The protection of your data is important to us
This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our social media profiles (hereinafter referred to collectively as “online offer”). With regard to the terms used, e.g. “processing” or “responsible person”, we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (DSGVO).
Responsible: Eurohell Design, Daniela Brodmann & Holger Lüttel GbR
Street no.: Hahnenstraße 18
PLZ, City, Country: 30167 Hannover, Germany
Partner: Daniela Brodmann, Holger Lüttel
Telephone number: +49 (0)176 – 433 66 566
Types of data processed:
– inventory data (e.g., names, addresses).
– contact data (e.g., e-mail, telephone numbers).
– content data (e.g., text entries, photographs, videos).
– contract data (e.g.,, subject matter of contract, duration, customer category).
– Payment data (e.g., bank details, payment history).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Processing of special categories of data (Art. 9 para. 1 DSGVO):
No special categories of data are processed.
Categories of data subjects concerned by the processing:
Customers, interested parties, visitors and users of the online offer.
Hereinafter we refer to the data subjects collectively also as “users”.
Purpose of processing:
– Provision of the online offer, its contents and store functions.
– Provision of contractual services, service and customer care.
– Answering contact inquiries and communication with users.
– Marketing, advertising and market research.
– Security measures.
Stand: May 2020
1. Terms used
1.1. “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a website address, a telephone number, a fax number, a fax number, an e-mail address, etc.) (e.g. cookie) or to one or more special characteristics which reveal the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.2. “Processing” means any operation or set of operations, whether or not performed upon personal data, by automatic means. The term is broad and covers practically all data processing operations.
1.3. “Controller” shall mean the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
2. Relevant legal basis
2.1. In accordance with Art. 13 DSGVO we inform you about the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Par. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering inquiries is Art. 6 Par. 1 lit. b DSGVO, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Par. 1 lit. c DSGVO, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Par. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO serves as the legal basis.
4. Safety measures
4.1. We shall meet in accordance with the provisions of Art. 32 DSGVO, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, we shall take appropriate technical and organizational measures to ensure a level of protection commensurate with the risk; these measures shall include in particular the safeguarding of the confidentiality, integrity and availability of data by controlling the physical access to the data as well as the access, input, transmission, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted, and we respond to any threats to the data. Furthermore, we take the protection of personal data into account already during the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly presettings (Art. 25 DSGVO).
4.2. The security measures include in particular the encrypted transmission of data between your browser and our server.
5. Disclosure and transmission of data
5.1. If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer them to them or otherwise grant them access to the data, this will only be done on the basis of a legal authorization (e.g. if a transfer of the data to third parties, such as payment service providers, pursuant to Art. 6 para. 1 lit. b DSGVO is required for the fulfilment of the contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfil our contractual obligations, administrative tasks and duties).
5.2. If we commission third parties to process data on the basis of a so-called “contract processing agreement”, this is done on the basis of Art. 28 DSGVO.
6. Transfers to third countries
6.1. If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer the data in a third country if the special requirements of Art. 44 ff. DSGVO. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
7. Rights of the persons concerned
7.1. You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information on this data and other information and a copy of the data in accordance with art. 15 of the DPA.
7.2. You have accordingly. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
7.3. You have the right to demand that the data in question be deleted immediately in accordance with Art. 17 DSGVO, or alternatively, in accordance with Art. 18 DSGVO, to demand that the processing of the data be restricted.
7.4. You have the right to request that the data concerning you which you have provided us with be communicated to us in accordance with art. 20 of the DPA and to request that it be communicated to other responsible parties.
7.5. You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.
8. Right of withdrawal
8.1. You have the right to revoke any consent you have given in accordance with Art. 7 Para. 3 DSGVO with effect for the future.
9. Right of objection
9.1. You may object to the future processing of data concerning you at any time in accordance with Art. 21 DSGVO. The objection can be made in particular against processing for the purposes of direct advertising.
10. Cookies and right of objection for direct advertising
10.1. “Cookies” are small files that are stored on the user’s computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online store or a login status can be stored. Cookies are described as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be saved if the user visits it after several days. Likewise, the interests of the users can be stored in such a cookie, which is used for range measurement or marketing purposes. Cookies from providers other than the person responsible for operating the online service are referred to as “third party cookies” (otherwise, if it is only their cookies, it is referred to as “first-party cookies”).
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this online offer.
11. Deletion of data
11.1. The data processed by us will be deleted or limited in their processing in accordance with articles 17 and 18 of the DSGVO. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
11.2. In accordance with legal requirements, the storage takes place in particular for 6 years in accordance with § 257 para. 1 HGB (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc
12. Order processing in the online store and customer account
12.1. We process the data of our customers in the context of the order procedures in our on-line store, in order to make possible for them the selection and the order of the selected products and achievements, as well as their payment and supply, and/or execution.
12.2. The processed data includes inventory data, communication data, contract data, payment data and about the persons concerned our customers, interested parties and other business partners. The processing is carried out for the purpose of providing contractual services in the context of operating an online store, billing, delivery and customer services. We use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.
12.3. The processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. In this context, the information marked as required is required for the establishment and performance of the contract. We disclose the data to third parties only within the scope of delivery, payment or within the scope of the legal permissions and obligations to legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfillment of the contract (e.g. on customer request for delivery or payment).
12.4. Users can optionally create a user account, where they can especially view their orders. During the registration process, the required mandatory data will be provided to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is necessary for reasons of commercial or tax law in accordance with Art. 6 para. 1 lit. c DSGVO. Data in the customer account shall remain in the customer account until its deletion with subsequent archiving in the event of a legal obligation. It is the responsibility of the users to back up their data in case of termination before the end of the contract.
12.5. Within the scope of registration and renewed logins and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s need for protection against misuse and other unauthorized use. This data will not be passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c DSGVO.
12.6. The deletion is carried out after the expiry of legal warranty and comparable obligations, the necessity of data storage is reviewed every three years; in case of legal archiving obligations, the deletion is carried out after their expiry (end of commercial (6 years) and tax (10 years) storage obligation); data in the customer account remain until its deletion.
13. Business management analyses and market research
13.1. In order to run our business economically, to recognize market trends, customer and user wishes, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the persons concerned include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purpose of business management evaluations, marketing and market research. In doing so, we can take into account the profiles of the registered users with information, e.g. on their purchase transactions. The analyses serve us to increase user-friendliness, to optimize our offer and business efficiency. The analyses serve only us and will not be disclosed externally, unless they are anonymous analyses with summarized values.
13.2. If these analyses or profiles are personal, they will be deleted or made anonymous upon termination by the user, otherwise after two years from conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.
14. Contacting and customer service
14.1. When contacting us (via contact form or e-mail), the user’s data will be processed for the purpose of handling the contact request and its processing in accordance with art. 6 para. 1 lit. b) DSGVO.
14.2. The information provided by users may be stored in our Customer Relationship Management System (“CRM System”) or a comparable request organization.
14.3. We delete the requests if they are no longer necessary. We review the necessity every two years; we permanently store requests from customers who have a customer account and refer to the customer account details for deletion. Furthermore, the legal archiving obligations apply.
15. Collection of access data and log files
15.1. We raise on the basis of our legitimate interests in the sense of art. 6 par. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited site), IP address and the requesting provider.
15.2. Logfile information will be stored for a maximum of seven days for security reasons (e.g. to investigate abuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
16. Online presence in social media
16.1. We maintain on the basis of our legitimate interests as defined in Art. 6 para. 1 lit. f. DSGVO online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
16.3. We use Google Analytics in order to display the advertisements placed within the advertising services of Google and its partners only to those users who have also shown an interest in our online offer or who exhibit certain characteristics (e.g. interests in certain topics or products determined by the websites visited) which we transmit to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences, we also want to ensure that our ads match the potential interest of the users and are not annoying.
17. Google Analytics
17.2. Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
17.3. Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. The processed data can be used to create pseudonymous user profiles of the users.
17.4. We use Google Analytics only with activated IP anonymization. This means that the IP address of users is shortened by Google within member states of the European Union or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.
17.5. The IP address transmitted by the user’s browser will not be merged with other data from Google. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and relating to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
17.6. Further information on the use of data by google, setting and contradiction possibilities you will find on the websites of google: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google in your use of websites or apps of our partners”), https://policies.google.com/technologies/ads (“Data use for advertising purposes”), https://adssettings.google.com/authenticated (“Manage information Google uses to serve ads to you”).
18.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer in the sense of Art. 6 para. 1 lit. f. DSGVO) the marketing and remarketing services (briefly “Google Marketing Services”) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
18.2. Google is certified under the Privacy-Shield Agreement and thus offers a guarantee to comply with the European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
18.3. Google’s marketing services allow us to better target advertisements for and on our website to show users only those ads that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is called “remarketing”. For these purposes, when users access our and other websites on which Google marketing services are active, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are embedded in the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (instead of cookies, comparable technologies can also be used). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, what content he is interested in and which offers he has clicked on, as well as technical information about the browser and operating system, referring websites, visiting time and other information about the use of the online offer. The IP address of the user is also recorded, whereby we inform within the framework of Google Analytics that the IP address is shortened within member states of the European Union or in other signatory states to the Agreement on the European Economic Area and only in exceptional cases is it transferred in full to a Google server in the USA and shortened there. The IP address is not merged with user data within other Google offers. Google may also combine the above-mentioned information with information from other sources. If the user subsequently visits other websites, the ads tailored to his interests can be displayed to him.
18.4. User data is processed pseudonymously within the framework of Google marketing services. This means that Google does not store and process the name or e-mail address of the user, for example, but processes the relevant data on a cookie-related basis within pseudonymous user profiles. I.e. from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information collected by Google’s marketing services about users is transmitted to Google and stored on Google’s servers in the USA.
18.5. The Google marketing services we use include the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked through the websites of AdWords customers. The information collected through the cookie is used to compile conversion statistics for AdWords customers who have opted in to conversion tracking. AdWords advertisers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive any information that personally identifies users.
18.8. We can also use the “Google Optimizer” service. Google Optimizer allows us in the context of so-called “A/B-Testings” to understand how various changes to a website affect it (e.g. changes in input fields, design, etc.). For these test purposes, cookies are stored on the users’ devices. Only pseudonymous data of the users are processed.
18.9. We may also use the “Google Tag Manager” to integrate and manage the Google analysis and marketing services into our website.
18.10. Further information on the use of data for marketing purposes by Google can be found on the overview page: https://policies.google.com/technologies/ads, the data protection declaration of Google is available under https://policies.google.com/privacy.
18.11. If you wish to object to interest-based advertising through Google marketing services, you can use the setting and opt-out options provided by Google: https://adssettings.google.com/authenticated.
19. Facebook Social Plugins
19.1. We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer in the sense of Art. 6 para. 1 lit. f. DSGVO) Social Plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The Plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white “f” on blue tile, the words “Like”, “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
19.2. Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
19.3. When a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer by the user. User profiles can be created from the processed data. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore inform the users according to our state of knowledge.
19.4. By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his or her Facebook account. If users interact with the plugins, for example, by pressing the Like button or making a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out his or her IP address and store it. According to Facebook, only an anonymized IP address is stored in Germany.
19.5. The purpose and scope of data collection and the further processing and use of data by Facebook, as well as the rights and settings options for protecting the privacy of users, can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy/.
19.6. If a user is a Facebook member and does not want Facebook to collect data about him/her via this online offer and link it with his/her membership data stored on Facebook, he/she must log out of Facebook and delete his/her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US-American page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
20. Communication by mail, e-mail, fax or telephone
20.1. We use remote means of communication such as mail, telephone or e-mail for business transactions and marketing purposes. We process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
20.2 The processing is based on Art. 6 para. 1 lit. a, Art. 7 DSGVO, Art. 6 para. 1 lit. f DSGVO in connection with legal requirements for advertising communications. Contact will only be established with the consent of the contact partners or within the scope of the legal permissions and the processed data will be deleted as soon as they are not required and otherwise with objection/ revocation or omission of the basis for authorization or legal archiving obligations.
21. Integration of third party services and content
21.1. We set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), we use content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of such content are aware of the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information on the browser and operating system, referring web pages, visiting time and other details on the use of our online offer, as well as being able to be linked to such information from other sources.
21.2. The following presentation offers an overview of third party providers and their contents, including links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, the possibility to object (so-called opt-out).
– If our customers use the payment services of third parties (e.g. PayPal or Sofortüberweisung), the terms and conditions and the data protection information of the respective third party providers apply, which can be accessed within the respective websites or transaction applications.