Privacy Policy
1. An overview of data protection
General information
The following information will provide you with an easy to navigate overview of what will happen with your
personal data when you visit this website. The term “personal data” comprises all data that can be used to
personally identify you. For detailed information about the subject matter of data protection, please consult
our Data Protection Declaration, which we have included beneath this copy.
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?
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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
External Hosting
This website is hosted by an external service provider (host). Personal data collected on this website are
stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests,
metadata and communications, contract information, contact information, names, web page access, and
other data generated through a web site.
The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art.
6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a
professional provider (Art. 6(1)(f) GDPR).
Our host will only process your data to the extent necessary to fulfil its performance obligations and to
follow our instructions with respect to such data.
We are using the following host:
Hostinger, UAB
Jonavos g. 60C, 44192
Kaunas, Lithuania
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Data processing
We have concluded a data processing agreement (DPA) with the above-mentioned provider. 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.
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:
Velvet Legends
Paul Bonik
Berliner Strasse 126
10713 Berlin
Germany
Phone: 01742460260
E-mail: paul@velvetlegends.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.
Information on data transfer to the USA and other non-EU countries
Among other things, we use tools of companies domiciled in the United States or other from a data
protection perspective non-secure non-EU countries. If these tools are active, your personal data may
potentially be transferred to these non-EU countries and may be processed there. We must point out that in
these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For
instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as
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the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out
that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal
data for surveillance purposes. We have no control over these processing activities.
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 demand that we hand over any data we automatically process on the basis of your
consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, 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.
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.
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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.
Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to at any time demand
information about your archived personal data, their source and recipients as well as the purpose of the
processing of your data. 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 in lieu 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.
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
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Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files 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.
In some cases, it is possible that third-party cookies are stored on your device once you enter our site (thirdparty cookies). These cookies enable you or us to take advantage of certain services offered by the third
party (e.g., cookies for the processing of payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions
would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The
purpose of other cookies may be the analysis of user patterns or the display of promotional messages.
Cookies, which are required for the performance of electronic communication transactions (required
cookies) or for the provision of certain functions you want to use (functional cookies, e.g., for the shopping
cart function) or those that are necessary for the optimization 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 cookies to
ensure the technically error free and optimized provision of the operator’s services. If your consent to the
storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the
consent obtained (Art. 6(1)(a) GDPR); 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.
In the event that third-party cookies are used or if cookies are used for analytical purposes, we will
separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.
Consent with Borlabs Cookie
Our website uses the Borlabs consent technology to obtain your consent to the storage of certain cookies in
your browser or for the use of certain technologies and for their data privacy protection compliant
documentation. The provider of this technology is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305
Hamburg, Germany (hereinafter referred to as Borlabs).
Whenever you visit our website, a Borlabs cookie will be stored in your browser, which archives any
declarations or revocations of consent you have entered. These data are not shared with the provider of the
Borlabs technology.
The recorded data shall remain archived until you ask us to eradicate them, delete the Borlabs cookie on
your own or the purpose of storing the data no longer exists. This shall be without prejudice to any retention
obligations mandated by law. To review the details of Borlabs’ data processing policies, please visit
https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/
We use the Borlabs cookie consent technology to obtain the declarations of consent mandated by law for
the use of cookies. The legal basis for the use of such cookies is Art. 6(1)(c) GDPR.
Request by e-mail, telephone, or fax
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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 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 pertinent consent has been requested, the processing shall
occur exclusively on the basis of Art. 6(1)(a) GDPR; the consent may 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).
Registration on this website
You have the option to register on this website to be able to use additional website functions. We shall use
the data you enter only for the purpose of using the respective offer or service you have registered for. The
required information we request at the time of registration must be entered in full. Otherwise, we shall
reject the registration.
To notify you of any important changes to the scope of our portfolio or in the event of technical
modifications, we shall use the e-mail address provided during the registration process.
We shall process the data entered during the registration process on the basis of your consent (Art. 6(1)(a)
GDPR).
The data recorded during the registration process shall be stored by us as long as you are registered on this
website. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory
retention obligations.
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Registration with Google
Instead of registering directly on this website, you can register with Google. The provider of this service is
Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
To register with Google, you must only enter your Google name and password. Google will identify you and
confirm your identity to our website.
When you sign in with Google, we may be able to use certain information in your account to complete your
profile with us. You decide whether you want this information to be used and if so, which information it is,
within the framework of your Google security settings, which you can find here:
https://myaccount.google.com/security and
https://myaccount.google.com/permissions.
The data processing associated with Google’s registration is based on our legitimate interest in making the
registration process as simple as possible for our users (Art. 6(1)(f) GDPR). Since the use of the registration
function is voluntary and the users themselves can decide on the respective access options, no conflicting
predominant rights of the data subjects are apparent.
5. 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 the
relevant consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a)
GDPR; the consent can be revoked at any time.
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. Google may consolidate these data in a profile that is
allocated to the respective user or the user’s device.
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.
This analysis tool is used on the basis of Art. 6(1)(f) GDPR. The operator of this website has a legitimate
interest in the analysis of user patterns to optimize both, the services offered online and the operator’s
advertising activities. If a corresponding agreement has been requested (e.g., an agreement to the storage of
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cookies), the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement 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/controllerterms/mccs/.
IP anonymization
On this website, we have activated the IP anonymization function. 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.
Demographic parameters provided by Google Analytics
This website uses the “demographic characteristics” function of Google Analytics, to be able to display to the
website visitor compatible ads within the Google advertising network. This allows reports to be created that
contain information about the age, gender, and interests of the website visitors. The sources of this
information are interest-related advertising by Google as well as visitor data obtained from third-party
providers. This data cannot be allocated to a specific individual. You have the option to deactivate this
function at any time by making pertinent settings changes for advertising in your Google account or you can
generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the
recording of data”.
Google Analytics E-Commerce-Tracking
This website uses the “E-Commerce Tracking” function of Google Analytics. With the assistance of ECommerce Tracking, the website operator is in a position to analyze the purchasing patterns of website
visitors with the aim of improving the operator’s online marketing campaigns. In this context, information,
such as the orders placed, the average order values, shipping costs and the time from viewing the product to
making the purchasing decision are tracked. These data may be consolidated by Google under a transaction
ID, which is allocated to the respective user or the user’s device.
Archiving period
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Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g.,
DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 months. For details,
please click the following link:
https://support.google.com/analytics/answer/7667196?hl=en
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 Google Ads is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in
marketing the operator’s services and products as effectively as possible.
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://privacy.google.com/businesses/controllerterms/mccs/.
Google AdSense
This website uses Google AdSense, a service for the integration of ads. The provider of this service is Google
Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With the assistance of Google Adsense, we are in a position to place targeted ads by third parties on our site.
The contents of the ads are based on your interests, which Google determines based on your past user
patterns. Moreover, when choosing compatible ads, context information, such as your location, the content
of the visited website or Google search terms you have entered, will be taken into account.
Google AdSense uses Cookies, Web Beacons (invisible graphics) and comparable recognition technologies.
As a result, it is possible to analyze information, such as visitor traffic data, on these sites.
The usage information for this website (including your IP address) recorded by Google Adsense and delivery
of advertising formats are transferred to a Google server in the United States, where the information is
stored. Google may share this information with one of its contracting partners. However, Google will not link
your IP address with any other of your stored information.
Our use of AdSense is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the
marketing of the operator’s website that is as effective as possible. If a respective declaration of consent was
requested, processing shall occur exclusively on the basis of Art. 6(1)(a) GDPR; the given consent may 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/controllerterms/mccs/.
Facebook Pixel
To measure conversion rates, this website uses the visitor activity pixel of Facebook. The provider of this
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service is Facebook 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. 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 Facebook Pixel is based on Art. 6(1)(f) GDPR. The operator of the website has a legitimate
interest in effective advertising campaigns, which also include social media. If a corresponding agreement
has been requested (e.g., an agreement to the storage of cookies), the processing takes place exclusively on
the basis of Art. 6(1)(a) GDPR; the agreement 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.facebook.com/legal/EU_data_transfer_addendum und
https://de-de.facebook.com/help/566994660333381.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to
Facebook, we and Facebook 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.
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/.
VG Wort Zählpixel
We have implemented texts on our website, in which a so-called tracking pixel (METIS tracking pixel) is
embedded. The provider is the Verwertungsgesellschaft WORT – VG WORT (association with legal capacity
by virtue of conferral), Untere Weidenstraße 5, 81543 Munich (hereinafter “VG Wort”).
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The pixel counts the views of texts, forwards them anonymously to the VG Wort, in order to determine the
distributions for the authors. The use of the VG Wort pixel is based on our legitimate interest in receiving
remuneration for the texts published on our website for our authors or for ourselves (Art. 6(1)(f) GDPR).
Conflicting interests of website visitors are not apparent, as the data is transmitted to VG Wort in
anonymized form.
6. 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.
MailerLite
This website uses MailerLite to send newsletters. The provider is UAB “MailerLite”, J. Basanaviciaus 15,
LT-03108 Vilnius, Lithuania (hereinafter referred to as MailerLite).
MailerLite is a service that, among other things, can be used to organize and analyze the sending of
newsletters. The data you enter to subscribe to the newsletter is stored on MailerLite’s servers.
If you do not want MailerLite to analyze your data, you must unsubscribe from the newsletter. For this
purpose, we provide a corresponding link in every newsletter message.
Data analysis by MailerLite
MailerLite enables us to analyze our newsletter campaigns. For example, we can see whether a newsletter
message was opened, and which links were clicked on, if any. In this way we can determine which links were
clicked on particularly often.
We can also see whether certain previously defined actions were carried out after opening/clicking
(conversion rate). For example, we can see whether you have made a purchase after clicking on the
newsletter.
MailerLite also enables us to divide the newsletter recipients into different categories (“clustering”). The
newsletter recipients can be divided according to age, gender, or place of residence, for example. In this way,
the newsletters can be better adapted to the respective target groups.
Detailed information on the functions of MailerLite can be found at the following link:
https://www.mailerlite.com/features.
The MailerLite privacy policy can be found at:
https://www.mailerlite.com/legal/privacy-policy.
Legal basis
Data processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke this consent at any time for
the future.
Storage period
The data you provide us with for the purpose of subscribing to the newsletter will be stored by us or the
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newsletter service provider until you unsubscribe from the newsletter and deleted from the newsletter
distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We
reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own
discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR. This does not
affect data stored by us for other purposes.
After you have been removed 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 will
only be used for this purpose and will not be merged with other data. This serves both your interest and our
interest in compliance with the legal requirements when sending newsletters (legitimate interest in the
sense of Art. 6(1)(f) GDPR). There is no time limit on storage in the blacklist. You can object to the storage if
your interests outweigh our legitimate interest.
Data processing
We have concluded a data processing agreement (DPA) with the above-mentioned provider. 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.
7. Plug-ins and Tools
YouTube with expanded data protection integration
Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited
(“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that
YouTube does not store any information about visitors to this website before they watch the video.
Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled
out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a
video, YouTube will always establish a connection with the Google DoubleClick network.
As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be
established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are
logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your
browsing patterns to your personal profile. You have the option to prevent this by logging out of your
YouTube account.
Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your
device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be
able to obtain information about this website’s visitors. Among other things, this information will be used to
generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts
to commit fraud.
Under certain circumstances, additional data processing transactions may be triggered after you have
started to play a YouTube video, which are beyond our control.
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 a corresponding agreement has been requested,
the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement can be revoked at
any time.
For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy
under:
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https://policies.google.com/privacy?hl=en.
Google Web Fonts (local embedding)
This website uses so-called Web 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 Web 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.
Font Awesome (local embedding)
This website uses Font Awesome to ensure the uniform use of fonts on this site. Font Awesome is locally
installed so that a connection to Fonticons, Inc.’s servers will not be established in conjunction with this
application.
For more information on Font Awesome, please and consult the Data Privacy Declaration for Font Awesome
under:
https://fontawesome.com/privacy.
Spotify
We have integrated features of the Spotify music platform into this website. The provider is Spotify AB,
Birger Jarlsgatan 61, 113 56 Stockholm, Sweden. You will be able to recognize Spotify plug-ins when you see
the green logo on this website. An overview of Spotify’s plug-ins can be found at:
https://developer.spotify.com.
The plug-in makes it possible to establish a direct connection between your browser and Spotify’s server
when you visit this website. As a result, Spotify receives the information that you visited this website with
your IP address. If you click the Spotify button while you are logged into your Spotify account, you have the
option to link content from this website with your Spotify profile. Consequently, Spotify will be in a position
to allocate your visit to this website to your user account.
We would like to point out that when using Spotify, cookies are used by Google Analytics so that your usage
data can also be passed on to Google when using Spotify. Google Analytics is a tool of the Google Group for
the analysis of user behavior with headquarters in the USA. Spotify alone is responsible for this integration.
We as website operators have no influence on this processing.
Data are stored and analyzed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate
interest in the attractive acoustic presentation of the website. If a respective declaration of consent has been
obtained (e.g. consent to the archiving of cookies), the data will be processed exclusively on the basis of Art.
6(1)(a) GDPR. Any such consent may be revoked at any time.
For more information, please consult Spotify’s Data Protection Declaration under:
https://www.spotify.com/us/legal/privacy-policy/.
If you do not want Spotify to be able to allocate the visit of this website to your Spotify user account, please
log out of your Spotify user account while visiting our sites.
8. eCommerce and payment service providers
Processing of data (customer and contract data)
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We collect, process, and use personal data only to the extent necessary for the establishment, content
organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art.
6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual
actions. We collect, process, and use personal data concerning the use of this website (usage data) only to
the extent that this is necessary to make it possible for users to utilize the services and to bill for them.
The collected customer data shall be eradicated upon completion of the order or the termination of the
business relationship. This shall be without prejudice to any statutory retention mandates.
Data transfer upon closing of contracts for online stores, retailers, and the shipment of
merchandise
We share personal data with third parties only if this is necessary in conjunction with the handling of the
contract; for instance, with companies entrusted with the shipment of goods or the financial institution
tasked with the processing of payments. Any further transfer of data shall not occur or shall only occur if you
have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your
express consent, for instance for advertising purposes, shall not occur.
The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the
fulfilment of a contract or for pre-contractual actions.
Order processing via dropshipping
If you order goods from us, your order may be shipped to you directly from our dealers (dropshipping). For
this purpose, we pass on your name, the delivery address and – as far as this is necessary for delivery – your
telephone number to the shipping company. This information is passed on exclusively for the purpose of
delivering the goods.
The legal basis for data processing is Art. 6(1)(b) GDPR (fulfilment of contract) and our legitimate interest in
the fastest and most effective possible purchase processing in accordance with Art. 6(1)(f) GDPR.
We use the following dealer in the context of dropshipping:
EasyMerchandising GmbH
Papenstraße 27a
22089 Hamburg
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”).
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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.
instant transfer Sofort
The provider of this payment service is Sofort GmbH, Theresienhöhe 12, 80339 Munich, Germany
(hereinafter “Sofort GmbH”). With the help of the “Sofortüberweisung” procedure, we receive a payment
confirmation from Sofort GmbH in real time and can immediately begin to fulfill our obligations. If you have
chosen the payment method “Sofortüberweisung”, please send the PIN and a valid TAN to Sofort GmbH,
with which it can log into your online banking account. Sofort GmbH automatically checks your account
balance after logging in and carries out the transfer to us with the help of the TAN you have transmitted.
Afterwards, it immediately sends us a transaction confirmation. After you log in, your turnover, the credit
limit of the overdraft facility and the existence of other accounts and their balances are also checked
automatically. In addition to the PIN and the TAN, the payment data entered by you as well as personal data
will be transmitted to Sofort GmbH. The data about your person are first and last name, address, telephone
number(s), email address, IP address and possibly other data required for payment processing. The
transmission of this data is necessary to determine your identity beyond doubt and to prevent fraud
attempts. For details on payment with immediate bank transfer, please refer to the following links:
https://www.sofort.de/datenschutz.html and
https://www.klarna.com/sofort/.
American Express
The provider of this payment service is the American Express Europe S.A., Theodor-Heuss-Allee 112, 60486
Frankfurt am Main, Germany (hereinafter “American Express”).
American Express may transfer data to its parent company in the US. The data transfer to the US is based on
the Binding Corporate Rules. Details can be found here:
https://www.americanexpress.com/en-pl/company/legal/privacy-centre/european-implementingprinciples/.
For more information, please see the American Express privacy policy:
https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html.
Mastercard
The provider of this payment service is the Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410
Waterloo, Belgium (hereinafter “Mastercard”).
Mastercard may transfer data to its parent company in the US. The data transfer to the US is based on
Mastercard’s Binding Corporate Rules. Details can be found here:
https://www.mastercard.de/de-de/datenschutz.html and
https://www.mastercard.us/content/dam/mccom/global/documents/mastercard-bcrs.pdf.
VISA
The provider of this payment service is the Visa Europe Services Inc, London Branch, 1 Sheldon Square,
London W2 6TT, United Kingdom (hereinafter “VISA”).
Great Britain is considered a secure non-EU country as far as data protection legislation is concerned. This
means that the data protection level in Great Britain is equivalent to the data protection level of the
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European Union.
VISA may transfer data to its parent company in the US. The data transfer to the US is based on the standard
contractual clauses of the EU Commission. Details can be found here:
https://www.visa.de/nutzungsbedingungen/visa-globale-datenschutzmitteilung/mitteilung-zuzustandigkeitsfragen-fur-den-ewr.html.
For more information, please refer to VISA’s privacy policy:
https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
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