Data Protection Declaration
1) Information on the Collection of Personal Data and Contact Details of the Controller
1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.
1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Rita Dowling, The Sanctuary, Kilmoon East 1, V95W667 Lisdoonvarna, Co. Clare, Irland, Tel.: 017684091060,
E-mail: email@example.com. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
1.3 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.
2) Data Collection When You Visit Our Website
When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:
- Our visited website
- Date and time at the moment of access
- Amount of data sent in bytes
- Source/reference from which you came to the page
- Browser used
- Operating system used
- IP address used (if applicable: in anonymized form)
Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.
Hosting by Wix. We use the website building system of Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel ("Wix") for the purpose of hosting and displaying the website based on processing on our behalf. All data collected on our website is processed on Wix's servers. As part of the aforementioned services provided by Wix, data may also be transferred to Wix Inc., 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA, as part of further processing on our behalf. In the case of data transfer to Wix in Israel, the adequate level of data protection is guaranteed by an adequacy decision of the European Commission. For further information on data protection at Wix, please visit the following website: https://de.wix.com/about/privacy
The extent to which personal data is processed is described below. Any further processing on other servers than the aforementioned of Wix will only take place within the scope communicated below.
In order to make your visit to our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your end 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 terminal and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process specific user information such as browser and location data as well as IP address values according to individual requirements. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can check the duration of the respective cookie storage in the overview of the cookie settings of your web browser.
In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the content of a virtual shopping basket for a later visit to the website). If personal data are also processed by individual cookies set by us, the processing is carried out in accordance with Art. 6 (1) point b GDPR either for the execution of the contract or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit. We work together with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). You will be informed individually and separately about the use of such cookies and the scope of the information collected in each case within the following sections.
Please note that you can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. Each browser differs in the way it manages the cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You will find these for the respective browsers under the following links:
- Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- Firefox: https://www.mozilla.org/en-US/privacy/websites/#cookies
- Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en
- Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- Opera: https://help.opera.com/en/latest/web-preferences/#cookies
Please note that the functionality of our website may be limited if cookies are not accepted.
5) Contacting Us
When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration. The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.
6) Data Processing When Opening a Customer Account and for Contract Processing
Pursuant to Art. 6 (1) point b GDPR, personal data will continue to be collected and processed if you provide it to us for the execution of a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. It is possible to delete your customer account at any time. This can be done by sending a message to the above-mentioned address of the controller. We store and use the data provided by you for contract processing. After complete processing of the contract or deletion of your customer account, your data will be blocked in consideration of tax and commercial retention periods and deleted after expiry of these periods, unless you have expressly consented to further use of your data or a legally permitted further use of data has been reserved by our site, about which we will inform you accordingly below.
7) Commentary Function
As a user you can subscribe to the follow-up comments. You will receive a confirmation e-mail to ensure that you are the owner of the specified e-mail address (double opt-in procedure). The legal basis for data processing in the case of subscribing to comments is Art. 6 (1) point a GDPR. You can unsubscribe from current comment subscriptions at any time with effect for the future. Please refer to the confirmation e-mail for further information on the option for unsubscribing.
8) Use of Client Data for Direct Advertising
8.1 If you subscribe to our e-mail newsletter, we will send you regular information about our offers. The only mandatory information for sending the newsletter is your e-mail address. The indication of additional possible data is voluntary and is used to allow us to address you personally. We use the so-called double opt-in procedure for sending newsletters. This means that we will not send you an e-mail newsletter, unless you have expressly confirmed to us that you agree to the sending of such a newsletter. We will then send you a confirmation e-mail asking you to confirm that you wish to receive future newsletters by clicking on an appropriate link.
By activating the confirmation link, you give us your consent to the use of your personal data in accordance with Art. 6 (1) point a GDPR. When you register for the newsletter, we store your IP address entered by the Internet Service Provider (ISP) as well as the date and time of registration so that we can trace any possible misuse of your e-mail address at a later time. The data collected by us when you register for the newsletter will be used exclusively for the purpose of advertising by means of the newsletter. You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a message to the responsible person named above. After your cancellation, your e-mail address will immediately be deleted from our newsletter distribution list, unless you have expressly consented to further use of your data or we reserve the right to use data in excess thereof, which is permitted by law and about which we inform you in this declaration.
8.2 If you have provided us with your e-mail address when purchasing products, we reserve the right to regularly send you offers for products similar to those already purchased by e-mail. Pursuant to Section 7 (3) German law against unfair competition, we do not need to obtain separate consent from you. In this respect, data processing is carried out solely on the basis of our legitimate interest in personalized direct advertising pursuant to Art. 6 (1) point f GDPR. If you have initially objected to the use of your e-mail address for this purpose, we will not send you an e-mail. You are entitled to object to the future use of your e-mail address for the aforementioned advertising purpose at any time by notifying the controller named at the beginning of this document. In this regard, you only have to pay the transmission costs according to the basic tariffs. Upon receipt of your objection, the use of your e-mail address for advertising purposes will cease immediately.
8.3 Our e-mail newsletters are sent via the technical service provider, The Rocket Science Group, LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (https://mailchimp.com), to whom we pass on the data you provided when registering for the newsletter. This disclosure is made in accordance with Art. 6 (1) point f GDPR and serves our legitimate interest in the use of an effective, secure and user-friendly newsletter system. Please note that your data is usually transferred to a MailChimp server in the USA and stored there.
MailChimp uses this information to send and statistically evaluate the newsletter on our behalf. For evaluation purposes, the e-mails sent contain so-called web beacons or tracking pixels, which represent single-pixel image files stored on our website. This allows us to determine whether a newsletter message has been opened and which links have been clicked on. In addition, technical information is recorded (e.g. time of retrieval, IP address, browser type and operating system). The data is raised exclusively in a pseudonymized format and is not linked with other personal data from you. A direct personal relationship is excluded. This data is used exclusively for 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 wish to object to the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter. Furthermore, MailChimp can use this data according to Art. 6 (1) point f GDPR even on the basis of its own legitimate interest in the demand-oriented design and optimization of the service as well as for market research purposes, for example to determine from which countries recipients come. However, MailChimp does not use the data of our newsletter recipients to address those recipients or pass that data on to third parties.
To protect your data in the USA, we have concluded a data processing agreement ("Data-Processing-Agreement") with MailChimp on the basis of the standard contractual clauses of the European Commission to enable the transmission of your personal data to MailChimp. If you are interested in viewing this data processing agreement, you can do so at the following Internet link: https://mailchimp.com/legal/data-processing-addendum/
9) Processing of Data for the Purpose of Order Handling
9.1 The personal data collected by us will be passed on to the transport company commissioned with the delivery within the scope of contract processing, insofar as this is necessary for the delivery of the goods. We will pass on your payment data to the commissioned credit institution within the framework of payment processing, if this is necessary for payment handling. If payment service providers are used, we explicitly inform you of this below. The legal basis for the transfer of data is Art. 6 (1) point b GDPR.
9.2 Use of Payment Service Providers
When you pay via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "payment by instalments" via PayPal, we transmit your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). The transfer takes place in accordance with Art. 6 (1) point b GDPR and only insofar as this is necessary for payment processing.
PayPal reserves the right to carry out credit checks for the payment methods credit card via PayPal, direct debit via PayPal or, if offered, "purchase on account" or "payment by installments" via PayPal. For this purpose, your payment data may be passed on to credit agencies on the basis of PayPal's legitimate interest in determining your solvency pursuant to Art. 6 (1) point f GDPR. PayPal uses the result of the credit assessment in relation to the statistical probability of non-payment for the purpose of deciding on the provision of the respective payment method. The credit report can contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on recognized scientific, mathematical-statistical methods. The calculation of the score values includes, but is not limited to, address data. For further information on data protection law, including the credit agencies used, please refer to PayPal's data protection declaration at: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full.
You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary for contractual payment processing.
- Wix Payments
If you choose the payment method Wix Payments, the payment will be processed via the payment system of Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel (hereinafter referred to as "Wix "). Wix Payments enables payments via all major credit card formats and, depending on the region, via additional payment methods. The individual payment methods offered by Wix Payments will be communicated to you on our website.
In the case of payments via Wix Payments, your payment data (e.g. payment amount, information on the means of payment used, details of the payee) as well as your confirmation that the payment data is correct will be collected, processed and transferred by Wix to the credit institution commissioned with the payment in accordance with Art. 6 (1) point b GDPR. This processing will only take place to the extent necessary for the execution of the payment. Wix will then authenticate the payment using the authentication procedure provided for you at your bank.
In this context, data may also be transferred to Wix Inc., 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA, for further processing on behalf of Wix Inc.
You can find further information about Wix's data protection at the following website: https://www.wix.com/about/privacy
Google Ads Conversion Tracking
This website uses the online advertising program "Google Ads" and the conversion tracking within the framework of Google Ads, operated by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 ESW5, Ireland ("Google"). We use the program of Google Ads to draw attention to our attractive offers with the help of advertising materials (so-called Google Adwords) on external websites. We can determine, in relation to the advertising campaigns data, how successful the individual advertising measures are. We are interested in showing you advertisements that are of interest to you. We want to make our website more interesting for you and to achieve a fair calculation of advertising costs.
The conversion tracking cookie is set on a user’s browser, if he clicks on an ad delivered by Google. Cookies are small text files that are stored on your computer system. These cookies usually lose their validity after 30 days and are not used for personal identification. If the user visits a certain page of this website and if the cookie has not yet expired, Google and we will be able to recognize that the user clicked on the ad and was forwarded to this page. Each Google Ads customer gets a different cookie. Thus, cookies cannot be traced via the website of Google Ads customers. The information collected by the conversion cookies is used to provide aggregate conversion statistics to Google Ads customers who have opted-in for conversion tracking. Customers are informed about the total number of users who clicked on the ad and were forwarded to a conversion tracking tag page. However, they do not get any information enabling them to identify users personally. If you do not want to participate in the tracking program, you can refuse the use of this program by deactivating the Google Conversion Tracking cookie via your Internet browser through the user settings. In this case, you will not be included in the conversion tracking statistics. We use Google Ads on the basis of our legitimate interest in targeted advertising in accordance with Art. 6 (1) point f GDPR. When using Google Ads, personal data may also be transmitted to the servers of Google LLC. in the USA.
You can permanently deactivate cookies for advertising preferences by blocking them via a respective setting of your browser software or by downloading and installing the browser plug-in, available under the following link:
To the extent required by law, we have obtained your consent to the processing of your data as described in accordance with Art. 6 (1) point a GDPR. You can withdraw your consent at any time with effect for the future. In order to exercise your right of withdrawal, please follow the procedure described above.
11) Web Analysis Services
Google (Universal) Analytics
This website uses Google (Universal) Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google (Universal) Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website (including the abbreviated IP address) is usually transferred to a Google server and stored there, and may also be transferred to the servers of Google LLC. in the USA.
This website uses Google (Universal) Analytics exclusively with the extension "_anonymizeIp()", which ensures anonymization of the IP address by shortening it and excludes the possibility of direct personal reference. Through the extension, your IP address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area before. Only in exceptional cases will the full IP address be transferred to a server of Google LLC. in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide us with further services related to the use of the website and the Internet. The IP address transmitted by your browser within the framework of Google (Universal) Analytics is not combined with other Google data.
Via a special function called "Demographics", Google Analytics also enables the compilation of statistics with statements about the age, gender and interests of site visitors based on an evaluation of interest-related advertising and with the use of third-party information. This allows the definition and differentiation of user groups of the website for the purpose of target-group-optimized marketing measures. However, data sets collected via "Demographics" cannot be assigned to a specific person.
All the processing described above, in particular the setting of Google Analytics cookies for reading information on the terminal device used, is only carried out if you have given us your express consent in accordance with Art. 6 Para. 1 letter a GDPR. Without this consent, the use of Google Analytics during your visit to our website will not take place.
You can withdraw your consent at any time with effect for the future. To exercise your right of withdrawal of consent, please deactivate this service in the "Cookie-Consent-Tool" provided on the website. We have concluded a data processing agreement with Google for the use of Google Analytics, which obliges Google to protect the data of our site visitors and not to pass it on to third parties.
For the transmission of data from the EU to the USA, Google relies on so-called standard data protection clauses of the European Commission, which are intended to ensure compliance with the European data protection level in the USA.
Further information about Google (Universal) Analytics can be found here: https://policies.google.com/privacy?hl=en&gl=en
12) Tools and Miscellaneous
We use the Zoom service of Zoom Video Communications Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA (hereinafter "Zoom") to conduct online meetings, video conferences and/or webinars.
When using Zoom, different data will be processed. The extend of the processed data depends on the data you provide before or during your participation in an online meeting, video conference or webinar. When using Zoom, data of the communication participants is processed and stored on Zoom servers. This data may include your registration data (name, e-mail address, telephone (optional) and password) and meeting data (topic, participant IP address, device information, description (optional)). In addition, visual and audio contributions of the participants, as well as voice inputs can be processed in chats.
When processing personal data necessary for the performance of a contract with you (this also applies to processing operations which are necessary for the performance of pre-contractual measures), Art. 6 (1) point b GDPR constitutes the legal basis. If you have given us your consent for the processing of your data, the processing will be carried out based on Art. 6 (1) point a GDPR. Consent granted can be revoked at any time with effect for the future.
Otherwise, the legal basis for the processing of data when conducting online meetings, videoconferences or webinars is our legitimate interest pursuant to Art. 6 (1) point f GDPR in the effective conduct of online meetings, webinars or videoconferences.
13) Rights of the Data Subject
13.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:
- Right of access by the data subject pursuant to Art. 15 GDPR: You shall have the right to receive the following information: The personal data processed by us; the purposes of the processing; the categories of processed personal data; the recipients or categories of recipients to whom the personal data have been or will be disclosed; the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling and at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject; the appropriate safeguards pursuant to Article 46 when personal data is transferred to a third country.
- Right to rectification pursuant to Art. 16 GDPR: You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you and/or the right to have incomplete personal data completed which are stored by us.
- Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR: You have the right to obtain from the controller the erasure of personal data concerning you if the conditions of Art. 17 (2) GDPR are fulfilled. However, this right will not apply for exercising the freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims.
- Right to restriction of processing pursuant to Art. 18 GDPR: You have the right to obtain from the controller restriction of processing your personal data for the following reasons: As long as the accuracy of your personal data contested by you will be verified. If you oppose the erasure of your personal data because of unlawful processing and you request the restriction of their use instead. If you require the personal data for the establishment, exercise or defense of legal claims, once we no longer need those data for the purposes of the processing. If you have objected to processing on grounds relating to your personal situation pending the verification whether our legitimate grounds override your grounds.
- Right to be informed pursuant to Art. 19 GDPR: If you have asserted the right of rectification, erasure or restriction of processing against the controller, he is obliged to communicate to each recipient to whom the personal date has been disclosed any rectification or erasure of personal data or restriction of processing, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients.
- Right to data portability pursuant to Art. 20 GDPR: You shall have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or to require that those data be transmitted to another controller, where technically feasible.
- Right to withdraw a given consent pursuant to Art. 7 (3) GDPR: You have the right to withdraw your consent for the processing of personal data at any time with effect for the future. In the event of withdrawal, we will immediately erase the data concerned, unless further processing can be based on a legal basis for processing without consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- Right to lodge a complaint pursuant to Art. 77 GDPR: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
13.2 RIGHT TO OBJECT
IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.
14) Duration of Storage of Personal Data
The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).
If personal data is processed on the basis of an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.
If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.
When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
If personal data is processed for the purpose of direct marketing on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.
Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.