CONTACT | Rita Dowling

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, V95W667, Ireland, Phone.: +35 3877 179 784, e-mail: team.ritadowling@gmail.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.

2) Data Collection When You Visit Our Website

2.1 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.

2.2 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.

3) Hosting & Content Delivery Network

Wix

For the hosting of our website and the display of the page content, we use the system of the following provider: Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel

Data is also transferred to: Wix Inc., 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA

All data collected on our website is processed on the provider's servers. We have concluded an order processing agreement with the provider, ensuring the protection of our site visitors' data and prohibiting unauthorised disclosure to third parties.

In case of data transfer to the provider's location, an adequate level of data protection is guaranteed by an adequacy decision of the European Commission.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

4) Contacting Us

4.1 Calendly

For the provision of an online appointment booking function, we use the services of the following provider: Calendly, LLC, BB&T Tower, 271 17th St NW, Atlanta, GA 30363, USA

For the purpose of making an appointment, your first name, surname and e-mail address (and telephone number, if a telephone appointment is requested) are collected in accordance with Art. 6 (1) point b GDPR and transferred to the provider in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in effective customer management and efficient appointment management and stored there for the purpose of organising the appointments.

After the appointment has been held or after the agreed appointment period has expired, your data will be deleted by the provider.

We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.

4.2 Own function for online appointments

We process your personal data within the framework of the online appointment arrangement provided. You can find out which data we collect for online appointments from the respective form or the appointment request for making an appointment. If certain data is necessary to make an online appointment, we will indicate this on the form or in the appointment request. If we provide you with a free text field on the form, you can describe your request in more detail there. You can also control which additional data you would like to enter. The data you provide will be stored and used exclusively for the purpose of making an appointment. When processing personal data which are necessary for the fulfilment of a contract with you (this also applies to processing operations which are necessary for the implementation of pre-contractual measures), Art. 6 para. 1 letter b GDPR serves as the legal basis. If you have given us your consent to process your data, the processing will take place on the basis of Art. 6 para. 1 lit. a GDPR. Consent that has been granted can be revoked at any time by sending a message to the person responsible named at the beginning of this declaration.

4.3 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.

5) Use of Client Data for Direct Advertising

Subscribe to our e-mail newsletter

If you register for our e-mail newsletter, we will regularly send you information about our offers. The only mandatory data for sending the newsletter is your e-mail address. The provision of further data is voluntary and will be used to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an e-mail newsletter once you have expressly confirmed that you consent to receiving newsletters. We will then send you a confirmation e-mail asking you to confirm that you wish to receive the newsletter in future by clicking on an appropriate link.

By activating the confirmation link, you give us your consent for the use of your personal data pursuant to Art. 6 (1) point a GPPR. When you register for the newsletter, we store your IP address entered by your Internet service provider (ISP) as well as the date and time of registration for the purpose of tracing any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter is used exclusively for the promotional purposes by way of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the responsible person named at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data, or we reserve the right to a more extensive use your data which is permitted by law and about which we inform you in this declaration.

6) Processing of Data for the Purpose of Order Handling

6.1 Insofar as necessary for the processing of the contract for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 Para. 1 lit. b GDPR.

If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we will process the contact data (name, address, e-mail address) provided by you when placing the order in order to inform you personally by suitable means of communication (e.g. by post or e-mail) about upcoming updates within the legally stipulated period of time within the framework of our statutory duty to inform pursuant to Art. 6 Para. 1 lit. c GDPR. Your contact details will be used strictly for the purpose of informing you about updates owed by us and will only be processed by us for this purpose to the extent that this is necessary for the respective information.

In order to process your order, we also work together with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transferred to these service providers in accordance with the following information.

6.2 Use of Payment Service Providers

- Cash Payment via Cash Payment Solutions GmbH
When selecting the payment method "cash payments", we provide your personal data (first and last name, street, house number, postcode, city, date of birth, e-mail address and possibly telephone number) for the purpose of payment processing in accordance with Art. 6 (1) point b GDPR to the payment service provider Cash Payment Solutions GmbH, Dircksenstr. 40, 10178 Berlin, so that Cash Payment Solutions GmbH can provide you with an individually generated payment or barcode (so-called "payment slip") for the respective transaction. The data will only be passed on if this is necessary for the processing of the payment method "cash payments". With the help of the payment form, it is possible for you to settle the respective transaction costs by cash payment in the business premises of partner companies of Cash Payment Solutions GmbH. The cash payment partner sends the payment confirmation in real time, after which the shipping process can be immediately started, should the goods be available immediately.
Cash Payment Solutions GmbH uses the credit institution NordFinanz Bank Aktiengesellschaft, Martinistraße 48, 28195 Bremen (hereinafter "NordFinanz") to process the payment method "cash payments" and passes your payment data on to that institution in accordance with Art. 6 (1) point b GDPR, to the extent required for the execution of the cash payment.
Both Cash Payment Solutions GmbH and NordFinanz use your personal data exclusively for the purposes of implementing the payment method "cash payments" and for compliance with money laundering regulations.
- Paypal

Online payment methods from the following provider are available on this website: PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg

If you select a payment method of the provider for which you make an advance payment, your payment data provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 (1) point b GDPR. In this case, your data will only be passed on for the purpose of processing payment with the provider and only to the extent necessary for this purpose.

When selecting a payment method of the provider with which the provider makes advance payments, you will also be asked to provide certain personal data (first name and surname, street, house number, postcode, city, date of birth, e-mail address, telephone number, if applicable data on alternative means of payment) during the ordering process.

In order to safeguard our legitimate interest in determining the solvency of our customers, this data is passed on to the provider by us for the purpose of a credit check in accordance with Art. 6 (1) point f GDPR. On the basis of the personal data provided by you as well as further data (such as shopping cart, invoice total, order history, payment history), the provider checks whether the payment option selected by you can be granted with regard to payment and/or bad debt risks.

The credit report may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, they have their basis in a scientifically recognised mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data.

You can object to this processing of your data at any time by sending a message to us or to the provider. However, the provider may still be entitled to process your personal data if this is necessary for the contractual processing of payments.
- Paypal Checkout

This website uses PayPal Checkout, an online payment system from PayPal, which consists of PayPal's own payment methods and local payment methods from third-party providers.

When paying via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "Pay Later" via PayPal, we pass on your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal") as part of the payment processing. The transfer takes place in accordance with Art. 6 Para. 1 lit. b GDPR and only insofar as this is necessary for the payment processing.

For the payment methods credit card via PayPal, direct debit via PayPal or - if offered - "Pay later" via PayPal - PayPal reserves the right to conduct a credit check. For this purpose, your payment data may be passed on to credit agencies in accordance with Art. 6 Para. 1 lit. f GDPR on the basis of PayPal's legitimate interest in determining your solvency. PayPal uses the result of the credit check in terms of the statistical probability of non-payment for the purpose of deciding on the provision of the respective payment method. The creditworthiness information may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, they have their basis in a scientifically recognised mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data. 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 the contractual processing of payments.

If you select the PayPal payment method "purchase on account", your payment data will first be transferred to PayPal in preparation for payment, whereupon PayPal will forward them to Ratepay GmbH, Franklinstraße 28-29, 10587 Berlin ("Ratepay") in order to carry out the payment. The legal basis in each case is Art. 6 para. 1 lit. b GDPR. In this case, RatePay carries out an identity and creditworthiness check on its own behalf to determine solvency in accordance with the principle already mentioned above and passes on your payment data to credit agencies on the basis of the legitimate interest in determining solvency in accordance with Art. 6 Para. 1 lit. f GDPR. A list of the credit agencies that Ratepay may use can be found here: https://www.ratepay.com/legal-payment-creditagencies/

When using the payment method of a local third party provider, your payment data will first be forwarded to PayPal for the preparation of the payment in accordance with Art. 6 (1) lit. b GDPR. Depending on your selection of an available local payment method, PayPal will then transfer your payment data to the corresponding provider in order to carry out the payment in accordance with Art. 6 Para. 1 lit. b GDPR:

- Apple Pay (Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Irland)
- Google Pay (Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Irland)
- Sofort (SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany).
- iDeal (Currence Holding BV, Beethovenstraat 300 Amsterdam, Netherlands)
- bancontact (Bancontact Payconiq Company, Rue d'Arlon 82, 1040 Brussels, Belgium)
- blik (Polski Standard Płatności sp. z o.o., ul. Czerniakowska 87A, 00-718 Warsaw, Poland)
- eps (PSA Payment Services Austria GmbH, Handelskai 92, Gate 2
1200 Vienna, Austria)
- MyBank (PRETA S.A.S, 40 Rue de Courcelles, F-75008 Paris, France)
- Przelewy24 (PayPro SA, Kanclerska 15A, 60-326 Poznań, Poland).
For further information on data protection, please refer to PayPal's privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full

7) Site Functionalities

7.1 Google Web Fonts

This site uses so-called web fonts from the following provider to display fonts in a uniform manner: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data is also transferred to: Google LLC, USA

When you call up a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly and establishes a direct connection to the provider's servers. In this process, certain browser information, including your IP address, is transmitted to the provider.

The processing of personal data while establishing the connection with the provider of the fonts is only carried out if you have given us your express consent to do so in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service via the "cookie consent tool" provided on the website. If your browser does not support web fonts, a standard font will be used by your computer.

7.2 Zoom

We use this provider to conduct online meetings, video conferences and/or webinars: Zoom Video Communications Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA

The provider processes different data, whereby the scope of the processed data depends on the data you provide before or during the participation in an online meeting, video conference or webinar. Your data as a communication participant is processed and stored on servers of the provider. This may include, in particular, your registration data (name, e-mail address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)). In addition, participants' image and sound contributions as well as voice input in chats may be processed.

For the processing of personal data that is necessary for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures), Art. 6 (1) point b GDPR serves as the legal basis. If you have given us your consent to process your data, the processing is based on Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future.
In addition, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest pursuant to Art. 6 (1) point f GDPR in the effective conduct of the online meeting, webinar or video conference.

We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.

8) Rights of the Data Subject

8.1 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;
Right to rectification pursuant to Art. 16 GDPR;
Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
Right to restriction of processing pursuant to Art. 18 GDPR;
Right to be informed pursuant to Art. 19 GDPR;
Right to data portability pursuant to Art. 20 GDPR;
Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
Right to lodge a complaint pursuant to Art. 77 GDPR.

8.2 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.

9) 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 basis on 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 based on 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.

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