggered (timestamp). This data is summarized in a user ID and assigned to the respective end device of the website visitor.

The use of this tool is based on Art. 6(1)(a) GDPR and § 25 (1) TDDDG. This consent can be revoked at any time.

Data transfer to third-party countries is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.tiktok.com/legal/page/eea/privacy-policy/de-DE and https://ads.tiktok.com/i18n/official/policy/controller-to-controller.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Pinterest-Tag

We have integrated Pinterest-Tag into this website. The provider is Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.

The purpose of Pinterest-Tag is to record certain actions you perform on our website. Subsequently, the data can be used to display promotions to you that meet your interests on our website or on another Pinterest-Tag website.

For this purpose, Pinterest-Tag records, among other things, a Tag ID, your location, and the referrer URL. Furthermore, action specific data, such as the order value, ordered quantity, order number, the category of the purchased item and video views may be recorded.

Pinterest-Tag uses technologies that make the recognition of the user across sites possible, so that the user patterns can be analyzed (e.g., cookies or device fingerprinting).

If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TDDDG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in ensuring the maximum effectiveness of the operator’s marketing activities.

Pinterest is an enterprise that does business around the globe, so that data may also be transmitted into the United States. Based on Pinterest’s statements, this data transmission is based on the standard contractual clauses of the EU Commissions. For details please visit: https://policy.pinterest.com/de/privacy-policy.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

9. Newsletter

Newsletter data

If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the handling of the newsletter, we use newsletter service providers, which are described below.

CleverReach

This website uses CleverReach for the sending of newsletters. The provider is the CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany (hereinafter “CleverReach”). CleverReach is a service that can be used to organize and analyze the sending of newsletters. The data you have entered for the purpose of subscribing to our newsletter (e.g., e-mail address) are stored on servers of CleverReach in Germany or in Ireland.

Newsletters we send out via CleverReach allow us to analyze the user patterns of our newsletter recipients. Among other things, in conjunction with this, it is possible how many recipients actually opened the newsletter e-mail and how often which link inside the newsletter has been clicked. With the assistance of a tool called Conversion Tracking, we can also determine whether an action that has been predefined in the newsletter actually occurred after the link was clicked (e.g., purchase of a product on this website). For more information on the data analysis services by CleverReach newsletters, please go to: https://www.cleverreach.com/en/features/reporting-tracking/.

The data is processed based on your consent (Art. 6(1)(a) GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

If you do not want to permit an analysis by CleverReach, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

For more details, please consult the Data Protection Provisions of CleverReach at: https://www.cleverreach.com/en/privacy-policy/.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Newsletter mailing to existing customers

If you order goods or services from us and enter your e-mail address, this e-mail address may subsequently be used by us to send you newsletters, provided we inform you of this in advance. In such a case, only direct advertising for our own similar goods or services will be sent via the newsletter. You can unsubscribe from this newsletter at any time. There is a corresponding link in every newsletter for this purpose. In this case, the legal basis for sending the newsletter is Art. 6 (1)(f) GDPR in conjunction with Section 7 (3) UWG.

After you unsubscribe from the newsletter distribution list, we may store your email address in a blacklist to prevent future mailings to you. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 (1)(f) GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

10. Plug-ins and Tools

YouTube with expanded data protection integration

This website integrates videos from the YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit one of these websites on which YouTube is integrated, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube in extended data protection mode. According to YouTube, videos that are played in extended data protection mode are not used to personalize browsing on YouTube. Ads that are played in extended data protection mode are also not personalized. No cookies are set in extended data protection mode. Instead, so-called local storage elements are stored in the user's browser, which contain personal data similar to cookies and can be used for recognition. Details on the extended data protection mode can be found here: https://support.google.com/youtube/answer/171780.

After activating a YouTube video, further data processing operations may be triggered over which we have no influence.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

Google Fonts (local embedding)

This website uses so-called Google Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application.

For more information on Google Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

Google Maps

This website uses the mapping service Google Maps. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. With the means of this service, we can integrate map material on our website.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer. In case Google Maps has been activated, Google has the option to use Google Fonts for the purpose of the uniform depiction of fonts. When you access Google Maps, your browser will load the required web fonts into your browser cache, to correctly display text and fonts.

We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6(1)(f) GDPR. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://privacy.google.com/businesses/gdprcontrollerterms/
and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of reCAPTCHA is to determine whether data entered on this website (e.g., information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyzes the behavior of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g., IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.

reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway.

Data are stored and analyzed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the protection of the operator’s websites against abusive automated spying and against SPAM. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

For more information about Google reCAPTCHA please refer to the Google Data Privacy Declaration and Terms Of Use under the following links: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

Userlike with extended data privacy mode

We use Userlike (hereinafter called “Userlike”) to process user inquiries via our support channels or live chat systems. The provider is Userlike UG (a limited liability company), Probsteigasse 44 – 46, 50670 Cologne, Germany.

Messages you send to us may be stored in the Userlike ticket system or answered by our staff in live chat. When you communicate with us through Userlike, we and Userlike store, among other things, your name and email address, if you have provided them, and your chat history. This data is summarized in a profile.

Messages that are addressed to us remain in our possession until you ask us to delete them or the reason for the data storage is no longer effective (e.g., after your inquiry has been processed). This shall be without prejudice to any statutory provisions – especially statutory mandatory retention obligations.

Userlike is deployed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in marketing activities that are as effective as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

For more information please consult the Userlike data protection declaration: https://www.userlike.com/de/data-privacy and https://www.userlike.com/de/blog/live-chat-software-datenschutz-dsgvo.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

11. eCommerce and payment service providers

Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data for the establishment, content arrangement and modification of our contractual relationships. Data with personal references to the use of this website (usage data) will be collected, processed, and used only if this is necessary to enable the user to use our services or required for billing purposes. The legal basis for these processes is Art. 6(1)(b) GDPR.

The collected customer data shall be deleted upon completion of the order or termination of the business relationship and upon expiration of any existing statutory archiving periods. This shall be without prejudice to any statutory archiving periods.

Data transfer upon closing of contracts for online stores, retailers, and the shipment of merchandise

Whenever you order merchandise from us, we will share your personal data with the transportation company entrusted with the delivery as well as the payment service commissioned to handle the payment transactions. Only the data these respective service providers require to meet their obligations will be shared. The legal basis for this sharing is Art. 6 (1)(b) GDPR, which permits the processing of data for the fulfillment of contractual or pre-contractual obligations. If you give us your respective consent pursuant to Art. 6 (1)(a) GDPR, we will share your email address with the transportation company entrusted with the delivery so that this company can notify you on the shipping status for your order via email. You have the option to revoke your consent at any time.

Payment services

We integrate payment services of third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank account details, credit card number) are processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment transaction (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent may be revoked at any time for the future.

We use the following payment services / payment service providers within the scope of this website:

PayPal

The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full.

Details can be found in PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Mollie

The provider of this payment service is Mollie B.V, Keizersgracht 126, 1015CW Amsterdam, Netherlands (hereinafter "Mollie"). With the help of Mollie, we can integrate various payment methods on our website. Details can be found in Mollie's privacy policy: https://www.mollie.com/de/privacy.

Shopify Payment

The provider of this payment service in the EU is Shopify International Limited, 2nd Floor Victoria Buildings, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland (hereinafter “Shopify Payment”). For more information, see Shopify Payment's privacy policy: https://www.shopify.de/legal/datenschutz

12. Online-based Audio and Video Conferences (Conference tools)

Data processing

We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).

Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.

Purpose and legal bases

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.

Duration of storage

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.

We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.

Conference tools used

We employ the following conference tools:

Microsoft Teams

We use Microsoft Teams. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

13. Custom Services

OneDrive

We have integrated OneDrive on this website. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland (hereinafter “OneDrive”).

OneDrive enables us to include an upload area on our website where you can upload content. When you upload content, it is stored on the OneDrive servers. When you access our website, a connection to OneDrive is also established so that OneDrive can determine that you have visited our website.

The use of OneDrive is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in a reliable upload area on its website. If the relevant consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR; consent may be revoked at any time.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/6474.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Status as of November, 2024

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