Privacy Policy
The controller responsible for data processing is:
Flavio Holstein
Zur Heide 10
Königs Wusterhausen
We appreciate your interest in our online shop. Protecting your privacy is very important to us. Below, we provide detailed information on how we handle your data. Further down the website, you will also find the privacy policy for using our rowing machines and the Augletics app.
Your data is processed on the basis of the GDPR and in accordance with Section 96 (3) of the TKG.
Privacy Policy for the use of the AUGLETICS rowing machine and the AUGLETICS app
§1 Stored Data
In connection with the use of the rowing machine, particularly when setting up and using a user account, various data are stored in the form of server log files and database entries. These include details of completed training sessions such as the date and time of the workout, duration, distance rowed, average speed achieved, average number of strokes, energy consumption, average and progression of heart rate, average and progression of power, total number of strokes, and the average trainer rating, broken down by consistency, rhythm, drive, stroke length, and movement sequence.
Furthermore, technical raw data is collected as part of quality assurance. This includes the handle displacement, the position of the sliding seat, the speed of the flywheel, the respective resistance setting, and inputs on the screen. This data is linked to the date and time and is stored exclusively for the purpose of improving the software, analyzing errors, and ensuring the quality of the user experience.
When you log in to the device, the training data and raw data are assigned to your personal profile. For this purpose, the time of login and the type of login are also stored, either through a personal login, an RFID key fob (only for devices before 2022), or via quick login. This data is collected exclusively to ensure the proper functioning of the system. This data is explicitly not passed on to advertising partners or used for marketing purposes.
§2 Offline Use and Handling of Personal Data
Our rowing machines can be operated completely offline and without setting up a user account. In this mode, training and raw data are stored as described in §1, but they remain exclusively local to the device. No transmission to servers or third parties takes place. The stored data can be completely deleted by the user at any time. The following option is available in the software for this purpose: “Settings → General → About → Support Options → Delete All Data.”
In offline mode, certain functions are not available. These include the display of the rowing position on a map and the use of the map view, logging into a personal account, uploading training data to the cloud, downloading and installing software updates, and using entertainment functions such as Google Chrome browser, Netflix, YouTube, or Amazon Prime.
If you create a user account, your training data can be stored and linked to your personal profile. Each device also has a unique technical identifier (Ergo-ID). This serves only for identification within the system but is not linked to a name or a person without a user account.
§3 Analysis and Error Reports
To improve the software and ensure stable functionality, we use services from Google Firebase. This is a platform that collects and analyzes both anonymous usage statistics and error reports. The data is collected anonymously and does not allow any conclusions to be drawn about your person.
The web application at webapp.augletics.de, through which you can view your training logs, additionally uses Google Analytics to statistically evaluate the use of this website. Cookies may be stored on your device for this purpose. You can deactivate the storage of cookies in your browser. However, we point out that in this case, there may be restrictions in use. Further information on data use by Google can be found at: https://support.google.com/analytics/answer/6004245?hl=en.
Furthermore, users can activate extended error logging in the device settings under “Features → Experimental Features.” This function is deactivated by default and must be actively switched on by the user. If you activate error logging, additional technical data related directly to an error or crash will be automatically transmitted, such as the circumstances and processes that led to the error, as well as relevant device status information. These extended error reports help us to improve the software in a targeted manner and sustainably increase stability and user experience. The data collected is used exclusively for this purpose, is not linked to personal data, and is not passed on to third parties.
Additionally, the diagnostic tool can be activated under “Settings → General → About → Support Options.” With an existing internet connection, our service staff can then access the raw data mentioned in §1. We will explicitly request this and inform you in advance if an insight into this data should be necessary to solve potential problems with your device.
Furthermore, with an existing internet connection, the software version installed on your device as well as the firmware version are automatically transmitted to our servers, along with the device code (Ergo-ID). This enables our service team to check which versions are installed on your device if necessary, and is particularly important for troubleshooting.
§4 Virtual Map and Google Maps API
If you activate the map function, the Google Maps API is used to display your virtual rowing position. In doing so, the virtual position can be shared along with the nickname you have chosen with other users who are also logged in. In return, their positions and nicknames will be displayed to you. If you deactivate this sharing, your data will not be shared, but at the same time, you will not see any other users on the map.
§5 Information via Email
Currently, we generally do not send emails in connection with your user account. The only exception is that you can send a summary of your training results to the email address you have provided at the touch of a button.
We reserve the right to use this option in the future for notifications about software updates or other product-relevant information. These notifications serve exclusively to provide information about safety-relevant changes or new functions and do not constitute advertising. Under no circumstances will your data, particularly your email address, be passed on to third parties or used for marketing purposes.
§6 Rights of Users
You have the right to receive free information about the personal data stored about you at any time. Furthermore, you have the right to correct incorrect data and to delete your data, provided there are no legal retention obligations. You can send corresponding inquiries to us at any time at: info@augletics.de.
Scope
This privacy policy applies to all AUGLETICS rowing machines, in particular the AUGLETICS Eight Style and the AUGLETICS Eight Sport.
Summary for the Privacy-Conscious
The AUGLETICS rowing machine can be used completely offline. In this case, all data remains exclusively local to the device and can be deleted by the user at any time. Data is only processed online once Wi-Fi is activated and a user account is set up. Training data is never passed on to advertising partners or used for advertising purposes under any circumstances. The use of the map function with Google Maps and the exchange of position and nickname is voluntary and can be deactivated at any time. The email address is used exclusively for sending training results or product-relevant notices, never for advertising purposes, and is never passed on to third parties.
1. Access Data and Hosting
You can visit our websites without providing any personal information. Each time a website is accessed, the web server merely automatically stores a so-called server log file, which contains, for example, the name of the requested file, your IP address, the date and time of access, the amount of data transferred, and the requesting provider (access data) and documents the access. This access data is evaluated exclusively for the purpose of ensuring the trouble-free operation of the site and improving our offer. This serves to protect our legitimate interests in a correct presentation of our offer, which outweigh in the context of a balancing of interests, in accordance with Art. 6 (1) sentence 1 lit. f GDPR. All access data is deleted no later than seven days after the end of your visit to the site.1.1 Hosting
The services for hosting and displaying the website are partly provided by our service providers as part of processing on our behalf. Unless otherwise explained in this privacy policy, all access data and all data collected in forms provided for this purpose on this website are processed on their servers. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy policy. Hoster: Cloudways Ltd. 52 Springvale, Pope Pius XII Street Mosta MST2653 Malta1.2 Content Delivery Network
For the purpose of shorter loading times, we use a so-called Content Delivery Network (“CDN”) for some offers. With this service, content, e.g., large media files, is delivered via regionally distributed servers of external CDN service providers. Therefore, access data is processed on the servers of the service providers. Our service providers act on our behalf as part of data processing. Our service providers are located in and/or use servers in countries outside the EU and the EEA. For these countries, there is no adequacy decision by the European Commission. Our cooperation with them is based on standard data protection clauses of the European Commission. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy policy.2. Data Processing for Contract Execution and Contacting
2.1 Data Processing for Contract Execution
We collect personal data when you voluntarily provide it to us as part of your order or when contacting us (e.g., via contact form or email). Mandatory fields are marked as such because in these cases we absolutely require the data for contract execution or to process your contact, and you cannot complete the order or send the contact without providing them. Which data is collected can be seen from the respective input forms. We use the data provided by you for contract execution and processing your inquiries (including inquiries about and processing of any existing warranty and performance disruption claims as well as any legal update obligations) in accordance with Art. 6 (1) sentence 1 lit. b GDPR. Further information on the processing of your data, in particular on the transfer to our service providers for the purpose of order, payment, and shipping processing, can be found in the following sections of this privacy policy. After complete execution of the contract, your data will be restricted for further processing and deleted after the expiry of any tax and commercial law retention periods in accordance with Art. 6 (1) sentence 1 lit. c GDPR, unless you have expressly consented to further use of your data in accordance with Art. 6 (1) sentence 1 lit. a GDPR or we reserve the right to further data use that is permitted by law and about which we inform you in this policy.2.2 Contacting
As part of customer communication, we collect personal data to process your inquiries in accordance with Art. 6 (1) sentence 1 lit. b GDPR when you voluntarily provide it to us when contacting us (e.g., via contact form, live chat tool, or email). Mandatory fields are marked as such because in these cases we absolutely require the data to process your contact. Which data is collected can be seen from the respective input forms. After your inquiry has been fully processed, your data will be deleted, unless you have expressly consented to further use of your data in accordance with Art. 6 (1) sentence 1 lit. a GDPR or we reserve the right to further data use that is permitted by law and about which we inform you in this policy.ChatGPT
We use ChatGPT for our customer communication. The provider is OpenAI Ireland Limited, 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland, https://openai.com. Therefore, when you contact us, your inquiries including metadata may be transmitted to ChatGPT’s servers and processed there to generate a suitable response. We have configured ChatGPT so that the data we forward to ChatGPT is not used to train the ChatGPT algorithm. Further information can be found here: https://openai.com/en-US/enterprise-privacy/ and https://openai.com/en-US/policies/data-processing-addendum/.Data Processing on Behalf
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that the service provider processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.3. Data Processing for Shipping Purposes
For the fulfillment of the contract in accordance with Art. 6 (1) sentence 1 lit. b GDPR, we pass on your data to the shipping service provider commissioned with the delivery, insofar as this is necessary for the delivery of ordered goods.Data Transfer to Shipping Service Providers for Shipping Notification Purposes
If you have given us your express consent for this during or after your order, we will pass on your email address and telephone number to the selected shipping service provider on the basis of this consent in accordance with Art. 6 (1) sentence 1 lit. a GDPR, so that they can contact you before delivery for the purpose of delivery notification or coordination. Consent can be revoked at any time by sending a message to the contact option described in this privacy policy or directly to the shipping service provider at the contact address listed below. After revocation, we will delete the data provided for this purpose, unless you have expressly consented to further use of your data or we reserve the right to further data use that is permitted by law and about which we inform you in this policy. DHL Paket GmbH Sträßchensweg 10 53113 Bonn Germany DPD Deutschland GmbH Wailandtstraße 1 63741 Aschaffenburg Germany4. Data Processing for Payment Purposes
When processing payments in our online shop, we work with these partners: technical service providers, credit institutions, payment service providers.4.1 Data Processing for Transaction Purposes
Depending on the selected payment method, we pass on the data necessary for processing the payment transaction to our technical service providers, who act on our behalf as part of data processing, or to the commissioned credit institutions or to the selected payment service provider, insofar as this is necessary for processing the payment. This serves the fulfillment of the contract in accordance with Art. 6 (1) sentence 1 lit. b GDPR. In some cases, the payment service providers collect the data required for processing the payment themselves, e.g., on their own website or via a technical integration in the ordering process. In this respect, the privacy policy of the respective payment service provider applies. If you have any questions about our partners for payment processing and the basis of our cooperation with them, please use the contact option described in this privacy policy.4.2 Data Processing for Fraud Prevention and Optimization of Our Payment Processes
If necessary, we provide our service providers with further data, which they use together with the data necessary for processing the payment as our processors for the purpose of fraud prevention and optimization of our payment processes (e.g., invoicing, processing of contested payments, accounting support). This serves to protect our legitimate interests in our protection against fraud and in efficient payment management, which outweigh in the context of a balancing of interests, in accordance with Art. 6 (1) sentence 1 lit. f GDPR.4.3 Identity and Credit Check when Selecting Klarna Payment Services
Klarna Direct Debit, Purchase on Account via Klarna, Klarna Installment Purchase If you decide to use the payment services of Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden (hereinafter Klarna), we ask for your consent according to Art. 6 (1) sentence 1 lit. a GDPR that we may transmit the data necessary for processing the payment and an identity and credit check to Klarna. In Germany, the credit agencies mentioned in Klarna’s Privacy Policy can be used for the identity and credit check. Klarna uses the information received about the statistical probability of a payment default for a balanced decision on the establishment, implementation, or termination of the contractual relationship. You can revoke your consent at any time by sending a message to the contact option mentioned in this privacy policy. This may result in us no longer being able to offer you certain payment options. You can also revoke your consent to this use of personal data at any time towards Klarna.5. Advertising via Email
5.1 Email Newsletter without Registration and Your Right to Object
If we receive your email address in connection with the sale of a product or service and you have not refused or objected to this, or for customers based in Austria (§ 7 (2) ECG) and Switzerland are registered in the Robinson list, we reserve the right (on the basis of § 7 (3) UWG for customers based in Germany or on the basis of § 107 (3) TKG for customers based in Austria, or on the basis of Art. 3 lit o UWG for customers based in Switzerland) to regularly send you offers for similar products from our range to those already purchased by email. This serves to protect our legitimate interests in advertising to our customers, which outweigh in the context of a balancing of interests, in accordance with Art. 6 (1) sentence 1 lit. f GDPR. As a customer based in Austria or Switzerland, you can object to this use of your email address at any time easily and free of charge by sending a message to the contact option described below or via a link provided for this purpose in the advertising email. As a customer based in Germany, you can object to this use of your email address at any time by sending a message to the contact option described below or via a link provided for this purpose in the advertising email, without incurring any costs other than the transmission costs according to the basic rates. After unsubscribing, we will delete your email address from the recipient list, unless you have expressly consented to further use of your data in accordance with Art. 6 (1) sentence 1 lit. a GDPR or we reserve the right to further data use that is permitted by law and about which we inform you in this policy.5.2 Newsletter Distribution
The newsletter may also be sent by our service providers as part of processing on our behalf. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy policy. Our service providers are located in and/or use servers in the following countries for which the European Commission has determined an adequate level of data protection by decision: United Kingdom. Our service providers are located in and/or use servers in these countries: USA, Australia. For this country/these countries, there is no adequacy decision by the European Commission. Our cooperation with them is based on these guarantees: Standard data protection clauses of the European Commission.5.3 Sending Review Requests via Email
If you have given us your express consent for this during or after your order in accordance with Art. 6 (1) sentence 1 lit. a GDPR, we will use your email address for the request to submit a review of your order via the review system we use. This consent can be revoked at any time by sending a message to the contact option described in this privacy policy or via a link provided for this purpose in the review request. The review requests may also be sent by our service providers as part of processing on our behalf. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy policy. Our service providers are located in and/or use servers in the following countries for which the European Commission has determined an adequate level of data protection by decision: United Kingdom6. Cookies and Other Technologies
6.1 General Information
In order to make the visit to our website attractive and to enable the use of certain functions, we use technologies including so-called cookies on various pages. Cookies are small text files that are automatically stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e., after closing your browser (so-called session cookies). Other cookies remain on your device and enable us to recognize your browser on your next visit (persistent cookies). Protection of Privacy for Devices When using our online offer, we use strictly necessary technologies to be able to provide the telemedia service explicitly requested. The storage of information in your device or access to information that is already stored in your device does not require consent in this respect. For functions that are not strictly necessary, the storage of information in your device or access to information that is already stored in your device requires your consent. We point out that if consent is not granted, parts of the website may not be fully usable. Any consent you have given remains in effect until you adjust or reset the respective settings in your device. Any downstream data processing by cookies and other technologies We use such technologies that are strictly necessary for the use of certain functions of our website (e.g., shopping cart function). Through these technologies, IP address, time of visit, device and browser information, and information about your use of our website (e.g., information on the content of the shopping cart) are collected and processed. This serves to protect our legitimate interests in an optimized presentation of our offer, which outweigh in the context of a balancing of interests, in accordance with Art. 6 (1) sentence 1 lit. f GDPR. In addition, we use technologies to fulfill the legal obligations to which we are subject (e.g., to be able to prove consent to the processing of your personal data) as well as for web analysis and online marketing. Further information on this, including the respective legal basis for data processing, can be found in the following sections of this privacy policy. The cookie settings for your browser can be found at the following links: Microsoft Edge™ / Safari™ / Chrome™ / Firefox™ / Opera™ Insofar as you have consented to the use of technologies in accordance with Art. 6 (1) sentence 1 lit. a GDPR, you can revoke your consent at any time by sending a message to the contact option described in the privacy policy. Alternatively, you can also call up the following link: https://augletics.de/datenschutzhinweise/. If cookies are not accepted, the functionality of our website may be restricted.6.2 Use of Borlabs for Consent Management
On our website, we use the Borlabs Cookie Plugin (“Borlabs”) to inform you about the cookies and other technologies we use on our website, and to obtain, manage, and document your consent, if required, to the processing of your personal data by these technologies. This is necessary in accordance with Art. 6 (1) sentence 1 lit. c GDPR to fulfill our legal obligation under Art. 7 (1) GDPR to be able to prove your consent to the processing of your personal data, to which we are subject. Borlabs is an offer from Borlabs – Benjamin A. Bornschein Georg-Wilhelm-Str. 17, 21107 Hamburg, Germany. When you visit our website, Borlabs’ web server stores a so-called Borlabs cookie, which contains information about cookie duration and version, device and browser information, and information about your consent behavior. No personal data is transmitted to Borlabs. Your data will be deleted after one year, unless you have expressly consented to further use of your data in accordance with Art. 6 (1) sentence 1 lit. a GDPR or we reserve the right to further data use that is permitted by law and about which we inform you in this policy.6.3 Use of Calendly
On our website, you have the opportunity to schedule appointments with us. We use the tool “Calendly” for appointment booking. The provider is Calendly LLC, 271 17th St NW, 10th Floor, Atlanta, Georgia 30363, USA (hereinafter “Calendly”). For the purpose of appointment booking, you enter the requested data and the desired date into the mask provided for this purpose. The data entered will be used for planning, conducting, and, if necessary, for follow-up of the appointment. The appointment data is stored for us on Calendly’s servers, whose privacy policy you can view here: https://calendly.com/privacy. The data entered by you remains with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies. Mandatory legal provisions – in particular retention periods – remain unaffected. The legal basis for data processing is Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in making appointment scheduling with interested parties and customers as uncomplicated as possible. If a corresponding consent was requested, processing takes place exclusively on the basis of Art. 6 (1) lit. a GDPR and Section 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s device (e.g., device fingerprinting) within the meaning of the TDDDG. The consent can be revoked at any time. Data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission. Details can be found here: https://calendly.com/pages/dpa. The company has certification according to the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA, which is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/6050.Data Processing on Behalf
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that the service provider processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.7. Use of Cookies and Other Technologies for Web Analysis and Advertising Purposes
Insofar as you have given your consent in accordance with Art. 6 (1) sentence 1 lit. a GDPR, we use the following cookies and other technologies from third-party providers on our website. After the purpose has ceased and the use of the respective technology by us has ended, the data collected in this context will be deleted. You can revoke your consent at any time with effect for the future. Further information on your revocation options can be found in the section “Cookies and other technologies.” Further information including the basis of our cooperation with the individual providers can be found with the individual technologies. If you have any questions about the providers and the basis of our cooperation with them, please use the contact option described in this privacy policy.7.1 Use of Google Services for Web Analysis and Advertising Purposes
We use the technologies of Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (“Google”) presented below. The information automatically collected by Google technologies about your use of our website is generally transmitted to a server of Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA and stored there. There is no adequacy decision by the European Commission for the USA. Our cooperation with them is based on standard data protection clauses of the European Commission. Insofar as your IP address is collected via Google technologies, it will be shortened before storage on Google’s servers by activating IP anonymization. Only in exceptional cases will the full IP address be transmitted to a server of Google and shortened there. Unless otherwise stated for the individual technologies, data processing takes place on the basis of an agreement concluded for the respective technology between joint controllers in accordance with Art. 26 GDPR. Further information about data processing by Google can be found in Google’s Privacy Policy.Google Analytics
For the purpose of website analysis, data (IP address, time of visit, device and browser information, and information about your use of our website) is automatically collected and stored with Google Analytics, from which usage profiles are created using pseudonyms. Cookies can be used for this purpose. Your IP address will generally not be merged with other Google data. Data processing takes place on the basis of an agreement on data processing by Google. For the purpose of optimized marketing of our website, we have activated the data sharing settings for “Google products and services” . This allows Google to access the data collected and processed by Google Analytics and subsequently use it to improve Google services. Data sharing with Google within the framework of these data sharing settings takes place on the basis of an additional agreement between controllers. We have no influence on the subsequent data processing by Google. For the purpose of optimized marketing of our website, we use the so-called User ID function. With the help of this function, we can assign a unique, permanent ID to your interaction data from one or more sessions on our online presence and thus analyze your user behavior across devices and sessions. To create and conduct tests, we also use the Google Analytics extension function Google Optimize. For web analysis, the Google Analytics extension function Google Signals enables so-called “cross-device tracking.” Insofar as your internet-enabled devices are linked to your Google account and you have activated the “personalized advertising” setting in your Google account, Google can create reports on your usage behavior (in particular the cross-device user numbers), even if you change your device. Processing of personal data by us does not take place in this respect; we only receive statistics created on the basis of Google Signals. For web analysis and advertising purposes, the Google Analytics extension function, the so-called DoubleClick cookie, enables recognition of your browser when visiting other websites. Google will use this information to compile reports on website activity and to provide other services related to website usage.Google AdSense
Our website markets space for third-party advertisements via Google AdSense. These advertisements are displayed to you at various points on this website. The so-called DoubleClick cookie enables the display of interest-based advertising through the collection and processing of data (IP address, time of visit, device and browser information, and information about your use of our website) as well as the automatic assignment of a pseudonymous UserID, with the help of which interests are determined based on visits to this and other websites.Google Ads
For advertising purposes in Google search results and on third-party websites, the so-called Google Remarketing cookie is set when you visit our website, which automatically enables interest-based advertising by collecting and processing data (IP address, time of visit, device and browser information, and information about your use of our website) and by means of a pseudonymous cookieID and based on the pages you have visited. Further data processing only takes place if you have activated the “personalized advertising” setting in your Google account. If you are logged in to Google during your visit to our website in this case, Google uses your data together with Google Analytics data to create and define target group lists for cross-device remarketing. For website analysis and event tracking, we measure your subsequent usage behavior via Google Ads Conversion Tracking if you have reached our website via a Google Ads advertisement. Cookies can be used for this purpose and data (IP address, time of visit, device and browser information, and information about your use of our website based on events specified by us, such as visiting a website or newsletter registration) can be collected, from which usage profiles are created using pseudonyms.Google Maps
For the visual representation of geographical information, Google Maps collects data about your use of the Maps functions, in particular the IP address and location data, transmits it to Google, and it is subsequently processed by Google. We have no influence on this subsequent data processing.Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. reCAPTCHA is used by us in particular as part of the checkout and payment process. The use serves to protect our website, our online shop, and the payment process from automated attacks, abusive payment attempts, bot traffic, spam, and fraud attempts. reCAPTCHA is intended to check whether certain actions on our website are performed by a human or by an automated program. For this purpose, reCAPTCHA can analyze the behavior of the website visitor based on various characteristics. This analysis can begin as soon as the protected area or the protected function, in particular the checkout or the PayPal payment process, is called up. For analysis, various information can be processed, such as the IP address, technical information about the browser and device used, duration of stay, interactions with the website, as well as mouse movements or comparable usage characteristics. The data collected during the analysis is forwarded to Google. The use of reCAPTCHA is based on Art. 6 (1) lit. f GDPR. We have a legitimate interest in protecting our online shop, the checkout, and the payment process from automated attacks, abusive use, and fraudulent payment attempts. Insofar as information is stored in or read from the user’s device as part of the use of reCAPTCHA, this is done to provide a safety-relevant function to protect the payment process and to defend against automated abusive use. Google processes the data collected in connection with reCAPTCHA according to the respective applicable Google terms as a processor within the meaning of Art. 28 GDPR. The tool is used on the basis of the corresponding agreements on data processing with Google. As part of the use of Google reCAPTCHA, a transfer of personal data to the USA cannot be excluded. Google LLC is certified according to the EU-US Data Privacy Framework (DPF). Further information on Google’s certification can be found at: https://www.dataprivacyframework.gov/participant/5780.Google Fonts
For the uniform presentation of content on our website, data (IP address, time of visit, device and browser information) is collected by the script code “Google Fonts,” transmitted to Google, and subsequently processed by Google. We have no influence on this subsequent data processing.YouTube Video Plugin
For the integration of third-party content, data (IP address, time of visit, device and browser information) is collected via the YouTube video plugin in the extended data protection mode we use, transmitted to Google, and subsequently processed by Google, only when you play a video.7.2 Web Analysis and Advertising Optimization with Tracify
We use the web analysis service Tracify from Tracify GmbH, Munich (Germany) on our website to evaluate the use of our website and to optimize our marketing measures. Tracify GmbH acts for us in certain configurations as a processor on the basis of a contract according to Article 28 GDPR.
a) Basic Analysis (without consent)
In the basic configuration, Tracify enables an analysis of website use without the use of cookies or similar technologies on your device. Only technical and usage-related information is processed, in particular:
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IP address
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Device and browser information
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Usage data (e.g., pages accessed)
This data is anonymized immediately after collection, so that there is no longer any personal reference. Only anonymized, aggregated data is evaluated. A transfer to third parties or a transfer to third countries does not take place in this configuration.
Legal BasisProcessing takes place on the basis of Article 6 (1) lit. f GDPR. Our legitimate interest lies in the needs-based design of our website as well as the analysis and optimization of our offers.
b) Enhanced tracking (with consent) If you give your consent, we use Tracify in an enhanced configuration.
Use of cookies and tracking technologies
Cookies and similar technologies are used here to record and evaluate user interactions. The storage of information on your terminal device is based on your consent in accordance with Section 25 (1) TDDDG.
Processing of usage and conversion data
As part of the enhanced tracking, information about your use of our website is processed, in particular:
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Page views
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Interactions
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Purchase or completion events
This data may be transmitted to marketing and analysis platforms used by us (e.g., Meta, Google, Outbrain). Personal data may also be processed in this context, in particular:
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IP address
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Device and browser information
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Contact or order data, if applicable (if provided by you)
The recipients process the data under their own responsibility under data protection law.
Third-country transfer
As part of the use, personal data may be transferred to third countries (e.g., USA). The transfer takes place on the basis of suitable guarantees pursuant to Article 46 GDPR (e.g., standard contractual clauses) or – where applicable – on the basis of an adequacy decision (e.g., EU-U.S. Data Privacy Framework).
Storage period Personal data is only processed for as long as is necessary for the stated purposes.
Legal basis and withdrawal
Processing is carried out on the basis of your consent in accordance with Article 6(1)(a) GDPR and Section 25(1) TDDDG. You can withdraw your consent at any time with effect for the future, e.g., via our consent management tool.
7.3 Use of Facebook services for web analysis and advertising purposes
Use of Facebook Pixel
We use the Facebook Pixel as part of the technologies of Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland (“Facebook (by Meta)” or “Meta Platforms Ireland”) described below. With the Facebook Pixel, data (IP address, time of visit, device and browser information as well as information on your use of our website based on events specified by us, such as visiting a website or newsletter registration) is automatically collected and stored, from which usage profiles are created using pseudonyms. As part of the so-called enhanced data matching, information is also collected and stored in hashed form for matching purposes, with which individuals can be identified (e.g., names, email addresses, and telephone numbers). For this purpose, a cookie is automatically set by the Facebook Pixel when you visit our website, which automatically enables your browser to be recognized when you visit other websites by means of a pseudonymous cookie ID. Facebook (by Meta) will combine this information with other data from your Facebook account and use it to compile reports on website activity and to provide other services associated with website use, in particular personalized and group-based advertising. The information automatically collected by Facebook (by Meta) technologies about your use of our website is usually transmitted to a server of Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, USA and stored there. There is no adequacy decision by the European Commission for the USA. Insofar as the data transfer to the USA falls within our responsibility, our cooperation is based on standard data protection clauses of the European Commission. Further information about data processing by Facebook can be found in the privacy policy of Facebook (by Meta).Facebook Analytics
As part of the Facebook Business Tools, statistics about visitor activity on our website are created from the data collected with the Facebook Pixel about your use of our website. Data processing is based on an agreement on data processing by Facebook (by Meta). Your analysis serves the optimal presentation and marketing of our website.Facebook Ads (Ads Manager)
We use Facebook Ads to advertise this website on Facebook (by Meta) and on other platforms. We determine the parameters of the respective advertising campaign. Facebook (by Meta) is responsible for the exact implementation, in particular the decision on the placement of the ads for individual users. Unless otherwise stated for the individual technologies, data processing is based on an agreement between joint controllers in accordance with Art. 26 GDPR. The joint responsibility is limited to the collection of the data and its transmission to Meta Platforms Ireland. Subsequent data processing by Meta Platforms Ireland is not covered by this. On the basis of the statistics on visitor activity on our website created via Facebook Pixel, we operate group-based advertising on Facebook (by Meta) via Facebook Custom Audience by determining the characteristics of the respective target group. As part of the enhanced data matching (see above) that takes place to determine the respective target group, Facebook (by Meta) acts as our processor. On the basis of the pseudonymous cookie ID set by the Facebook Pixel and the data collected about your usage behavior on our website, we operate personalized advertising via Facebook Pixel Remarketing. Via Facebook Pixel Conversions, we measure your subsequent usage behavior for web analysis and event tracking if you reached our website via an advertisement from Facebook Ads. Data processing is based on an agreement on data processing by Facebook (by Meta).7.4 Advertising in ChatGPT (OpenAI Ads)
We place advertisements within ChatGPT. The provider is OpenAI Ireland Limited, 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland. OpenAI processes data to select and display the ads on its platform. As part of our advertising campaigns, we receive aggregated reports, for example on impressions and clicks. The content of your conversations with ChatGPT is not disclosed to us.
If you click on one of our ads and thereby access our website, the access data described in Section 1 will be processed. Further information on ads in ChatGPT and data processing by OpenAI can be found at https://help.openai.com/en/articles/20001047-ads-in-chatgpt and https://openai.com/policies/eu-privacy-policy/.
8. Integration of the Trusted Shops Trustbadge/ other widgets
Trusted Shops widgets (e.g., Trusted Shops Trustbadge) are integrated on this website to display Trusted Shops services (e.g., seal of approval, collected reviews) and to offer Trusted Shops products to buyers after an order. This serves to protect our overriding legitimate interests in optimal marketing by enabling secure shopping in accordance with Art. 6 (1) sentence 1 lit. f GDPR. The Trustbadge and the services advertised with it are an offer from Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne (Trusted Shops), with whom we are joint controllers under data protection law in accordance with Art. 26 GDPR. In the following, we inform you about the essential contractual content in accordance with Art. 26 (2) GDPR as part of these data protection notices. Within the framework of the joint responsibility existing between us and Trusted Shops GmbH, please contact Trusted Shops GmbH preferentially for data protection questions and to assert your rights; you can find their contact details here. Further information on data protection can be found at the following link here. Regardless of this, you can always contact us using the contact option described in this privacy policy. Your request will then, if necessary, be passed on to the other controller for a response.8.1 Data processing when integrating the Trustbadge/ other widgets
The Trustbadge is provided by a US CDN provider (Content Delivery Network) as part of joint responsibility. An adequate level of data protection is ensured by standard data protection clauses and further contractual measures. Further information on data protection at Trusted Shops GmbH can be found here. When the Trustbadge is called up, the web server automatically saves a so-called server log file, which also contains your IP address, date and time of the call-up, amount of data transferred and the requesting provider (access data) and documents the call-up. The IP address is anonymized immediately after collection so that the stored data cannot be assigned to you personally. The anonymized data is used in particular for statistical purposes and for error analysis.8.2 Data processing after order completion
After completion of the order, your email address, hashed by a cryptological one-way function, is transmitted to Trusted Shops GmbH. The legal basis is Art. 6 (1) sentence 1 lit. f GDPR. This serves to check whether you are already registered for services at Trusted Shops GmbH and is therefore necessary for the fulfillment of our and Trusted Shops’ overriding legitimate interests in the provision of the buyer protection linked to the specific order and the transactional review services in accordance with Art. 6 (1) sentence 1 lit. f GDPR. If this is the case, further processing takes place in accordance with the contractual agreement made between you and Trusted Shops. If you are not yet registered for the services, you will then be given the opportunity to do so for the first time. Further processing after registration has taken place is also based on the contractual agreement with Trusted Shops GmbH. If you do not register, all transmitted data will be automatically deleted by Trusted Shops GmbH and a personal reference is then no longer possible. Trusted Shops uses service providers in the areas of hosting, monitoring, and logging. The legal basis is Art. 6 (1) lit. f GDPR for the purpose of ensuring trouble-free operation. Processing may take place in third countries (USA and Israel). An adequate level of data protection is ensured in the case of the USA by standard data protection clauses and further contractual measures and in the case of Israel by an adequacy decision.9. ManageWP
We manage this website using the ManageWP tool. The provider is GoDaddy.com WP Europe, Trg republike 5, 11000 Belgrade, Serbia (hereinafter ManageWP). With ManageWP, we can, among other things, monitor the security and performance of our website and create automatic backups. ManageWP therefore has access to all website content, including our databases. ManageWP is hosted on the provider’s servers. The use of ManageWP is based on Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in the most effective and secure operation of its website(s). If a corresponding consent has been requested, processing takes place exclusively on the basis of Art. 6 (1) lit. a GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn 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 required by data protection law, which ensures that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.10. Social Media
Our online presence on Facebook (by Meta), Instagram (by Meta), YouTube, LinkedIn
Insofar as you have given your consent to the respective social media operator in accordance with Art. 6 (1) sentence 1 lit. a GDPR, your data will be automatically collected and stored for market research and advertising purposes when you visit our online presence on the social media mentioned above, from which usage profiles are created using pseudonyms. These can be used, for example, to place advertisements within and outside the platforms that presumably correspond to your interests. Cookies are usually used for this purpose. For detailed information on the processing and use of data by the respective social media operator, as well as a contact option and your rights in this regard and setting options for protecting your privacy, please refer to the providers’ privacy policies linked below. Should you still need help in this regard, you can contact us. Facebook (by Meta) is an offer from Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland (“Meta Platforms Ireland”). The information automatically collected by Meta Platforms Ireland about your use of our online presence on Facebook (by Meta) is usually transmitted to a server of Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, USA and stored there. There is no adequacy decision by the European Commission for the USA. Our cooperation with them is based on standard data protection clauses of the European Commission. Data processing in the context of visiting a Facebook (by Meta) fan page is based on an agreement between joint controllers in accordance with Art. 26 GDPR. Further information (information on insights data) can be found here. Instagram (by Meta) is an offer from Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland (“Meta Platforms Ireland”). The information automatically collected by Meta Platforms Ireland about your use of our online presence on Instagram is usually transmitted to a server of Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, USA and stored there. There is no adequacy decision by the European Commission for the USA. Our cooperation with them is based on standard data protection clauses of the European Commission. Data processing in the context of visiting an Instagram (by Meta) fan page is based on an agreement between joint controllers in accordance with Art. 26 GDPR. Further information (information on insights data) can be found here. YouTube is an offer from Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). The information automatically collected by Google about your use of our online presence on YouTube is usually transmitted to a server of Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA and stored there. There is no adequacy decision by the European Commission for the USA. Our cooperation with them is based on standard data protection clauses of the European Commission. LinkedIn is an offer from LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland (“LinkedIn”). The information automatically collected by LinkedIn about your use of our online presence on LinkedIn is usually transmitted to a server of LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA and stored there. There is no adequacy decision by the European Commission for the USA. Our cooperation with them is based on standard data protection clauses of the European Commission.11. Contact options and your rights
11.1 Your rights
As a data subject, you have the following rights:- pursuant to Art. 15 GDPR, the right to request information about your personal data processed by us to the extent specified therein;
- pursuant to Art. 16 GDPR, the right to immediately request the correction of incorrect or completion of your personal data stored by us;
- pursuant to Art. 17 GDPR, the right to request the deletion of your personal data stored by us, unless further processing is required
- to exercise the right to freedom of expression and information;
- to fulfill a legal obligation;
- for reasons of public interest or
- for the assertion, exercise, or defense of legal claims;
- pursuant to Art. 18 GDPR, the right to request the restriction of the processing of your personal data, insofar as
- the accuracy of the data is disputed by you;
- the processing is unlawful, but you refuse its deletion;
- we no longer need the data, but you need it to assert, exercise, or defend legal claims or
- you have lodged an objection to the processing in accordance with Art. 21 GDPR;
- pursuant to Art. 20 GDPR, the right to receive your personal data that you have provided to us in a structured, common, and machine-readable format or to request transmission to another controller;
- pursuant to Art. 77 GDPR, the right to complain to a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or work or our company headquarters for this purpose.
| Right to object Insofar as we process personal data as explained above to protect our overriding legitimate interests as part of a balancing of interests, you can object to this processing with effect for the future. If the processing is for direct marketing purposes, you can exercise this right at any time as described above. Insofar as the processing is for other purposes, you only have a right to object if there are reasons arising from your particular situation. After exercising your right to object, we will no longer process your personal data for these purposes unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights, and freedoms, or if the processing serves the assertion, exercise, or defense of legal claims. This does not apply if the processing is for direct marketing purposes. In that case, we will no longer process your personal data for this purpose. |