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PRIVACY POLICY

1. General Information

 

The following information provides a simple overview of what happens to your personal data when you visit this website (circledwardrobe.com). Personal data refers to any data that can personally identify you. Detailed information on data protection can be found in our privacy policy listed below this text.

 

Responsible Body

 

If you have any further questions, need more information about our data storage, or wish to file a complaint, please contact us, the responsible body, via email at office@circledwardrobe.com or use the following contact information:

 

Circled Wardrobe UG (haftungsbeschränkt)

Große Bleiche 15

55116 Mainz

Germany

 

Phone: +49 176 20229765

Email: office@circledwardrobe.com

 

The responsible body is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g., names, email addresses, etc.).

 

Data Collection on This Website

 

Who is responsible for data collection on this website?

 

Data processing on this website is carried out by the website operator. You can find their contact details in the "Responsible Body" section of this privacy policy.

 

How do we collect your data?

 

Your data is collected when you provide it to us. This can be, for example, data that you enter into a contact form.

 

Other data is automatically collected or obtained with your consent when you visit the website through our IT systems. These are primarily technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

 

What do we use your data for?

 

Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior.

 

What rights do you have regarding your data?

 

You have the right to obtain free information about the origin, recipient, and purpose of your stored personal data at any time. You also have the right to request the correction or deletion of this data. If you have given consent for data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the relevant supervisory authority.

 

For this purpose and for further questions regarding data protection, you can contact us at any time.

 

2. Hosting

 

We host the content of our website with the following provider:

 

WIX

 

The provider is Wix.com Ltd., 40 Namal Tel Aviv St., Tel Aviv 6350671, Israel (hereinafter "WIX").

 

WIX is a tool for creating and hosting websites. When you visit our website, WIX analyzes user behavior, visitor sources, the region of website visitors, and visitor numbers. WIX stores cookies on your browser that are necessary for the display of the website and for ensuring security (necessary cookies).

 

The data collected through WIX may be stored on various servers worldwide. WIX's servers are located, among others, in the United States.

 

For details, please refer to WIX's privacy policy:

https://www.wix.com/about/privacy.

 

The transfer of data to the United States and other third countries is based on the standard contractual clauses of the European Commission or comparable guarantees pursuant to Art. 46 GDPR, as stated by WIX. Details can be found here:

https://www.wix.com/about/privacy-dpa-users.

 

The use of WIX is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in displaying our website as reliably as possible. If the corresponding consent has been obtained, processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, to the extent that the consent includes the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be withdrawn at any time.

 

Data Processing 

 

We have concluded a contract for data processing on behalf of the controller (DPA) for the use of the service mentioned above. This is a legally required contract that ensures that this service processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

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3. General Information and Mandatory Information

 

Data Privacy

 

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

 

When you use this website, various personal data are collected. Personal data are data with which you can be personally identified. This privacy policy explains what data we collect and for what purpose, as well as how and for what purpose this is done.

 

We would like to point out that data transmission over the Internet (e.g. communication by e-mail) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.

 

Storage Duration

 

Unless a more specific storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for processing the data ceases to apply. If you make a legitimate request for deletion or withdraw 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 retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

 

General Information on the Legal Bases of Data Processing on this Website

 

If you have given your consent to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, if special categories of data are processed in accordance with Art. 9 para. 1 GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing also takes place on the basis of Art. 49 para. 1 lit. a GDPR. If you have given your consent to the storage of cookies or access to information on your device (e.g. via device fingerprinting), data processing also takes place on the basis of § 25 para. 1 TTDSG. The consent can be revoked at any time. If your data are necessary for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation based on Art. 6 para. 1 lit. c GDPR. Data processing may also take place on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. The relevant legal bases for the respective cases are provided in the following paragraphs of this privacy policy.

 

Note on data transfer to the USA and other third countries

 

We use tools from companies based in the USA or other countries outside the EU that may not have a comparable level of data protection. When these tools are active, your personal data may be transferred to and processed in these third countries. Please note that these countries may not guarantee a data protection level equivalent to that of the EU. For example, US companies may be required to disclose personal data to security authorities without the possibility of legal recourse for affected individuals. Therefore, it cannot be ruled out that US authorities (such as intelligence agencies) may process, analyze, and permanently store data located on US servers for surveillance purposes. We have no control over these processing activities.

 

Withdrawal of your consent to data processing

 

Many data processing operations are only possible with your express consent. You can revoke already given consent at any time. The legality of the data processing carried out until the revocation data processing remains unaffected by the revocation.

 

Right to object to data collection in specific cases and direct marketing (Art. 21 GDPR)

 

If data processing is based on Article 6(1)(e) or (f) of the GDPR, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation, including profiling based on these provisions. The respective legal basis on which processing is based can be found in this data protection statement. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or the processing serves the purpose of asserting, exercising, or defending legal claims (objection according to Article 21(1) GDPR).

 

If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing, including profiling to the extent that it is related to such direct marketing. If you object, your personal data will no longer be used for the purpose of direct marketing (objection according to Article 21(2) GDPR).

 

Right to lodge a complaint with the competent supervisory authority

 

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. The right to lodge a complaint is without prejudice to other administrative or judicial remedies.

 

Right to Data Portability

 

You have the right to receive the personal data that we process based on your consent or in fulfillment of a contract, in a commonly used and machine-readable format, and have the right to transmit those data to another controller, where technically feasible, upon request.

 

Information, Correction, and Deletion

 

You have the right, in accordance with applicable legal provisions, to obtain free information about your stored personal data, their origin, recipients, and the purpose of data processing, and, if applicable, the right to rectification or deletion of such data. For this purpose, as well as for any other questions regarding personal data, you can contact us at any time.

 

Right to Restriction of Processing

 

You have the right to request the restriction of processing of your personal data. You can contact us at any time for this purpose. The right to restrict processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of processing of your personal data.

  • If the processing of your personal data was/is unlawful, but you oppose the deletion of the data and instead request the restriction of their use.

  • If we no longer need your personal data for the purposes of processing, but you need them for the establishment, exercise, or defense of legal claims.

  • If you have objected to the processing of your personal data based on legitimate interests, pending verification of whether our legitimate grounds override yours.

 

If you have restricted the processing of your personal data, this data - apart from its storage - may only be used with your consent or for the assertion, exercise or defense of defense of legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the European Union or of a member state.

 

SSL or TLS encryption

 

For security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator, SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

 

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

 

Objection to advertising e-mails

 

The use of contact data published within the scope of the imprint obligation for the transmission of not expressly requested advertising and information materials is hereby contradicted. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

 

4. Data collection on this website

 

Cookies

 

Our Internet pages use so-called "cookies". Cookies are small data packets and do not cause do no harm to your terminal device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) stored on your end device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your terminal until you delete them yourself or until they are automatically deleted by your web browser.

 

Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies within websites (e.g. cookies for processing payment services).

 

Cookies have various functions. Many cookies are technically necessary, as certain website

website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies can be used to evaluate user behavior or for advertising purposes.

be used for advertising purposes.

 

Cookies that are required to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6 (1) lit. f DSGVO, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG); consent can be revoked at any time.

 

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. When deactivating cookies, the functionality of this website may be limited.

 

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

 

Server log files

 

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

  • browser type and browser version

  • Operating system used

  • referrer URL

  • Host name of the accessing computer

  • Time of the server request

  • IP address

 

This data is not merged with other data sources.

 

The collection of this data is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website - for this purpose, the server log files must be collected.

 

Contact form

 

If you send us inquiries via the contact form, your details from the inquiry form, including the contact data you have provided there, will be used for the purpose of processing the inquiry

and for the case of follow-up questions. We do not pass on this data without your consent.

 

The processing of this data is based on Art. 6 (1) lit. b DSGVO, insofar as your request is related to the performance of a contract or is necessary for the implementation of 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 para. 1 lit. f DSGVO) or on your consent (Art. 6 para. 1 lit. a DSGVO) if this has been requested; consent can be withdrawn at any time.

 

The data you entered in the contact form will remain with us until you request us to delete it, withdraw your consent to storage, or until the purpose for storing the data no longer applies

(e.g. after the processing of your inquiry has been completed). Mandatory legal provisions - in particular retention periods - remain unaffected.

 

Email Inquiry

 

When you contact us via email, your inquiry, including all personal data provided (such as name, inquiry), will be stored and processed by us for the purpose of handling your request. We do not disclose this data without your consent.

 

The processing of this data is based on Art. 6(1)(b) GDPR if your inquiry is related to the performance of a contract or necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in effectively processing inquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if requested; consent can be withdrawn at any time.

 

The data sent to us via contact inquiries will remain with us until you request deletion, withdraw your consent to storage, or the purpose for data storage no longer applies (e.g., after completion of processing your request). Mandatory legal provisions, especially statutory retention periods, remain unaffected.

 

Comment Function on this Website

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For the comment function on this site, in addition to your comment, information about the time of creating the comment and, if you do not post anonymously, the username you have chosen will be stored.

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The comments and the associated data are stored and remain on this website until the commented content has been completely deleted or the comments have to be deleted for legal reasons (e.g., offensive comments).

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The storage of comments is based on your consent (Art. 6(1)(a) GDPR). You can withdraw consent granted by you at any time. For this purpose, a informal notification to us by email is sufficient. The lawfulness of data processing operations already carried out remains unaffected by revocation.

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Google reCAPTCHA

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We use "Google reCAPTCHA" (hereinafter "reCAPTCHA") on our website to protect our Site against spam and abuse. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. The purpose of reCAPTCHA is to verify whether the data input on this website (e.g. in a SignUp form) is made by a human being or by an automated program. For this purpose reCAPTCHA analyzes the behavior of the website visitor based on various characteristics.

This analysis begins automatically as soon as the website visitor enters the website. For the analysis reCAPTCHA evaluates various information (e.g., IP address, length of time the website visitor spends on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The storage and analysis of the data is based on Art. 6 para.1 lit. f DSGVO. The website operator has a legitimate interest in protecting its web offerings from abusive automated spying and SPAM. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent allows the storage of cookies or the access to information in the User's terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be objected at any time.

The use of Google reCAPTCHA is subject to Google's privacy policy and terms of service. By using our website, you acknowledge and agree to the collection and processing of your information by Google in accordance with their privacy policy and terms of service.

For more information on Google reCAPTCHA, please refer to Google's privacy policy and the Google Terms of Use under the following links:

https://policies.google.com/privacy?hl=de and

https://policies.google.com/terms?hl=de.

 

5. Social Media

 

Instagram

 

This website includes features of the Instagram service, which are provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

 

When the social media element is active, a direct connection is established between your device and the Instagram server. As a result, Instagram receives information about your visit to this website.

 

If you are logged into your Instagram account, you can link the content of this website to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate your visit to this website with your user account. We would like to point out that as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Instagram.

 

If consent has been obtained, the use of the above-mentioned service is based on Art. 6 para. 1 lit. a GDPR and § 25 TTDSG. Consent can be revoked at any time. If no consent has been obtained, the use of the service is based on our legitimate interest in the most comprehensive visibility in social media.

 

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 forwarding is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The text of the agreement can be found at: 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 the Facebook or Instagram products. You can assert data subject rights (e.g. requests for information) regarding the 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.

 

The data transfer to the USA is based on the standard contractual clauses of the EU Commission.

Details can be found here:

https://www.facebook.com/legal/EU_data_transfer_addendum,

https://help.instagram.com/519522125107875 und

https://de-de.facebook.com/help/566994660333381.

 

For more information, please see Instagram's privacy policy:

https://instagram.com/about/legal/privacy/.

 

6. Newsletter

 

Newsletter Data

 

If you wish to subscribe to the newsletter offered on the website, we require your email address and information that allows us to verify that you are the owner of the provided email address and that you consent to receiving the newsletter. Further data will not be collected or will only be collected on a voluntary basis. We use this data exclusively for sending the requested information and do not disclose it to third parties.

 

The processing of data entered into the newsletter registration form is based exclusively on your consent (Art. 6 para. 1 lit. a GDPR). You can revoke the consent you have given for the storage of data, email address, and their use for sending the newsletter at any time, for example by clicking on the "Unsubscribe" link in the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the withdrawal.

 

The data you provide to us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter or the purpose for which the data was collected no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion in accordance with our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR.

 

Data stored with us for other purposes remains unaffected by this.

 

After unsubscribing from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist, if necessary, 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 and our interest in complying with legal requirements for sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is not time-limited. You can object to the storage if your interests outweigh our legitimate interest.

 

Mailchimp 

 

We use the services of MailChimp for sending newsletters. MailChimp is a service with which, among other things, the sending of newsletters can be organized and analyzed. When you enter data for the purpose of receiving newsletters (e.g. email address), this data is stored on MailChimp's servers in the USA. With the help of MailChimp, we can analyze our newsletter campaigns. When you open an email sent with MailChimp, a file contained in the email (so-called web-beacon) connects to the servers of MailChimp in the USA. This makes it possible to determine whether a newsletter message has been opened and which links, if any, have been clicked. In addition, technical information is recorded (e.g. time of retrieval, IP address, browser type and operating system). This information cannot be assigned to the respective newsletter recipient. It is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients. If you do not want any analysis by MailChimp, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message. Furthermore, you can also unsubscribe from the newsletter directly in our services. The data you provide for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from the servers of MailChimp after you unsubscribe from the newsletter. Data that has been stored by us for other purposes (e.g. email addresses for the member area) remains unaffected by this. The provider of Mailchimp and thus the recipient of the data is Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA. The transfer of your personal data to a third country such as the USA only occurs on a case-by-case basis, on the basis of an order processing agreement concluded with MailChimp, in accordance with standard contractual clauses agreed with Mailchimp and other security measures permitted by the GDPR, which ensure the security of the processing of your personal data with a level of protection identical to that in the EU. The processing of data processed in the context of sending newsletters is based on your consent (Art. 6 para. 1 lit. a DSGVO). You have the right to object your consent at any time, for example via the "unsubscribe" link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation. 

 

For more details, please refer to the privacy policy of MailChimp at: https://mailchimp.com/de/gdpr/.

 

7. Changes to the Privacy Policy

 

Our privacy policy may be updated at irregular intervals to comply with current legal requirements or to implement changes to our services, such as the introduction of new offerings. The new privacy policy will automatically apply to your next visit.

 

8. Contacting the Data Protection Officer

 

For questions regarding data protection, please send us a message to office@circledwardrobe.com with the subject line "Data Protection".

 

Last updated: 15.04.2023

Quelle:

https://www.e-recht24.de

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