At MARC O’POLO, your satisfaction is our top priority, and an important part of our role is to protect your privacy. We therefore collect and process your personal data exclusively in accordance with the principles set out below and in compliance with the applicable data protection laws, in particular the General Data Protection Regulation (GDPR).
The data controller pursuant to Article 4(7) of the GDPR for the website https://www.qolzirvaxune.site and the online shop contained therein (hereinafter collectively referred to as the “website”) and the Marc O’Polo app (hereinafter the “app”) is MARC O’POLO Einzelhandels GmbH, Hofgartenstraße 1, 83071 Stephanskirchen, Germany, service@qolzirvaxune.site (hereinafter “MARC O’POLO” or “we”).
You can contact our Data Protection Officer at (datenschutz@qolzirvaxune.site) or via our postal address, adding ‘Data Protection Officer’ to the address.
If you are under 16 years of age, please obtain permission from a parent or guardian before providing MARC O’POLO with any personal data.
In connection with the presentation and sale of our goods, we process personal data relating to various individuals. This includes, in particular:
Visitors to our website http://www.qolzirvaxune.site and visitors to our app
Customers of our online shop (website and app)
Subscribers to our newsletter via email and/or WhatsApp
Participants in the MARC O’POLO COMMUNITY loyalty programme
Users of our customer service
Participants in our prize draws
In Section A of this privacy notice, you will find information about the controller and the Data Protection Officer of the data controllers.
In Sections B to G you will also find information on the processing of your personal data.
In Section H you will find detailed information on the use of cookies or similar technologies.
In Section I , you will also find information about your rights regarding the processing of your personal data.
The data protection terms used in this privacy notice have the meanings set out in the General Data Protection Regulation. Detailed information on this can be found in Section J.
- Informational use of the website or app (using essential cookies or comparable technologies)
- Use of third-party marketing tools (e.g. from social networks, search engine operators and advertising networks) (using ‘marketing’ cookies and similar technologies (app))
- Use of web analytics technologies (using ‘analytics’ cookies and similar tracking technologies (app))
- Use of personalisation technologies (using personalisation cookies and similar tracking technologies (app))
- Information on the processing of personal data of customers of our online shop (website and app)
- Details of the personal data that is processed
- Details about the processing of personal data
- Details regarding the recipients of personal data and the transfer of personal data to third countries and/or to international organisations
- Information on the processing of personal data of subscribers to our email and WhatsApp newsletters and our push notifications
- Details of the personal data that is processed
- Details regarding the processing of personal data
- Details about the recipients of personal data and the transfer of personal data to third countries and/or international organisations
- Information on the processing of personal data of participants in the customer loyalty scheme
- Information about the personal data we process
- Details about the processing of personal data
- Details about the recipients of personal data and the transfer of personal data to third countries and/or international organisations
- Information about the processing of personal data of users of our customer service
- Information about the personal data we process
- Details about the processing of personal data
- Details about the recipients of personal data and the transfer of personal data to third countries and/or international organisations
- Information about the processing of personal data of participants in our competitions
- Details about the processing of personal data
- Details about the processing of personal data
- Details about the recipients of personal data and the transfer of personal data to third countries and/or international organisations
A - Information about the controller
Name and contact details of the controller
Marc O’Polo Einzelhandels GmbH
Hofgartenstraße 1, 83071 Stephanskirchen
E-Mail: service@marc-o-polo.de
Telephone: 00 800 10221022 (free service hotline)
Contact details of the data protection officer of the controller
Hofgartenstraße 1, 83071 Stephanskirchen
Data protection officer
E-Mail: dataschutz@qolzirvaxune.site
B - Information on the processing of personal data of visitors to our website www.qolzirvaxune.site or our app
Informational use of the website or app (using essential cookies or comparable technologies)
When you use the website or app for information purposes, certain information – such as your IP address – is sent to our website’s server by the browser on your device for technical reasons. We process this information to provide you with the website content you have accessed. To ensure the security of the IT infrastructure used to provide the website, this information is also temporarily stored in a so-called web server log file.
To provide the search functions on our website or app, data that you enter into our search functions is temporarily processed on our web server.
To provide the consent management functions for our website or app (e.g. for the use of certain cookie-based technologies), information regarding your consent to cookies (🡪section H) is stored on your device. The cookies and the information stored in them can be read whilst you are visiting our website to determine whether and which consents you have given. Data is also processed temporarily on our web server to provide the language selection function, so that we can display the content of the website or app you have accessed in your chosen language.
More detailed information about this is available below:
| Categories of personal data we process | Personal data in the categories | Sources of data | Obligation to make the data available | Duration of storage |
|---|---|---|---|---|
| HTTP data. | Log data generated automatically for technical reasons when accessing the website and using our native app via the Hypertext Transfer Protocol (Secure) (HTTP(S)). On the website: This includes your IP address, the type and version of your web browser, the operating system used, the page accessed, the previously visited page (referrer URL), and the date and time of access. In the app: These include the IP address, the type and version of the HTTP component used in the app, the operating system used or the operating system of the end device, the page accessed or the web address of a technical service (API endpoint) accessed by the app through which data is received or provided, the previously visited page (referrer URL), and the date and time of the request. | Users of the website or app | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide this data. If the data is not provided, we will be unable to display the requested content on the website. | Data is stored in server log files in a form that allows the identification of the data subjects for a maximum period of 6 weeks, unless a security-related incident occurs (e.g. a DDoS attack). In the event of a security-related incident, server log files are stored until the security-related incident has been resolved and fully investigated. |
| Search function data. | Data that you enter into the search functions on our website or app. This includes all the information you enter as search terms in the relevant search form on the website. | User of the website or app | The provision of data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to make the requested website content available. | Data is stored in server log files in a form that allows the identification of the data subjects for a maximum period of 6 weeks, unless a security-related incident occurs (e.g. a DDoS attack). In the event of a security-related incident, server log files are stored until the security-related incident has been resolved and fully investigated. |
| Opt-in data | Data relating to the consents you have given for our website or app. This includes your consent and, where applicable, your individual preferences regarding the use of cookie-based technologies. This data is stored in cookies or similar technologies on your device (🡪Section H). | Users of the website or app | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide this data. If you do not provide the data, we cannot take your cookie consents into account on this website. | We do not store this data permanently on our systems, but only temporarily whilst the website is being accessed. Permanent storage takes place locally in the browser or in the app. (🡪 See Section H.III. for information on the validity period of the cookies or similar technologies used.) |
| Language selection data | Data stored for the purpose of providing the language selection function. This includes the language you have selected. This data is stored in cookies on your device (🡪Section H). | User of the website or app | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide this data. If you do not provide the data, we will be unable to display the website content you have accessed in your chosen language. | We do not store this data permanently on our systems, but only temporarily at the time the website or app is accessed. Permanent storage takes place locally in the user’s browser for a maximum period of 4 weeks. In the case of the app, the data is stored locally and permanently within the app. |
| Purpose of the processing of personal data | Categories of personal data we process | Automated decision-making | Legal grounds and legitimate interests | Recipient |
|---|---|---|---|---|
| Provision of the website or app content accessed by the user: To this end, data is processed temporarily on our web server. | HTTP data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to provide the website content accessed by the user. | Hosting provider. |
| Provision of the search functions on our website or app: To this end, data that you enter into our search functions is processed temporarily on our web server. | HTTP data Search function data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to provide the website’s search functions accessed by the user. | Hosting provider. |
| Provision of the consent management function for the website. Your consent is required for certain functions of our website and app (e.g. for the use of certain cookie-based or similar technologies). To grant and, where applicable, withdraw your consents, we provide a consent management function for our website. To this end, information regarding your consents relating to cookies or similar technologies ( 🡪Section H) is stored on your device. The information stored therein can be read whilst you are visiting our website or app to determine whether and which consents you have given. | HTTP data Opt-in data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is the management of the consents given by the user for this website. | Consent provider. |
| Provision of the language selection function on the website or app: To this end, data is processed temporarily on our web server in order to provide you with the website content you have accessed in your chosen language. | HTTP data Language selection data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to provide the website content accessed by the user in the language selected in each case. | Hosting provider. |
| Ensuring the security and stability of the IT infrastructure used to provide the website or app, in particular to identify, rectify and document in a manner that preserves evidence any disruptions (e.g. DDoS attacks), as well as to identify crashes (app) and rectify the associated faults. To this end, data is temporarily stored in log files on our web server and analysed. | HTTP data, search function data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to ensure the security of the data required to providethe website and the app , in particular to detect, rectify and document malfunctions (e.g. DDoS attacks) in a manner that preserves evidence . | Website and app: hosting provider App only: Google Firebase Crashlytics |
| Implementation of the ‘Refer a Friend’ feature. With the ‘Refer a Friend’ feature, we aim to attract new customers through our existing customers. As a thank you, the referring member receives bonus points from us, credited to their account, as soon as the newly referred member has made a purchase. | Customer Master Data Login Log Data Identification Data for New Customer Acquisition | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is the operation of the ‘Refer a Friend’ feature. | CRM system, loyalty tool |
| Recipient | Role of the recipient | Transfer to third countries and/or to international organisations | Adequacy decision or appropriate or adequate guarantees for transfers to third countries and/or international organisations |
|---|---|---|---|
| Hosting provider (currently: commercetools GmbH, Adams-Lehmann-Str. 44, 80797 Munich, Germany) | Data processor. | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA and the UK. The adequacy decision for the USA is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj The adequacy decision for the United Kingdom (UK) is available here: http://data.europa.eu/eli/dec_impl/2021/1772/oj There is no adequacy decision by the European Commission within the meaning of Article 45(3) of the General Data Protection Regulation for transfers to Australia and Singapore. Commerctools GmbH has Standard Contractual Clauses (SCCs) in place which have been approved in accordance with Article 46 of the General Data Protection Regulation. |
| Google Firebase Crashlytics | Data processors | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Google is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| Consent provider (currently: Usercentrics GmbH, Sendlinger Str. 7, 80331 Munich, Germany) | Data processor. | EU. | - |
Use of third-party marketing tools (e.g. from social networks, search engine operators and advertising networks) (using ‘marketing’ cookies and similar technologies (app))
Prov ided you have given your consent to this in our privacy and cookie settings, we use certain third-party marketing tools (e.g. from social networks, search engine operators and advertising networks) on our website and in our app (i.e. if you have given your consent to the ‘Marketing’ category or to individual marketing tools listed under this category in our Privacy and Cookie Settings). The respective providers are listed in → Section B.II.3, and you can select specific providers in our Privacy and Cookie Settings.
These marketing tools are used for the following purposes:
Conversion tracking, including app attribution and deep linking
“Conversions” are usage activities on our website or app that we have defined. “Conversion tracking” is a process that records what happens after our adverts have been displayed to you on the website of the provider of the relevant marketing tool (e.g. their search engine or social network) or on other websites that cooperate with that provider, or after you have interacted with these adverts. For example, we can see whether you subsequently carried out a specific action on our website or in our app (e.g. placing an order or signing up for our newsletter).
As part of app-based conversion tracking , the events recorded in our app (such as purchases, adding items to the shopping basket (‘add-to-cart’) and similar interactions on the website or in the app) are processed via a so-called mobile measurement partner and sent back to the relevant marketing partners (such as Meta, Google Ads, etc.) (‘postbacks’). This enables the marketing partners to measure the success of the advertising campaigns displayed there and to optimise them technically.
App-based conversion tracking also includes app attribution. By ‘app attribution’, we mean a process that enables us to analyse and measure the specific marketing channels or advertising campaigns (e.g. an advert on a social media platform, in search engines or on partner websites) through which users became aware of our app and subsequently downloaded and installed it on their device. When you click on one of our adverts, this click is recorded. If you install and open the app within a specific time window, the attribution tool links this click – in pseudonymised form – to the app installation.
In this way, we can see which keywords, adverts, ad groups and campaigns lead to the user actions we are seeking. We can also track how our return on investment (ROI) is generated and make informed decisions regarding our advertising spend. Furthermore, we can automatically optimise our advertising campaigns in line with our business objectives. This enables us to identify which marketing measures, adverts and campaigns are particularly successful, how to use our advertising budgets efficiently, and what the return on investment (ROI) of our mobile advertising activities is.
In addition, ‘deep linking’ technology can be used to redirect you directly to the advertised product, content or offer within our app after you click on an advertising link. If the app is not yet installed, the redirection takes place after the app has been downloaded and opened for the first time. To do this, technical identifiers such as a click ID, your IP address, device information and session data are processed for a short period.
Remarketing (including profile enrichment by the provider of the relevant marketing tool we use, personalisation of advertising and profile enrichment by us, as well as the determination of billing-related circumstances of ad placement by the provider of the relevant marketing tool we use)
‘Remarketing’ (or ‘retargeting’) means that we can specifically target users who have already interacted with our website or our app, for example with adverts on the website of the provider of the relevant marketing tool (e.g. their search engine or social network) or on other websites that cooperate with the relevant provider.
For these purposes, a unique ID may be assigned to your device, which is linked to a profile. This ID may be stored in cookies (--> Section H.III.2) on your device, as well as in the profile maintained by the provider of the relevant marketing tool. When you visit our website or app, as well as when you visit the website of the provider of the relevant marketing tool (e.g. their search engine or social network) or other websites that cooperate with that provider, the ID stored in cookies on your device may be read, thereby enabling your device to be recognised on the basis of this ID. In this case, the profile may be enriched (e.g. with information about your orders with us, items viewed on our website or in the app, or your interactions with our adverts on other websites). Conversion tracking and remarketing are carried out on the basis of this information. The provider of the respective marketing tool we use makes analyses or further information, generated on the basis of the data collected, available to us solely in aggregated, anonymised form. As a rule, we cannot link the information provided to us to any specific individual.
However, instead of using the ID, a link to your profile may also be established by matching hashed contact information or, where applicable, by linking it to your account with the relevant provider (e.g. your Google Account, if you have enabled personalised advertising there). In this way, actions you carry out using different devices may also be attributed to you as a unique user.
Provided that, in addition to giving your consent to one or more of the ‘marketing’ tools, you have also given your consent to ‘personalisation’ in general or at least to personalisation via ‘Bloomreach’ (you can check this via our privacy and cookie settings), we use the data on transactions, preferences and interests from your profile as criteria for creating segmented customer target groups. The contact details of these target groups are transmitted in hashed form to the relevant providers (e.g. social media platforms, search engine operators and advertising networks) and used to serve adverts, so that these can be tailored even more effectively to your preferences and interests. This may also include ‘guest orders’ that we have been able to link to your customer account, or orders placed in one of our high-street shops that have been linked to your customer account.
We are jointly responsible, in some cases, with the respective provider of the marketing tools for the use of these tools on our website and in our app. Any further processing of the data by the respective provider for its own purposes or for the purposes of third parties (for example, to create target groups for other advertising clients) is the sole responsibility of the respective provider (which is not covered by this privacy policy). Information on whether we are jointly responsible with the relevant provider, and a reference to the relevant providers’ privacy policies, can be found below.
Detailed information on this is provided below:
| Categories of personal data we process | Personal data in the categories | Sources of data | Obligation to make the data available | Duration of storage |
|---|---|---|---|---|
| HTTP and app connection data (separately for each provider of the relevant marketing tool) | Log data generated for technical reasons via the Hypertext Transfer Protocol (Secure) (HTTP(S)) when using the respective marketing tool on our website or app: These include: · IP address · Type and version of your web browser · Operating system used · the page accessed or the app screen opened · the page you visited previously (referrer URL) · Date and time of access | Users of our website or app | The provision of data is not required by law or contract, nor is it necessary for the conclusion of a contract. The data subject is under no obligation to provide the data. If the data is not provided, we cannot carry out remarketing or conversion tracking. | We do not store this data. The storage of this data falls within the remit of the provider of the relevant marketing tool for as long as it is necessary for the purpose. |
| Device data (separately for each provider of the relevant marketing tool) | Data that can be associated with your device when you access our website or app, or visit the website of the provider of the relevant marketing tool (e.g. their search engine or social network) (subject, where applicable, to your consent given to the relevant provider) or visit a website that cooperates with this provider and displays our adverts (i.e. another website, such as an online newspaper, which displays our adverts via the relevant provider) (subject, where applicable, to your consent given to the relevant website operator): In the app: Temporary click IDs and session data Unique identifiers for (re)identifying your device (advertising IDs such as IDFA for iOS devices, GAID for Android devices, and the device-specific AppsFlyer ID). Parameters passed to tracking pixels or app interfaces (SDKs) (e.g. partner ID, page type, product numbers, order number, order value, language settings, approximate location data derived from the IP address, screen size). Partner identification number, e.g. of the advertising partner Google Page type (e.g. thank-you page following an order, product detail page, shopping basket, category overview, search results) Product numbers of the products viewed Product numbers of the products ordered Product numbers of the products searched for Order number Order value URL of the page(s) visited Names/prices of the products viewed Number of products in the shopping basket Currency Website language setting Approximate location information User agent data (browser type, device, screen size, email programmes, server) As part of the ID creation process, the IP address is collected and translated into a rough geographical location. The last octet of this IP address is removed. This data may (depending on your consent to the relevant provider/operator, where applicable) be stored in cookies (→ Section H.III.2) on your device. When you visit our website or other websites participating in the same advertising networks, the information stored in these cookies may be read. | Users of our website or app | The provision of data is not required by law or contract, nor is it necessary for the conclusion of a contract. The data subject is under no obligation to provide the data. If the data is not provided, we will be unable to carry out remarketing or conversion tracking. | Neither we nor the relevant provider store the cookies themselves. However, the data contained in the cookies is incorporated into the relevant profile data (see the data category ‘Profile Data’ below). (For information on the validity period of the cookies stored on your device, please see → Section H.III.2) |
| Installation and interaction data | Data collected specifically during the installation and active use of our app. This includes: • The time the app was downloaded, installed and first opened. • App version and updates carried out. • Interactions with in-app content (e.g. buttons clicked, banners viewed, features used). • Transactions within the app (in-app purchases, time of purchase, products purchased, order value). • Information about advertising links and deep links used (which campaign led you to us). | Users of our app (collected via the integrated AppsFlyer Software Development Kit [SDK]) | The provision of this data is not required by law or contract. There is no obligation to provide it. However, without this data, we cannot measure the success of app campaigns or offer deep linking. | We do not store this data permanently on our own systems. For the purpose of measuring the success of app campaigns and providing deep linking, we transfer it in pseudonymised form to AppsFlyer. AppsFlyer processes the data as part of a pseudonymised profile for as long as is necessary for these purposes. You may withdraw your consent at any time with future effect. In this case, processing for these purposes will cease. |
| Profile data (separately for each provider of the relevant marketing tool) | Data that may be collected by the relevant marketing tool and stored in a profile when our adverts are displayed to you on the website of the provider of the relevant marketing tool (e.g. their search engine or social network) or on other websites participating in the same advertising network, or when you interact with such adverts (where applicable, subject to your consent given to the relevant provider/operator): This includes the unique ID assigned to your device (cookie ID, advertising ID or AppsFlyer ID), as well as information about our adverts displayed to you on the relevant websites that are part of the same advertising network, or with which you have interacted there. This also includes information about your use of the relevant website and app. This may also include hashed contact details (e.g. an email address, name and address, or a telephone number) known to the provider of the relevant marketing tool, as well as technical information about your device that can be extracted from it (e.g. screen size). | Collected by the marketing tool on search engines or other websites | - | We do not store this data. The storage of this data falls within the remit of the provider of the relevant marketing tool for as long as it is necessary for the purpose. |
| Data generated by the relevant marketing tool used on our website or app and added to your profile when you visit our website, or which we add to your profile. This includes the unique ID assigned to your device. It also includes, for example, the following information about your use of our website: Page views Frequency of visits Time spent on pages visited The ‘conversions’ you have triggered (e.g. visiting a product page, adding an item to the ‘shopping basket’, placing an order – including the order value –, registering a customer account or subscribing to our newsletter) The user’s origin (i.e. via which advertising partner or advertising campaign a visitor arrived at our website). This may also include hashed contact details (e.g. an email address, name and address, or a telephone number) that we add to the profile, provided you have a customer account with us and are logged in to it whilst visiting our website. This may also include technical information about your device that can be read from it (e.g. the screen size). This also includes the results of the analysis of this information, in particular the assignment of your profile to specific advertising segments or ‘target groups’ for the display of adverts, the bounce rate and turnover. | Collected via the marketing tool on our website | - | We do not store this data. The storage of this data falls within the remit of the provider of the respective marketing tool. |
| Purpose of the processing of personal data | Categories of personal data we process | Automated decision-making | Legal grounds and legitimate interests | Recipient |
|---|---|---|---|---|
| Conversion tracking: ‘Conversions’ are user activities on our website or within our app. ‘Conversion tracking’is a process that records what happens after our adverts have been displayed to you on the website of the provider of the relevant marketing tool (e.g. their search engine or social network) or on other websites that cooperate with that provider, or after you have interacted with these adverts. For example, we can see whether you subsequently carried out a specific action on our website or in our app (e.g. placing an order or signing up for our newsletter). When our adverts are displayed to you on such websites or you interact with our adverts, information about this may be collected and stored in a profile (subject, where applicable, to your consent given to the provider of the relevant marketing tool and the relevant operator of other websites). In order to be able to associate this information with your device, a unique ID may be assigned to your device, which is linked to the profile. This ID may be stored in cookies ( → Section H.III.2) or similar storage formats on your device. When you subsequently visit our website or app , the information stored in these cookies can be read. In this way, your device can be recognised by means of the ID, and this ID can be used to retrieve the information stored in the profile regarding your interactions with our adverts and to store further data. This enables us to collect information about the use of our website or app, in particular the ‘conversions’ triggered by you. Such association can be made not only via the ID but also by matching hashed contact information or, where applicable, via a link to your account with the relevant provider (e.g. your Google Account, if you have enabled personalised advertising there). In this way, actions you carry out using different devices can also be attributed to you as a unique user. This enables us to see which keywords, adverts, ad groups and campaigns lead to the user actions we are seeking. We can also track how our return on investment (ROI) is generated and make informed decisions regarding our advertising expenditure. Furthermore, we can automatically optimise our advertising campaigns in line with our business objectives. The provider of the respective marketing tool we use makes analyses or further information, generated on the basis of the data collected, available to us solely in aggregated, anonymised form. As a rule, we cannot associate the information provided to us with any specific individual. | HTTP data Device data Profile data (separately for each provider of the relevant marketing tool) | No automated decision-making takes place. | Article 6(1)(a) of the GDPR (Consent) | (relevant) marketing tool service provider |
| Remarketing: ‘Remarketing’ (or ‘retargeting’) means that we can specifically target users who have already interacted with our website or app, for example with adverts on the website of the provider of the relevant marketing tool (e.g. their search engine or social network) or on other websites that cooperate with the relevant provider. When you visit our website or use our app , information about your use of our website or app is collected and stored in a profile. In order to be able to link this information to your device, a unique ID is assigned to your device and linked to the profile. This ID is stored in cookies ( → Section H.III.2) on your device. If you subsequently visit the website of the provider of the relevant marketing tool (e.g. its search engine or social network) or other websites that cooperate with that provider using the same device, (subject, where applicable, to your consent given to the provider of the relevant marketing tool and the respective operator of other websites) your device may be recognised there on the basis of the ID assigned to it, and the information stored regarding your use of our website or app – including the assignment of your profile to specific advertising segments – may be retrieved using this ID. Such an association may be made not only via the ID but also by matching hashed contact information or, where applicable, via a link to your account with the relevant provider (e.g. your Google Account, if you have enabled personalised advertising there). In this way, actions you carry out using different devices may also be attributed to you as a unique user. In this way, the provider of the relevant marketing tool we use can display our adverts to you in a targeted manner or, where appropriate, suppress certain adverts (e.g. for products you have already purchased). In addition, the marketing tools use the data collected for predictive targeting. In this process, the relevant provider calculates statistical twins of our users based on their usage profiles. Our partners apply these insights to other people who have similar preferences to our users, in order to draw these people’s attention to our website and to products that may be of interest to them. | HTTP data Device data Profile data (separately for each provider of the respective marketing tool) | No automated decision-making takes place. | Article 6(1)(a) of the GDPR (Consent) | (Respective) marketing tool service provider |
| Enrichment of profiles by the provider of the relevant marketing tool we use: If you visit the website of the provider of the relevant marketing tool (e.g. its search engine or social network) or other websites that cooperate with that provider, the provider of the relevant marketing tool we use may add information about your use of such websites and information regarding the adverts displayed to you there or with which you have interacted to your profile, in order to enable better personalisation Furthermore, profile enrichment enables the provider of the relevant marketing tool we use to optimise the delivery of various adverts for us and other companies for which it serves adverts (e.g. controlling the frequency with which certain adverts are displayed). | Device data Profile data (separately for each provider of the relevant marketing tool) | No automated decision-making takes place | Article 6(1)(a) of the GDPR (Consent) | (Respective) marketing tool service provider |
| Personalisation of advertising and enrichment of profiles by us: We and the provider of the relevant marketing tool we use personalise our adverts for you specifically on the basis of your profile, in particular based on your use of our website or app. To this end, we analyse the information stored in your profile and, on this basis, assign your profile to specific advertising segments. Provided that, in addition to giving your consent to one or more of the ‘marketing’ tools, you have also given your consent to ‘personalisation’ as a whole or at least to personalisation via ‘Bloomreach’ (you can check this via our privacy and cookie settings ), we use the data on transactions, preferences and interests from your profile as criteria for creating segmented customer target groups. The contact details of these target groups are transmitted in hashed form to the relevant providers (e.g. social media platforms, search engine operators and advertising networks) and used to serve adverts, so that these can be tailored even more effectively to your preferences and interests. This may also include ‘guest orders’ that we have been able to link to your customer account, or orders placed in one of our high-street shops that have been linked to your customer account. | Bloomreach profile data ( → Section B.IV.1) | No automated decision-making takes place. | Art. 6(1)(a) GDPR (Consent) | (relevant) marketing tool service provider Bloomreach ( → Section B.IV.3) |
| Determination of billing-related details regarding the display of adverts by the provider of the relevant marketing tool we use: The information stored in your profile is also used by the provider of the relevant marketing tool we use to analyse the adverts displayed on your device that lead to our website or app via that provider, so that they can bill us for their services. For the purposes of billing us, the provider must determine the number of visits to our website or app via these adverts and other billing-related details (in particular, any purchases made as a result). | Profile data (separately for each provider of the respective marketing tool) | No automated decision-making takes place, and the tool is used to determine the return on investment (ROI) of our mobile advertising activities. | ||
| App-only: App attribution: App attribution measures which marketing channel users use to install the app. Clicks and installations are linked in a pseudonymised manner within a limited time period. This enables us to measure campaign success and optimise our advertising spend. We link ad clicks and app installations in a pseudonymised manner to measure the success of our campaigns. We only receive aggregated and anonymised reports that cannot be linked to any individual. We use device-specific advertising IDs (IDFA for iOS, GAID for Android) for advertising and campaign measurement. With your consent, we process these IDs in a pseudonymised form to measure the effectiveness of advertising. | HTTP data Device data Installation and interaction data | No automated decision-making takes place. | Article 6(1)(a) of the GDPR (Consent) | AppsFlyer Ltd. (relevant) marketing tool service providers (such as Google Ads, Meta, Pinterest, Criteo) |
| In-app only: Deep linking (optimised user guidance): Deeplinking takes you directly to the advertised content in our app after clicking on an advertising link or – if the app is not installed – redirects you there after you have downloaded it. For this purpose, technical identifiers are processed briefly and then deleted. | HTTP data Device data | No automated decision-making takes place. | Article 6(1)(a) of the GDPR (Consent) | AppsFlyer Ltd. |
| Recipient | Role of the recipient | Transfer to third countries and/or to international organisations | Adequacy decision or appropriate or adequate guarantees for transfers to third countries and/or international organisations |
|---|---|---|---|
| Marketing tool service provider (1): Google Ireland Limited Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland The provider’s privacy policy can be found here: https://policies.google.com/privacy?hl=de | (Joint) Data Controller We process data jointly with Google Ireland. Where applicable, Google Ireland may transfer data to third countries, such as the USA, within its area of responsibility. | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Google is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| Marketing tool service provider (2): Microsoft Ireland Operations Limited One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland The provider’s privacy policy can be found here: https://privacy.microsoft.com/de-de/privacystatement | (Joint) Data Controller We process data jointly with Microsoft Ireland. Where applicable, Microsoft Ireland may transfer data to third countries, such as the USA, within its area of responsibility. | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Microsoft is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| Marketing tool service provider (3): Criteo SA 32 Rue Blanche, 75009 Paris, France The provider’s privacy policy can be found here: https://www.criteo.com/de/privacy/ | (Joint) Data Controller | EU | - |
| Marketing tool service provider (4): retailAds GmbH & Co. KG Kaiserstraße 23, 90403 Nuremberg, Germany The provider’s privacy policy can be found here: LINK: https://www.retailads.net/de-de/ueberuns/datenschutz/ | (Joint) Data Controller We process data jointly with retailAds. | EU | - |
| Marketing tool service provider (5): Tectumedia GmbH Eichhornstrasse 3 10785 Berlin, Germany The provider’s privacy policy can be found here: https://www.tectumedia.com/privacy-policy/ | (Joint) Data Controller | EU | - |
| Marketing tool service provider (6): Outbrain UK Limited 5th Floor, The Place, 175 High Holborn, London, WC1V 7AA, UK The provider’s privacy policy can be found here: https://www.outbrain.com/legal/privacy#privacy-policy | (Joint) Data Controller We process data jointly with Outbrain UK. Where applicable, Outbrain UK may transfer data to other third countries, such as the USA, within its area of responsibility. | UK and USA | Adequacy decisions by the European Commission within the meaning of Article 45 of the GDPR are in place for the transfer of personal data to the United Kingdom (UK) and the USA. The adequacy decision for the USA is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Outbrain is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list The adequacy decision for the United Kingdom (UK) is available here: http://data.europa.eu/eli/dec_impl/2021/1772/oj |
| Marketing tool service provider (7): RTB House GmbH Kurfürstendamm 226 10719 Berlin, Germany The provider’s privacy policy can be found here: https://blog.rtbhouse.com/privacy-policy/ | (Joint) Data Controller | EU | - |
| Marketing tool service provider (8): Taboola Germany GmbH Alt-Moabit 2, 10557 Berlin, Germany The provider’s privacy policy can be found here: https://www.taboola.com/de/policies/datenschutzerklaerung | (Joint) Data Controller | EU | - |
| Marketing tool service provider (9): Axel Springer Teaser Ad GmbH (“Ad-up”) Axel-Springer-Straße 65, 10969 Berlin, Germany The provider’s privacy policy can be found here: https://www.adup-tech.com/rechtliches/datenschutz/ | (Joint) Data Controller We process data jointly with Axel Springer Teaser Ad Deutschland. Where applicable, Axel Springer Teaser Ad Deutschland may transfer data to third countries, such as the USA, within its area of responsibility. | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj |
| Marketing tool service provider (10): Meta Platforms Ireland Limited Merrion Road, Dublin 4, D04 X2K5, Ireland The provider’s privacy policy can be found here: https://de-de.facebook.com/about/privacy/ | (Joint) Data Controller We process data jointly with Meta Ireland. Where applicable, Meta Ireland may transfer data to third countries, such as the USA, within its area of responsibility. | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Meta is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| Marketing tool service provider (11): TikTok Technology Limited 10 Earlsfort Terrace, Dublin, D02 T380, Ireland The provider’s privacy policy can be found here: https://www.tiktok.com/legal/page/eea/privacy-policy/de | (Joint) Data Controller | The provider to whom we transfer personal data or who collects such data via our website is based in the EU. This provider may, within its own area of responsibility, transfer data to third countries, in particular the USA. We have no knowledge of this. | For some of these third countries, there may be a so-called adequacy decision by the European Commission within the meaning of Article 45 of the GDPR, to which a transfer by the provider may be subject. Furthermore, such transfers are regularly carried out on the basis of so-called ‘standard contractual clauses’ adopted by the European Commission under Article 46(2)(c) of the GDPR, in order to ensure an adequate level of protection for the data transferred. Further information on the relevant adequacy decisions or standard contractual clauses may be obtained from the provider. |
| Marketing tool service provider (12): Pinterest Europe Limited 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland The provider’s privacy policy can be found here: https://policy.pinterest.com/de/privacy-policy | (Joint) Data Controller | The provider to whom we transfer personal data or who collects such data via our website is based in the EU. This provider may, where applicable, transfer data to third countries – in particular the USA – within its own area of responsibility. We have no knowledge of this. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Pinterest is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| Marketing tool service provider (13): Reddit Inc. 303 2nd St, San Francisco, CA 94107, United States The provider’s privacy policy can be found here: https://www.reddit.com/policies/privacy-policy | (Joint) Data Controller | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Microsoft is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| Marketing tool service provider (14): AppsFlyer Ltd. 14 Maskit St., Herzliya, Israel The provider’s privacy policy can be found here: https://www.appsflyer.com/legal/services-privacy-policy/ | Data processor | EU and Israel Where applicable, AppsFlyer may transfer data to other third countries, such as the USA, in the course of providing its services (e.g. via sub-processors). | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR (Decision 2011/61/EU) is in place for the transfer of personal data to Israel. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec/2011/61(1)/oj For any data transfers by AppsFlyer to third countries without an adequacy decision (such as the USA), AppsFlyer uses appropriate safeguards such as the EU Standard Contractual Clauses in accordance with Article 46(2)(c) of the GDPR or relies on the EU-US Data Privacy Framework for self-certified recipients there. |
Use of web analytics technologies (using ‘analytics’ cookies and similar tracking technologies (app))
Provided you have given your consent to this in our data privacy and cookie settings we use certain web analytics technologies on our website or app (i.e. if you have consented to the ‘Analytics’ category or to individual web analytics technologies listed under this category in our Privacy and Cookie Settings). The respective providers are listed in → Section B.III.3, and you can select specific technologies in our privacy and cookie settings.
Web analytics enables the collection and analysis of information about the activities of users of our website or app. These web analytics technologies are used for the following purposes:
Improvement of the website and app, including through so-called “A/B tests” (comparison of user behaviour across different layout variants of our website)
Better achievement of the website and app’s objectives ( e.g. increasing page views)
Calculating remuneration for advertising partners (affiliates)
One specific aspect of web analytics is the creation of video recordings of the content of our users’ browser windows when they visit our website, using monitoring technology from Datadog and Mouseflow. The video recordings reveal the details of interactions with our website (for example, by showing mouse movements), which is necessary in certain error scenarios where aggregated insights from regular web analytics are insufficient.
We use cookies for these purposes (🡪 Section H.III.3).
You will find more detailed information on this below:
| Categories of personal data we process | Personal data in the categories | Sources of data | Obligation to make the data available | Duration of storage |
|---|---|---|---|---|
| Web analytics HTTP data / App analytics event data (separately for each web analytics tool) | Log data generated automatically for technical reasons when you visit the website and use our native app via the Hypertext Transfer Protocol (Secure) (HTTP(S)). This includes your IP address, the type and version of your web browser or the HTTP component used in the app, the operating system used or the operating system of the end device, the page accessed or the API endpoint called, the previously visited page (referrer URL), and the date and time of the request. Within the app (in particular Firebase for Google Analytics): device ID (IMEI / advertising IDs such as IDFA/GAID), app instance ID, IP address, operating system used, device and system properties, installed app version, page/screen accessed, date and time of access, app updates, app launches. In addition, links to our website from our advertising partners may contain certain parameters that enable us to better identify the origin of our users (e.g. identification numbers of specific advertising media or campaigns) | Users of the website or app. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we cannot carry out web analytics using the relevant web analytics tool. | For GoogleAnalytics & Firebase for Google Analytics: On this website and in the app, so-called IP anonymisation or IP masking is enabled for the use of the web analytics tools Google Analytics and Firebase for Google Analytics. This means that the IP address, which is transmitted for technical reasons, is anonymised by truncating the IP address before it is stored. With Firebase for Google Analytics, the IP address is, by default, used only to determine the approximate geographical location and is then discarded. We store the remaining data for 14 months (or a maximum of 38 months for certain Google Analytics historical data). For AB Tasty and Mouseflow (website only): The IP address is transmitted to AB Tasty/Mouseflow and converted into an approximate location. The IP address is not stored by AB Tasty/Mouseflow and is used solely to identify the location. We store the remaining data for the duration of the session. In the case of Mouseflow, for 12 months. For Datadog (website only): No IP addresses are stored. We store the remaining data for 30 days. For Factfinder (website and app): The IP address isstored in log files. |
| Web/app analytics cookie and device identifier data (separately for each web analytics tool) | Data stored in cookies or similar technologies (such as app IDs/SDK technologies) for the relevant web analytics tool (e.g. Google Analytics / Firebase for Google Analytics) on users’ devices. This includes a unique ID (such as a client ID, app instance ID or advertising ID) for the (re)identification of returning visitors. It may also include test and variant IDs for assigning different display variants of our website, as well as timestamps. (🡪 See Section H.III.3 for detailed information on the contents of the cookies used.) | User of the website or app. | Provision is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we cannot carry out web analytics using the relevant web analytics tool. | We do not store the cookies themselves. However, the data contained in the cookies is incorporated into the relevant web analytics profile data (see the data category ‘Web analytics profile data’ below). (🡪 See Section H.III.3 for information on the validity period of the cookies used.) |
| Web/App Analysis Profile Data (separately for each web analytics tool) | Data generated by the respective web analytics tool (such as Google Analytics / Firebase for Google Analytics) and stored separately for that tool in pseudonymous usage profiles. This includes information about the use of the website or app, in particular page and screen views, frequency of visits, time spent on pages/screens visited, the order in which content is accessed, in-app purchases, clicks, interactive actions such as adding items to or emptying a shopping basket, and the origin of individual visitors (i.e. via which advertising partner or advertising campaign a visitor arrived at the website or app), linked to the unique ID of the respective visitor contained in the relevant web analytics cookie or device identifier data. | Generated automatically. | - | For Google Analytics & Firebase for Google Analytics: 14 months (or up to 38 months for certain Google Analytics historical data). For AB Tasty (website only): 13 months For Datadog (website only): 30 days For Mouseflow (website only): 12 months |
| Video data | Video recording of the browser content from a session (a visit) by our website users. The video recording displays the browser content exactly as the respective user saw it, including mouse movements. Where text is entered into text fields, the text is obscured; for example, entries are displayed in the video recordings as “xxxxxxxxx”. Content from other browser windows outside our website or other screen content is not visible. Mouseflow: Website content containing personally identifiable information is not recorded (e.g. your name when you are logged into your account). | Generated automatically | - | Data Dog: 30 days Mouseflow: 12 months |
| Factfinder search function data | These include search terms, a unique ID for identifying the visitor during the session, and an ID for identifying the session. | Generated automatically. | Provision is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we cannot carry out web analytics using the relevant web analytics tool. | Stored locally in the browser’s session storage or in the visitor’s app’s working memory until the end of the session. |
| Purpose of the processing of personal data | Categories of personal data we process | Automated decision-making | Legal grounds and legitimate interests | Recipient |
|---|---|---|---|---|
| Web analytics to better achieve the objectives of the website or app (e.g. increasing page views): To this end, users’ behaviour on our website and app is recorded and analysed in pseudonymised form. Users of the website or app are identified in pseudonymised form (e.g. by means of cookies or app instance IDs) so that they can be recognised on the website or app . Pseudonymous usage profiles are created from this information. The pseudonymous usage profiles are not merged with data relating to the person behind the pseudonym. The aim of this process is to investigate where users come from (e.g. via which advertising partners and which advertising campaigns), which areas of the website or app are visited, and how often and for how long specific subpages and categories are viewed. This enables us to improve our website and app by tailoring them to the needs of our users, to better manage our campaigns, and to calculate the remuneration payable to our advertising partners (affiliates). Cookies or similar technologies (e.g. SDKs from web analytics tools) are used for these purposes. (🡪 See Section H.III.3 for detailed information on the purposes for which the cookies are used.) | Web analytics HTTP data / App analytics event data Web/app analytics cookie and device identifier data Web/app analytics profile data | No automated decision-making takes place. | Article 6(1)(a) of the General Data Protection Regulation (consent). | For Google Analytics & Firebase for Google Analytics: Google Ireland Limited For AB Tasty (website only): AB Tasty SAS For Datadog (website only): Datadog, Inc. |
| A/B testing based on web analytics: Web analytics also includes the performance of so-called ‘A/B tests’ (also known as ‘split testing’), in which we test different layout variants of our website against one another. This testing method enables us to automatically display different layout variants of a specific page to different users of our website on a random basis. In doing so, details of user behaviour across different versions are recorded, analysed and compared (e.g. analysing which version of our newsletter sign-up form results in more people subscribing to the newsletter). The aim is to optimise the website for a better user experience (e.g. optimising functions, layouts and transparency). | Web analytics HTTP data / App analytics event data Web analytics cookie data Web analytics profile data | No automated decision-making takes place. | Article 6(1)(a) of the General Data Protection Regulation (consent). | For Google Optimize: Google Ireland Limited For AB Tasty: AB Tasty SAS |
| Video recording when signing up for the newsletter or a member account and during the checkout process to improve the website and identify errors more quickly: Videos are created from the usage profiles generated using Datadog’s web analytics technology; these videos reproduce the content of the browser window exactly as the respective user saw it and interacted with it whilst visiting our website. To this end, the web analytics tool records, in particular, mouse movements. When text is entered into text fields, the text is obscured; that is, entries are displayed in the video recordings as, for example, “xxxxxxxxx”. Consequently, no data entered by our users is recorded. The aim of the analysis is to identify sources of error on the website and to understand how they arise. We use the information obtained to improve our website and better achieve its objectives (e.g. ensuring good navigation on the website). We only view such individual video recordings if the aggregated findings from our regular web analytics are insufficient (e.g. because error scenarios are highly specific, such as due to particular characteristics of the browser being used). | Web analytics profile data Datadog video data | No automated decision-making takes place. | Article 6(1)(a) of the GDPR (consent). | Datadog |
| Provision and optimisation of the search functions on our website or app: To this end, data that you enter into our search functions is sent to Factfinder’s servers. The information collected enables the FactFinder search tool to learn from user behaviour. The data provided may be used to track events such as visiting product detail pages, adding products to the basket or completing a purchase. This information forms the basis for automated search optimisation. Search results are continuously improved based on the user behaviour identified. | Search function data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to provide the website’s search functions accessed by the user. | Omikron Data Quality GmbH |
| Web analytics to better achieve the website’s objectives (e.g. improved user experience). To this end, user behaviour (click, mouse movement and scroll data at URL level) is visualised in various ways (e.g. heatmaps, screen captures, form analyses). Entries in text fields are expressly not recorded and are deliberately obscured and displayed as “xxxx”. Content that may contain personal data is also expressly not recorded. Users’ movements within the online shop across the various pages are also recorded and analysed in the form of user journeys and funnel analyses in order to optimise the user experience and reduce errors. For analysis purposes, data may be linked to user segments for personalisation using the Bloomreach software or for A/B testing using the AB Tasty software. | Web analytics HTTP data / App analytics event data Web analytics cookie data Web analytics profile data Video data (Mouseflow) | No automated decision-making takes place. | Article 6(1)(a) of the General Data Protection Regulation (consent). | Mouseflow |
| Recipient | Role of the recipient | Transfer to third countries and/or to international organisations | Adequacy decision or appropriate or adequate guarantees for transfers to third countries and/or international organisations |
|---|---|---|---|
| Google Analytics and Firebase for Google Analytics | |||
| Google Ireland Limited Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland | Data processors | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Google is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| AB Tasty | |||
| AB TASTY SAS 3 impasse de la Planchette F-75003 Paris | Data processor. | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As AB-Tasty’s sub-processors, Google and Microsoft, are self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to these recipients. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| Datadog | |||
| Datadog, Inc. 620 8th Ave, 45th Floor, New York, NY 10018, United States of America | Data processor | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Datadog is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| FactFinder | |||
| Omikron Data Quality GmbH Habermehlstr. 17 75172 Pforzheim | Data processor | EU | |
| Mouseflow | |||
| Mouseflow ApS Flaesketorvet 68 1711 Copenhagen Denmark | Data processor | EU and USA | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: Implementing Decision 2023/1795 – EN – EUR-Lex As Mouseflow is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: Data Privacy Framework |
Use of personalisation technologies (using personalisation cookies and similar tracking technologies (app))
Provided you have given your consent to this in our Privacy and Cookie Settings, we use certain personalisation technologies on our website and in our app within our online shop and our newsletters, as well as for our direct mail (i.e. if you have consented to the ‘Personalisation’ category or to individual personalisation technologies listed under this category in our Privacy and Cookie Settings). The respective providers are listed in → Section B.IV.3, and you can select specific technologies in our Privacy and Cookie Settings.
These personalisation technologies are used for the following purposes:
Engaging with users via product recommendations at specific points in the online shop (website and app) based on the usage behaviour of users of our website and app
Provision of the size guide tool on the website
Personalisation of content on our website or app (in particular product recommendations) based on the usage behaviour of users of our website and app, and, where applicable, based on the data stored in our users’ customer accounts
Collecting and analysing the behaviour of website or app users in order to use this information to personalise our newsletters and direct mail, tailoring them to the individual subscriber
For this purpose, we use cookies or similar technologies (🡪 Section H.III.4).
You will find detailed information on this below:
| Categories of personal data we process | Personal data in the categories | Sources of data | Obligation to make the data available | Duration of storage |
|---|---|---|---|---|
| epoq | ||||
| epoq HTTP data. | Log data generated automatically via the Hypertext Transfer Protocol (Secure) (HTTP(S)) when using the web tracking tool employed on the website. This includes your IP address, device, the type and version of your web browser, the operating system used, the page accessed, the previously visited page (referrer URL), and the date and time of access. | Users of the website. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we cannot carry out web tracking using epoq | For the use of the web tracking tool epoq on this website, so-called IP anonymisation is enabled. This means that the IP address transmitted by the browser for technical reasons is anonymised prior to storage by truncating the IP address (by deleting the last octet of the IP address). Deletion after 1 year. |
| epoq cookie data. | Data stored in cookies for the web tracking tool on users’ devices. This includes a unique ID for the (re)identification of returning visitors. It also includes information on the types of pages visited by the user (e.g. thank-you page after an order, product detail page, shopping basket), product numbers of the products viewed, and the number of products in the shopping basket. (🡪 See Section H.III.4 for detailed information on the contents of the cookies used.) | Website user. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we cannot carry out web tracking using epoq. | (🡪 See Section H.III.4 for information on the validity period of the cookies used.) |
| epoq profile data. | Data that we generate via the web tracking tool and which is stored in pseudonymous usage profiles. This includes information about the use of the website, in particular page views, frequency of visits and time spent on the pages visited, linked to the unique visitor ID of the respective visitor contained in the epoq cookie data. | Generated automatically. | - | Deleted after 1 year. |
| Saiz | ||||
| Saiz-HTTP-Data | Log data generated automatically via the Hypertext Transfer Protocol (Secure) (HTTP(S)) when using the Saiz size guide tool available on the website. This includes your IP address, the type and version of your web browser, the operating system used, the page accessed, the previously visited page (referrer URL), and the date and time of access. | Website user. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide this data, we will be unable to offer you sizing advice. | 90 days |
| Saiz-Cookie-Data | Data stored in cookies for the Saiz size advice tool on users’ devices. This includes a unique ID for the (re)identification of users of the size advice tool. (🡪 See Section H.III. for more detailed information on the content of the cookies used.) | Website users. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide the data, we will be unable to offer you size advice. | We do not store either the cookies themselves or the information contained within them. (🡪 See Section H.III.4 for information on the validity period of the cookies used.) |
| Size advice data | Data generated when using the size guide tool: This includes information you provide when using the size advice tool: age, gender, height in cm, bust measurement (if applicable), hip measurement (if applicable), waist measurement (if applicable), weight, information on body build and body shape, as well as your IP address, which is linked to the unique ID of the respective visitor contained in the relevant Saiz cookie data. This also includes information on the recommended sizes and the probabilities that these sizes will fit. | User of the size guide. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide the data, we will be unable to offer you a size advice service | 90 days. |
| Bloomreach | ||||
| Bloomreach HTTP data | Log data generated automatically via the Hypertext Transfer Protocol (Secure) (HTTP(S)) when using the Bloomreach personalisation tool on the website or app. This includes your IP address, device type, the type and version of your web browser or the HTTP component used in the app, the operating system you are using or the operating system of the end device, the number of pages viewed, the number of visits, the sequence of visits and the duration of each visit. | Users of the website or app. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide the data, we will be unable to offer you an optimised or personalised user experience. | The IP address is transmitted to Bloomreach and converted into an approximate location. The IP address is not stored by Bloomreach and is used solely to identify the location. The remaining data is also stored in anonymised form so that it can be analysed for statistical purposes. |
| Bloomreach cookie data | Data stored in cookies for the Bloomreach personalisation tool on users’ devices. This includes a unique ID for the (re)identification of returning visitors. It also includes usage and interaction data: pages visited and time spent on them, click behaviour, search queries on the website or app, and interactions with banners or product recommendations. (🡪 See Section H.III.4 for detailed information on the contents of the cookies used.) | Users of the website or app. | Provision is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide the data, we will be unable to offer you an optimised or personalised user experience. | Cookie data is stored for between 7 days and 3 years. (🡪 See section H.III.4 for information on the validity period of the cookies used.) |
| Bloomreach profile data | Data that we generate via the Bloomreach personalisation tool and which is stored in pseudonymous or customer-specific usage profiles: This includes information about the use of the website or app, in particular page views, actions on the website or app (e.g. adding products to the shopping basket), frequency of visits and time spent on pages visited, linked to the unique visit ID or the app instance ID in the app of the respective visitor. Where linked to a member account, this also includes the member ID and email address of the customer, as well as transaction data stored in the member account relating to orders placed in our online shop (website and app) and other purchases linked to the member account (e.g. in our high-street shops). This also includes information on the preferences and interests of users or customers derived from this data. | User of the website or app. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide the data, we will be unable to offer you an optimised or personalised user experience. | We store this data for as long as you remain subscribed to our newsletter or enrolled in our loyalty programme. We also store this data in anonymised form for internal statistical analysis. |
| Emarsys eMarketing Systems AG | ||||
| Emarsys HTTP data | Log data generated automatically for technical reasons when using the Emarsys web tracking tool via the Hypertext Transfer Protocol (Secure) (HTTP(S)). The data collected includes the following: Browser and its version Operating system Referring URL IP address (encrypted and truncated) Session and cookie IDs Country | Website user. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we cannot carry out web tracking using Emarsys. | 1 year. |
| Emarsys cookie data | Data stored in the Emarsys cookies for the relevant web tracking tool on users’ devices. In general, the cookies collect the following two types of information: Information about the service IP address Browser Cookie identifiers Pseudonymised identifiers (newsletter or member) when visiting the website. Information on browsing behaviour Product numbers of the products viewed Product numbers of the products added to the shopping basket Product numbers of the products purchased | Website users. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to carry out web tracking or (insofar as this is the purpose of the relevant web tracking tool) to send users personalised advertising. | The expiry dates are normally one year, with the exception of session cookies, which are deleted at the end of each session. (🡪 See Section H.III.4 for information on the validity periods of the cookies used.) |
| Emarsys profile data | The Emarsys database regularly updates data it has collected during visitor sessions. Here, the identifiers for these sessions stored in cookies are matched to the identification keys stored in the Emarsys contact database (e.g. encrypted email addresses). This also includes interests in products or product categories derived from this usage behaviour data. | Generated by Emarsys | - | We store this data for as long as you remain subscribed to our newsletter. We also store this data in anonymised form in order to analyse it for internal statistical purposes. |
| Purpose of the processing of personal data | Categories of personal data we process | Automated decision-making | Legal grounds and legitimate interests | Recipient |
|---|---|---|---|---|
| epoq | ||||
| Targeting users with product recommendations at specific points in the online shop based on the usage behaviour of our website’s users: To this end, users’ behaviour on our website is recorded and analysed in pseudonymised form. Website users are identified in pseudonymised form so that we can recognise them on our website . Pseudonymous usage profiles are created from this information. The pseudonymous usage profiles are not merged with data relating to the person behind the pseudonym. The aim of this process is to draw the attention of a user who has already shown an interest in a product on our website to that product again whilst they are on our website, in order to increase the relevance of the advertising and thus the click-through and conversion rates (e.g. order rate). We also use the (truncated) IP address to determine the approximate geographical location of users in order to further personalise product recommendations based on location (e.g. based on the weather at the respective location). epoq offers various analytics tools for this purpose. (🡪 See Section H.III.4 for detailed information on the purposes for which the cookies are used.) | epoq HTTP data, epoq cookie data, epoq profile data | No automated decision-making takes place. | Article 6(1)(a) of the General Data Protection Regulation (consent). | epoq |
| SAIZ | ||||
| Provision of the size guide tool on the website: The size guide tool recommends the size most likely to fit users. Once users have entered their body measurements, the tool calculates, based on real-world fit data, the probability that a particular size of our product will fit the user in question. Data is pseudonymised and processed temporarily on our web server in order to provide you with the size advice tool and to ensure the security of the tool’s IT infrastructure. To this end, information about your use of the size advice tool is stored in cookies (🡪 Section H.III.4) on your device. If you wish, you can delete the data stored in cookies on our servers and on your device yourself at any time via our cookie banner. | Saiz HTTP data, Saiz cookie data, size guide data | No automated decision-making takes place | Article 6(1)(a) of the General Data Protection Regulation (consent). | Saiz GmbH |
| Bloomreach | ||||
| Personalisation of content on our website or app (in particular product recommendations) based on the usage behaviour of our website and app users and, where applicable, on the data stored in our users’ customer accounts: When you visit our website or app, information about your use of our website or app is collected and stored in a profile that is initially pseudonymous. In order to be able to associate this information with your device, a unique ID is assigned to your device and linked to the profile. This ID is stored in cookies (--> Section H.III.4) on your device. Your device can be recognised by the ID assigned to it, so that subsequent visits made using the same device can also be associated with the profile. Usage and interaction data, as well as transaction and e-commerce data from users, are collected in pseudonymised form, assigned to the usage profile and analysed. If, after you have logged in to your customer account, we are able to identify you as a registered Marc O’Polo customer, the pseudonymised usage information collected (including prior to logging in) is merged with the existing customer data. This creates a customer-specific usage profile which, in particular, also consolidates usage across different devices. Any orders you may have placed as a guest (“guest checkout without logging into your member account”) will be added to your customer account in the background using your email address, provided you have already created an account with that email address or create a customer account after placing the order as a guest. (Note: The order will be added to your purchase history, but no bonus points will be credited.) We use the information collected to better tailor the content we display to you on our website, the app and its push notifications to your personal interests. This includes, for example, personalised product and size recommendations based on the data you have entered, as well as content specifically tailored to you that we believe may be relevant to you. We use cookies for these purposes. (🡪 See Section H.III.4 for detailed information on the purposes for which the cookies are used.) Please note: If , in addition to giving your consent to ‘personalisation’ in general or at least to personalisation via ‘Bloomreach’, you have also given your consent to one or more of the ‘marketing’ tools (you can check this via our privacy and cookie settings ), we further enrich the profiles created by the respective providers of the marketing tools with information from the profiles created by Bloomreach, so that we can also display the content – which is better personalised in this way – to you on other marketing channels (e.g. Facebook) (--> Section B.IV.2). | Bloomreach HTTP data, Bloomreach cookie data, Bloomreach profile data. All data categories from Sections C (Online Shop) and E (Member Account) | No automated decision-making takes place. | Article 6(1)(a) of the General Data Protection Regulation (consent). | Bloomreach |
| Emarsys eMarketing Systems AG | ||||
| Collection and analysis of website users’ behaviour in order to personalise our newsletters and direct mail, tailoring them to the individual subscriber: The collection and analysis of your usage behaviour via the Emarsys analytics tool only takes place if you have given your consent to “personalisation” in our privacy and cookie settings and have also have subscribed to our email newsletter (--> Section D) and/or are a member of our loyalty programme (--> Section E). In this case, a usage profile is created from your usage behaviour/click data in order to deduce your interests in our products. In order to provide you with personalised content (newsletters or direct mail), we store the interests identified in this way as category data (for example, the most recently clicked category or products added to the shopping basket, but not specific click paths) in your customer profile, which we maintain for you as a participant in the loyalty programme. We use cookies for these purposes. (🡪 See Section H.III.4 for detailed information on the purposes for which the cookies are used.) | Emarsys HTTP data Emarsys cookie data Emarsys profile data | No automated decision-making takes place. | Article 6(1)(a) of the General Data Protection Regulation (consent). | Emarsys eMarketing Systems AG |
| Recipient | Role of the recipient | Transfer to third countries and/or to international organisations | Adequacy decision or appropriate or adequate guarantees for transfers to third countries and/or international organisations |
|---|---|---|---|
| Epoq | |||
| epoq internet services GmbH ⋅ Willy-Brandt-Straße 3 ⋅ 76275 Ettlingen | Data processor. | EU. | - |
| SAIZ | |||
| SAIZ GmbH (Pappelallee 78/79, 10437 Berlin, Germany) | Data processor. | EU and USA. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj The transfer of personal data to the USA is carried out via Saiz’s subcontractors |
| Bloomreach | |||
| Bloomreach B.V. Fred. Roeskestraat 109, 1076 EE Amsterdam, Netherlands | Data processor | EU and USA. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Bloomreach is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| Emarsys eMarketing Systems AG | |||
| Emarsys eMarketing Systems AG Hans-Fischer-Str. 10, 80339 Munich, Germany | Data processor | EU and UK. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the United Kingdom (UK). The adequacy decision is available here: http://data.europa.eu/eli/dec_impl/2021/1772/oj |
| Talon.One GmbH | |||
| Talon.One GmbH Wiener Straße 10, 10999 Berlin, Germany | Data processors | EU and UK. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the United Kingdom (UK). The adequacy decision is available here: http://data.europa.eu/eli/dec_impl/2021/1772/oj |
C. Information on the processing of personal data of customers of our online shop (website and app)
Information on the processing of personal data of customers of our online shop (website and app)
On our website and in our app, you have the option to use our MARC O’POLO online shops, which are accessible in different country-specific versions via country-specific URLs (e.g. for Germany at http://www.qolzirvaxune.site/de-de/ ) (hereinafter referred to as ‘country shops’). An overview of the individual country shops can be found in Part A, Section 1.1 of our Terms and Conditions. The country shops on the app and website are hereinafter collectively referred to as the ‘online shop’.
When you use our Online Shop, we process various items of personal data that you provide to us, for example via the order form, for the following purposes:
To provide various functions in our online shop,
for the conclusion, execution and cancellation of sales contracts,
to send emails containing advertising for our own similar products in accordance with the provisions of Section 7(3) of the Unfair Competition Act (UWG),
to ensure the security of the IT infrastructure used to operate the online shop,
to manage and enforce our claims for the purchase price,
to provide the review function,
to provide address correction suggestions during the ‘Checkout’ stage of the ordering process,
to carry out an order and risk assessment prior to the completion of the order,
to carry out a fraud and creditworthiness check during and after the order is completed,
to carry out a sustainability check,
to carry out customer surveys
for market research purposes, and
for evidential purposes and to fulfil statutory retention obligations
You can place orders in our Online Shop ‘as a guest’ (website only) or, alternatively, via a customer account. Use of our customer account in the Country Shops is exclusively available to participants in the MARC O’POLO loyalty programme COMMUNITY . Details of the processing of personal data relating to participants in the loyalty programme, including the use of the member account, are set out in Section E of this privacy policy.
Below you will find detailed information on this:
Details of the personal data that is processed
| Categories of personal data we process | Personal data in the categories | Sources of data | Obligation to make the data available | Duration of storage |
|---|---|---|---|---|
| HTTP data. | Log data generated automatically for technical reasons when accessing the website and using our native app via the Hypertext Transfer Protocol (Secure) (HTTP(S)). On the website: This includes your IP address, the type and version of your web browser, the operating system used, the page accessed, the previously visited page (referrer URL), and the date and time of access. In the app: This includes your IP address, the type and version of the HTTP component used in the app, the operating system used or the operating system of the end device, the page accessed or the web address of a technical service (API endpoint) accessed by the app via which data is received or provided, the previously visited page (referrer URL), and the date and time of access. | User of the online shop. | The provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to display the requested content on the website. | Data is stored in server log files in a form that allows the identification of the data subjects for a maximum period of 7 days, unless a security-related incident occurs (e.g. a DDoS attack). In the event of a security-related incident, server log files are stored until the security-related incident has been resolved and fully investigated. |
| Shopping basket data. | Data relating to products that you place in the online shop’s shopping basket. This includes product description, product code, quantity, size, colour, price and currency. | Online shop user. | Provision of this data is necessary to conclude a contract of sale. There is no obligation to provide the data. If you do not provide this data, you will not be able to purchase items via our online shop. | Before completing an order: Without logging in: We do not store this data permanently on our systems, but only process it temporarily whilst the website or app is being used ( e.g. to display the contents of the shopping basket). The data is stored temporarily locally in the user’s browser or in the app for the duration of the respective user’s session. With/after logging in: When you log in to your customer account, the shopping basket data is permanently stored in your profile. After completing an order: Data is stored until your order has been fully processed, i.e. until the goods have been dispatched. We also store this data for evidential purposes in order to assert, exercise or defend legal claims, and for a transitional period of three years from the end of the year in which you provided us with the data, and in the event of any legal disputes, until such disputes are resolved. We also store this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the type of document, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| Contact details. | Data that you provide to us as part of the ordering process so that we can contact you to process your order. This may include, in particular, the following details: title, surname, first name, postal address, telephone number and email address. | Online shop user. | The provision of data marked as mandatory during the ordering process is necessary for the conclusion of the contract. There is no obligation to provide this data. If the data is not provided, it will not be possible to conclude a contract. | Data is stored until your order has been fully processed, i.e. until the goods have been dispatched. We also store this data for evidential purposes in connection with the potential assertion, exercise or defence of legal claims, and for a transitional period of three years from the end of the year in which you provided us with the data, and in the event of any legal disputes, until such disputes are resolved. We also retain this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the type of document, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| Delivery details. | Data that you provide to us as part of the ordering process for the dispatch of the items you have ordered. This includes the delivery method you have selected and, where applicable, any delivery address you have provided that differs from the billing address. | Online shop user. | Provision of this data is necessary to conclude a contract of sale. There is no obligation to provide the data. If you do not provide this data, you will not be able to purchase any items via our online shop. | We store the data until your order has been fully processed, i.e. until the goods have been dispatched. We also store this data for evidential purposes in connection with the potential assertion, exercise or defence of legal claims, and for a transitional period of three years from the end of the year in which you provided us with the data, and in the event of any legal disputes, until such disputes are resolved. We also retain this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the type of document, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| Payment details. | Data that you provide to us for the payment of the items you have ordered. This depends on the payment method you choose. Depending on the payment method, this includes, for example, your IBAN, BIC or billing address. | Online shop user. | The provision of data marked as mandatory during the ordering process is required for the conclusion of the contract. There is no obligation to provide this data. If the mandatory details are not provided, it is not possible to conclude a contract. | Data will be stored until your order has been fully processed, i.e. until the goods have been dispatched. We store this data for evidential purposes in order to assert, exercise or defend legal claims, and furthermore for a transitional period of three years from the end of the year in which you provided us with the data, and in the event of any legal disputes, until such disputes are resolved. We also retain this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the type of document, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| Order details. | Information about your order. This includes details of the items purchased (item description, item number, price, currency, order number), the store version used, the date and time of the respective purchase, the device used and, if using the app, its operating system, the selected payment method and delivery method, and the status of your order. | Generated automatically. | - | Data is stored until your order has been fully processed, i.e. until the goods have been dispatched. We also store this data for evidential purposes in connection with the assertion, exercise or defence of legal claims, and for a transitional period of three years from the end of the year in which you provided us with the data, and in the event of any legal disputes, until such disputes are resolved. We also retain this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the type of document, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| Customer account data. | Data that we process for the administration of our purchase price receivables within our internal accounts receivable management system. This includes, in particular, information regarding confirmation or cancellation of payment, current outstanding items, incoming payments, reminder stages, ongoing debt collection processes and returns. | Payment service providers, debt collection agencies, generated independently. | - | Data is stored until your order has been fully processed, i.e. until the goods have been dispatched. We also store this data for evidential purposes in connection with the potential assertion, exercise or defence of legal claims, and for a transitional period of three years from the end of the year in which you provided us with the data, and in the event of any legal disputes, until such disputes are resolved. We also retain this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the type of document, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| Transaction e-mail data. | Information from transactional emails that we send to process or cancel your order (e.g. order confirmation). This includes the content and time of the transactional emails. | Generated independently. | - | Data is stored until your order has been fully processed. This includes, in particular, any potential cancellation of the order. We also store this data for evidential purposes in connection with the assertion, exercise or defence of legal claims, and for a transitional period of three years from the end of the year in which you provided us with the data, and in the event of any legal disputes, until such disputes are resolved. We also store this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the type of document, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| Order and return values. | Reasons for returns, if provided in connection with a return. | User of the online shop. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to take the reasons for returns into account when calculating and assessing the returns rate. | We do not store the reasons for returns on our systems. We store the return rate calculated by us for 24 months. |
| Order and return values. | The order total and the total price of the returned goods, as well as the contact details you have provided, which we require to calculate your return rate. To calculate your return rate, we determine the percentage of your returns based on the total order value you have generated through orders placed in our online shop. | Generated independently. | - | We do not store the reasons for returns on our systems. We store the return rate calculated by us for 24 months. |
| Creditworthiness data. | Information regarding our customers’ creditworthiness. This includes, in particular, credit reports provided by credit reference agencies based on insolvency and debtors’ register data from local courts, as well as notifications from creditors or their representatives regarding payment behaviour in breach of contract. | Credit reference agencies. | - | We store the data until your order has been fully processed, i.e. until the goods have been dispatched. We also store this data for evidential purposes in connection with the potential assertion, exercise or defence of legal claims, and furthermore for a transitional period of three years from the end of the year in which you provided us with the data, and in the event of any legal disputes, until such disputes are resolved. We also retain this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the type of documentation, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| Creditworthiness data. | This also includes information generated by us regarding the timely settlement of our claims and findings we derive from past fraud and credit checks, such as credit limit settings for your purchases. | Generated independently. | - | We store the data until your order has been fully processed, i.e. until the goods have been dispatched. We also store this data for evidential purposes in connection with the potential assertion, exercise or defence of legal claims, and furthermore for a transitional period of three years from the end of the year in which you provided us with the data, and in the event of any legal disputes, until such disputes are resolved. We also retain this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the type of documentation, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| Market research data. | Information that we collect as part of customer surveys for market research purposes, in order to analyse, in pseudonymised form, in particular our customers’ satisfaction and to improve the content of our offering. | Users of the online shop. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to carry out surveys and analyses for market research purposes. | We store this data in pseudonymised form for a maximum of 38 months. We also store this data in anonymised form in order to analyse it for internal statistical purposes. |
| App review data | Information that we collect as part of customer surveys for market research purposes, in order to analyse, in pseudonymised form, in particular our customers’ satisfaction with our app and to improve the content of our offering. | Users of the online shop (app only). | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to carry out surveys and analyses for market research purposes. | We store this data in pseudonymised form for a maximum of 38 months. We also store this data in anonymised form in order to analyse it for internal statistical purposes. |
| Advertising management data. | Information regarding any consent you have given for marketing purposes, as well as any objections you may have raised to marketing. This includes the subject matter, date and time of the consent, the IP address of the device used to give consent, and the subject matter, date and time of any withdrawal of consent or objection to the processing of personal data for advertising purposes. | Users of the online shop. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide the data, we will be unable to take your consents or your objections to advertising into account. | We store this data for as long as consent remains in force or for as long as we carry out advertising activities without consent on the basis of the information provided to you regarding such advertising. We also store this data for evidential purposes in order to assert, exercise or defend legal claims, and furthermore for a transitional period of three years from the end of the year in which you withdrew your consent or we ceased the relevant advertising measure, and in the event of any legal disputes, until such disputes are resolved. |
| Virtual fitting data. | Information relating to the virtual fitting, which we collect on the basis of your consent during the session. This includes the subject matter, date and time of consent, the IP address of the device used to give consent, and the subject matter, date and time of any withdrawal of consent or objection to the processing of personal data for advertising purposes. | Users of the online shop. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide the data, we will be unable to offer you the virtual fitting service. | We store this data for the duration of a session. |
Details about the processing of personal data
| Purpose of the processing of personal data | Categories of personal data we process | Automated decision-making | Legal grounds and legitimate interests | Recipient |
|---|---|---|---|---|
| Provision of our online shop functions on the website or app. To this end, HTTP data is processed temporarily on our web server. | HTTP data, shopping basket data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to provide the website content accessed by the user. | Hosting provider. |
| Conclusion and fulfilment of sales contracts concluded via the online shop. This includes, in particular, processing the payment, dispatching the goods you have ordered, and sending transactional emails to inform you of the current status of your order. If you choose a payment service provider when making a payment, it is possible that they may carry out a credit check. Please refer to the privacy policies of our payment partners: Adyen N.V., Simon Carmiggelstraat 6-50, 1011 DJ Amsterdam, Netherlands; credit card (Visa, MasterCard), P24, iDeal, Klarna: Adyen Privacy Policy Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden: Paylater (purchase on account): Klarna Privacy Policy PayPal (Europe), S.à.r.l. et Cie, S.C.A, 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg: PayPal: PayPal Privacy Policy American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany: American Express credit card: American Express Privacy Policy | Shopping basket data, contact details, delivery details, payment details, order details, transaction email details. If you select payment service providers such as Klarna, PayPal, P24 and iDeal, we will pass on the following data: Order details, contact details | No automated decision-making takes place. | Article 6(1)(b) of the General Data Protection Regulation (fulfilment of a contract or implementation of pre-contractual measures). | Hosting providers, Arvato Distributions, parcelLab, system and service email providers, delivery service providers, payment service providers. |
| Carrying out a check on your order based on general characteristics such as order volume, a delivery address that differs from the billing address, or whether you are a new or existing customer. Based on automated checks, a shortlist of payment methods is drawn up, which we offer to you in order to minimise the risk of non-payment as far as possible. This check takes place before you select a payment method, to ensure the ordering process runs as smoothly as possible. | Contact details, shopping basket details, delivery details. | An automated decision-making process takes place, based on the following logic: The order verification begins once you have entered your contact and delivery details, before we display specific payment methods for your order. In accordance with predefined rules, we check whether processing the order carries a risk of non-payment, so that only secure payment methods are offered – i.e. no purchase on account. To this end, we may check your contact and delivery details to ensure that the address(es) provided match. To this end, we analyse the order value. In particular, we check whether the maximum order limit has been reached or whether you are placing an order as a new customer or a guest buyer. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to minimise the risk of non-payment as much as possible and to enhance the customer experience during the ordering process. | Hosting provider. |
| Prevention of incorrect billing and delivery addresses being entered, including suggestions for address corrections during the ‘Checkout’ stage of the order process. | Contact and delivery details | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to minimise the risk of non-payment as much as possible and to enhance the customer experience during the ordering process. | Address validation provider |
| Provision of the permitted payment methods, which are displayed to you as available. To this end, our service provider Arvato SE (Reinhard-Mohn-Straße 22 33333 Gütersloh) carries out a RiskCheck on our behalf. | Contact details, shopping basket details, delivery details, order details, customer account details, order and returns values | Automated decision-making takes place, based on the following logic: The check to determine which payment methods are available begins when the order is finalised by clicking on ‘Place order with payment due now’. Arvato uses the aforementioned data to carry out a risk assessment for payment default. In addition, Arvato checks the information we generate regarding the timely settlement of our claims and the findings we have drawn from past fraud audits, such as spending limits set for your purchases. In particular, Arvato checks whether the maximum order limit set has been reached. To calculate your returns rate, we determine the percentage of your returns based on the total order value you have generated through orders in our online shop. Arvato then transmits the result of the risk assessment to us automatically; we interpret this in accordance with pre-set rules, which determine whether the order can be processed using the selected payment method. If the assessment criteria are not met to a sufficient standard, you will be redirected back to the payment methods page and will then only be able to choose from other available secure payment methods. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to minimise the risk of non-payment as much as possible and to enhance the customer experience during the ordering process. | Risk Management Provider |
| Provision of the ‘Purchase on account’ payment method. To this end, our service provider Infoscore Consumer Data GmbH (Rheinstraße 99, 76532 Baden-Baden) carries out a credit check on our behalf (hereinafter ‘Infoscore’), provided you have selected the ‘Purchase on account’ payment method. | Contact details, shopping basket details, delivery details, order details, customer account details, order and returns values, creditworthiness data. | Automated decision-making takes place, based on the following logic: The credit check begins once you have consented to it by completing the order and clicking on ‘Place order with payment due now’. To this end, we transmit your contact and delivery details to the credit reference agency. The credit report contains a so-called score, which is calculated using a scientifically recognised mathematical and statistical method and is used to assess credit risk. Based on the score value provided, the service provider assesses the risk of non-payment. The service provider then sends us the results of the fraud and credit checks automatically; we interpret these according to pre-set rules and determine whether the order can be processed using the selected payment method. If the assessment criteria are not met, you will be redirected back to the payment methods page and will then only be able to choose from secure payment methods (excluding purchase on account). | Consent (Article 6(1)(a) of the General Data Protection Regulation). | Credit reference agency. |
| Conducting a fraud check after your order has been completed in order to minimise the risk of non-payment as far as possible. On the basis of predominantly automated checks, we decide to what extent we can fulfil your order as requested. The fraud check is carried out by Arvato SE (Reinhard-Mohn-Straße 22, 33333 Gütersloh) on our behalf (hereinafter “Arvato”). | Contact details, shopping basket details, delivery details, order details, customer details, order and returns values. | Automated decision-making takes place, based on the following logic: The fraud check begins when the order is completed by clicking on ‘Place order with immediate payment’. In accordance with predefined rules, Arvato checks whether processing the order carries a risk of non-payment, so that only secure payment methods should be offered, i.e. no purchase on account. To this end, Arvato first checks your contact and delivery details to ensure the accuracy of the address(es) provided. Arvato also analyses the number and value of orders placed within a specific time period. In particular, it checks the extent to which your contact and delivery details have been used for previous orders – for example, whether different email addresses have been provided for the same billing address within a short period of time. Arvato also checks the information we have generated regarding the timely settlement of our claims and insights we have gained from past fraud checks, such as spending limits set for your purchases. In particular, Arvato checks whether the maximum order limit configured has been reached, reviews your returns rate generated from order and returns data, and determines from our accounts receivable data whether and to what extent there are any current outstanding items, reminder stages or ongoing debt collection processes. If the assessment criteria cannot be adequately met, the order will be rejected. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to minimise the risk of non-payment as much as possible. | Risk and Fraud Management Provider |
| Conducting a sustainability check. Based on predominantly automated checks, we decide to what extent we can fulfil your order to the desired extent. | Contact details, order and returns values. | Automated decision-making takes place, based on the following logic: In accordance with predefined rules, we check whether fulfilling the order meets our sustainability criteria in the online shop. In particular, we check your return rate, which is generated from your order and return values. To calculate your returns rate, we determine the percentage of your returns based on the total order value you have generated through orders in our online shop. If your returns rate exceeds a certain threshold, your account will be blocked for online shopping and any other accounts associated with your contact details will be identified. You can redeem vouchers from the membership programme in-store at any time. You will be notified of this by email. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to minimise returns and the associated CO₂ emissions as much as possible | Arvato SE |
| Sending emails containing advertising for our own similar products to customers who have provided us with their email address when placing an order in the online shop and who were clearly informed at the time their email address was collected that they may object to this use of their email address at any time, without incurring any costs other than the transmission costs in accordance with the standard rates. We also reiterate this right to object each time the email address is used, i.e. in every product recommendation email. To promote our own similar products, we use the information about your previous purchases contained in the transaction email data to ensure that you only receive advertising that matches your interests. | Contact details, transaction email data, advertising management data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is the use of your email address for direct marketing of our own similar goods, subject to the conditions set out in Section 7(3) of the Unfair Competition Act (UWG). | AWS (transactional emails) |
| Conducting customer surveys for market research purposes and pseudonymised analysis of market research data to further develop and improve the content of our offering. | Market research data. | No automated decision-making takes place. | Balancing of interests (Article 6(1)(f) of the General Data Protection Regulation). Our legitimate interest is the further development and improvement of our offering. | Survey agency. |
| Ensuring the security of the IT infrastructure used to operate the online shop, in particular to identify, rectify and document malfunctions (e.g. DDoS attacks) in a manner that preserves evidence. To this end, data is temporarily stored in log files on our web server and analysed. | HTTP data, shopping basket data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to ensure the security of the IT infrastructure used to operate the online shop, in particular to identify, rectify and document malfunctions (e.g. DDoS attacks) in a manner that preserves evidence. | Hosting provider. |
| Management and enforcement of our claims for payment of the purchase price. | Contact details, customer account details. | No automated decision-making takes place. | Article 6(1)(b) of the General Data Protection Regulation (performance of a contract). | Debt collection agencies. |
| Reversal of sales contracts in the event of withdrawal or other grounds for reversal. | Contact details, delivery details, payment details, order details, transaction email details, customer account details. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is the rescission of sales contracts. | Delivery service providers. |
| Storage and processing for evidential purposes in connection with the potential assertion, exercise or defence of legal claims. | HTTP data, contact details, payment details, order details, shopping basket details, delivery details, transactional email data, customer account details, creditworthiness data, review data, advertising management data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is the assertion, exercise or defence of legal claims. | Hosting provider. |
| Retention of data to fulfil statutory retention obligations, in particular those under commercial and tax law. Depending on the type of documents, commercial and tax law retention obligations may apply for a period of six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). | Contact details, payment details, order details, shopping basket details, dispatch details, transaction email details, customer account details, review details. | No automated decision-making takes place. | Article 6(1)(c) of the General Data Protection Regulation (compliance with a legal obligation). | Hosting provider. |
| Provision of a reminder regarding product availability. | Email address (contact details), marketing management data | No automated decision-making takes place. | Article 6(1)(a) of the General Data Protection Regulation (consent). | Hosting provider. |
| Provision of a virtual fitting service on the website. By clicking on ‘I agree’, you grant Fittingbox access to use your webcam. | Virtual fitting data. | No automated decision-making takes place. | Article 6(1)(a) of the General Data Protection Regulation (consent). | Fittingbox |
Details regarding the recipients of personal data and the transfer of personal data to third countries and/or to international organisations
| Recipient | Role of the recipient | Transfer to third countries and/or to international organisations | Adequacy decision or appropriate or adequate guarantees for transfers to third countries and/or international organisations |
|---|---|---|---|
| Hosting provider (currently: commercetools GmbH, Adams-Lehmann-Str. 44, 80797 Munich, Germany) | Data processor. | EU, UK, USA, Australia, Singapore | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA and the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj There is no adequacy decision by the European Commission within the meaning of Article 45(3) of the General Data Protection Regulation for transfers to Australia and Singapore. Commerctools GmbH has Standard Contractual Clauses (SCCs) in place which have been approved in accordance with Article 46 of the General Data Protection Regulation. |
| Payment service providers | Data controller. | EU. | - |
| Delivery service providers | Data controllers. | EU. | - |
| parcelLab GmbH Schillerstr. 23a, 80336 Munich, Germany. | Data processor. | EU. | - |
| Arvato SE Reinhard-Mohn-Straße 22, 33333 Gütersloh, Germany. | Data processor. | EU. | - |
| Credit reference agency: Infoscore Consumer Data GmbH part of Experian GmbH, Rheinstraße 99, 76532 Baden-Baden | Data controller. | EU. | - |
| Debt collection agency (currently: Germany: Riverty Services GmbH, Gütersloher Str. 123, 33415 Verl, Germany Netherlands: Riverty Services Netherlands B.V., K.R. Poststraat 66, 8441 Heerenveen, Netherlands Austria: Riverty Services Austria GmbH, Karl-Popper-Straße 2/Top 6, 1100 Vienna, Austria Switzerland: infoscore Inkasso AG, part of Arvato Financial Solutions, Ifangstrasse 8, 8952 Schlieren. | Controller. | EU. | - |
| Collection agency (currently: Germany and Netherlands: Paigo GmbH, Forderungsmanagement GmbH & Co. KG, Rheinstrasse 99, 76532 Baden-Baden Austria: infoscore austria GmbH, Weyringergasse 1, 1040 Vienna Switzerland: infoscore Inkasso AG, Ifangstrasse 8, 8952 Schlieren). | Data processors. Data processors. Data processor. Data processor. | EU EU EU Switzerland. | - - - EU Commission’s adequacy decision regarding personal data in Switzerland: http://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32000D0518&from=DE |
| Emarsys eMarketing Systems AG Hans-Fischer-Straße 10 80339 Munich | Data processor. | EU and UK. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj |
| Survey agency (currently: SurveyMonkey Europe UC, 2nd Floor, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland) | Data processor. | EU. | - |
| Fittingbox S.A. 209 Rue de l’Innovation 31670 Labège France | Data controller. | EU | - |
| Mouseflow ApS Flaesketorvet 68 1711 Copenhagen Denmark | Data processor | EU and UK. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: Implementing Decision 2023/1795 – EN – EUR-Lex As Mouseflow is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: Data Privacy Framework |
| Talon.One GmbH Wiener Straße 10, 10999 Berlin | Data processor. | EU and UK. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj |
D. Information on the processing of personal data of subscribers to our email and WhatsApp newsletters and our push notifications
Information on the processing of personal data of subscribers to our email and WhatsApp newsletters and our push notifications
We offer you the option to subscribe to our email and/or WhatsApp newsletter – for example, via our website or app – as well as to our push notifications via our app. The newsletter and push notifications keep you informed about new outfits and the latest product trends, as well as our special events, promotions or competitions. We also offer the option to subscribe to our email and/or WhatsApp newsletter directly via social media platforms such as Meta and Instagram.
We can tailor the content of the newsletter and push notifications (where we have such data) to your individual preferences based on your orders in our online shop (🡪 Section C) or your membership of the MARC O’POLO COMMUNITY (🡪 Section E) (e.g. based on your purchase history, your orders via your member account or your Memberrybonus points balance). If, in addition to your email newsletter subscription, you have also given your ‘personalisation ’ consent ( or at least consent to personalisation via Emarsys (newsletter) or Bloomreach (app)) (🡪 Section B.IV), we will expand the email newsletter to include further personalised content (e.g. relating to products you have added to your basket or which we recommend based on the product category you last clicked on).
When you subscribe to the email and WhatsApp newsletters, certain information is collected, such as your email address for the email newsletter or your telephone number for the WhatsApp newsletter.When you sign up for our push notifications, information such as your device type and operating system is collected.
We process this information
to confirm your subscription
to provide the relevant newsletter
to ensure security
for evidential purposes to assert, exercise or defend legal claims
for market research purposes, if you take part in customer surveys.
When you subscribe to the newsletter via WhatsApp, we will add your telephone number to your member account or email newsletter if you provide us with the email address you also use in your member account so that we can link the two. When you use the form to subscribe to or unsubscribe from our email newsletter on the website, in the app or from our WhatsApp newsletter, certain information (such as your IP address) is sent to our website’s server or our WhatsApp provider for technical reasons via the browser or app used on your device. We process this information to provide the form for subscribing to and unsubscribing from our newsletter on the website, in the app and on WhatsApp.
You will find detailed information on this below:
Details of the personal data that is processed
| Categories of personal data we process | Personal data in the categories | Sources of data | Obligation to make the data available | Duration of storage |
|---|---|---|---|---|
| Newsletter form HTTP data. | Log data generated automatically for technical reasons when accessing the form for subscribing to or unsubscribing from our newsletter on the website and when using our native app via the Hypertext Transfer Protocol (Secure) (HTTP(S)). Email newsletter On the website: This includes your IP address, the type and version of your web browser, the operating system used, the page accessed, the previously visited page (referrer URL), and the date and time of access. In the app: This includes your IP address, the type and version of the HTTP component used in the app, the operating system used or the operating system of the end device, the page accessed or the web address of a technical service (API endpoint) accessed by the app via which data is received or provided, the previously visited page (referrer URL), and the date and time of access. WhatsApp Newsletter This includes the source of the request (e.g. QR code), as well as the date and time of the request. | User of the website , the app or WhatsApp. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we cannot make the accessed content of the website or WhatsApp available. | Data is stored in server log files in a form that allows the identification of the data subjects for a maximum period of 7 days, unless a security-related incident occurs (e.g. a DDoS attack). In the event of a security-related incident, server log files are stored until the security-related incident has been resolved and fully investigated. |
| Newsletter subscription data. | Data that we collect when you subscribe to the newsletter. Email newsletter This includes the following details: email address, first name and surname, and, where applicable, your preference as to whether you would like to receive the newsletter with content for women or for men. WhatsApp newsletter This includes the following details: WhatsApp username, telephone number. | Newsletter subscribers. | Provision of this information is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide this information. If you do not provide this data, we will be unable to send you the newsletter. | We will store this data for as long as you remain subscribed to our newsletter. We also store this data for evidential purposes in connection with the potential assertion, exercise or defence of legal claims, as well as for a transitional period of three years from the end of the year in which you unsubscribed, and in the event of any legal disputes, until such disputes are resolved. |
| Newsletter opt-in data. | Log data generated automatically for technical reasons when you subscribe to or unsubscribe from the newsletter. This includes the date and time of newsletter subscription, the date and time the subscription notification was sent as part of the double opt-in process, the date and time the subscription was confirmed as part of the double opt-in process, as well as the IP address (email newsletter) of the device used for confirmation or the telephone number (WhatsApp newsletter), the date and time of any unsubscription from the newsletter. | Newsletter subscribers. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide the data, we will be unable to provide you with the newsletter. | We store this data for as long as you remain subscribed to our newsletter. We also store this data for evidential purposes in connection with the assertion, exercise or defence of legal claims, and for a transitional period of three years from the end of the year in which you unsubscribed, and in the event of any legal disputes, until such disputes are resolved. |
| Market research data | Information that we collect as part of customer surveys for market research purposes, in order to analyse, in pseudonymised form, in particular our customers’ satisfaction and to improve the content of our offering. | Newsletter subscribers. | The provision of data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to carry out surveys and analyses for market research purposes. | We store this data in pseudonymised form for a maximum of 38 months. We also store this data in anonymised form beyond this period in order to analyse it for internal statistical purposes. |
| Pushnotification data | Data generated for technical reasons when registering for and activating push notifications. This includes the device type, operating system, and the date and time of access, as well as the device-specific push token (a unique identifier for your mobile device used to deliver push notifications via Bloomreach). Log data generated for technical reasons when push notifications are enabled or disabled, such as the date and time when push notifications were enabled or disabled in our app. | Push notification recipient. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide this data, we will be unable to send you push notifications | We store this data for as long as you have our push notifications enabled. We also store this data for evidential purposes to enable us to assert, exercise or defend legal claims, and for a transitional period of three years from the end of the year in which you unsubscribed, and in the event of any legal disputes, until such disputes are resolved. |
Details regarding the processing of personal data
| Purpose of the processing of personal data | Categories of personal data we process | Automated decision-making | Legal grounds and legitimate interests | Recipient |
|---|---|---|---|---|
| Provision of the form for subscribing to and unsubscribing from our newsletter on the website or app: For this purpose, newsletter form HTTP data is temporarily processed on our web server or by our WhatsApp provider. | HTTP data from the newsletter form. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to provide the website content accessed by the user. | Hosting providers, email newsletter providers, WhatsApp providers, system and service email providers. |
| Provision of the form for subscribing to our newsletter via social media. | Newsletter form HTTP data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to provide the content accessed by the user on social media platforms. | Transmission service providers, email newsletter providers, system and service email providers. |
| Ensuring the security of the IT infrastructure used to provide the form, in particular to detect, rectify and document malfunctions (e.g. DDoS attacks) in a manner that preserves evidence: To this end, data is temporarily stored and analysed in log files on our web server or with our WhatsApp provider. | Newsletter form HTTP data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to ensure the security of the IT infrastructure used to provide the form, in particular to detect, rectify and document malfunctions (e.g. DDoS attacks) in a manner that preserves evidence. | Hosting providers, email newsletter providers, WhatsApp providers, system and service email providers. |
| ‘Double opt-in’ procedure to confirm subscription to the email newsletter: To this end, we send an email message requesting confirmation to the email address provided during registration. A subscription only becomes effective once the subscriber has confirmed their email address by clicking on the confirmation link contained in the email. | Newsletter subscription data, newsletter opt-in data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is the legally compliant documentation of your consent to receive the newsletter. | System and email service providers |
| Sending the newsletter to the email address (email newsletter) or telephone number (WhatsApp newsletter) provided by the newsletter subscriber, or sending push notifications to the app user’s mobile device (push notifications). The newsletter and push notifications contain information about the products and services of Marc O’Polo Einzelhandels GmbH (e.g. clothing, shoes & accessories, bags, Junior, Living or the MARC O’POLO COMMUNITY programme , including cross-channel services), including information on current product trends, special events, invitations to take part in customer surveys, special offers or competitions. We use your name to address you personally and to tailor gender-specific content in our email newsletter and push notifications. We can tailor the content of the newsletter and push notifications to you individually (where we have such data) based on your orders in our online shop (🡪 Section C) or your membership of the MARC O’POLO COMMUNITY(🡪 Section E) (e.g. based on your orders via your member account, your purchase history or your bonus points balance). If, in addition to your newsletter subscription, you have also given your consent to ‘personalisation’ (or at least consent to personalisation via ‘Emarsys’) via our privacy and cookie settings (🡪 Section B.IV)): we will expand the newsletter (email and WhatsApp) to include further personalised content (e.g. regarding products you have added to your basket or which we recommend based on the product category you last clicked on). we will send you a newsletter (via email and WhatsApp) about products that you have added to your basket but subsequently did not order (a so-called ‘abandoned basket’ email). WhatsApp newsletter: When you sign up for the newsletter via WhatsApp, we will add your telephone number to the details we hold for your member account, provided you supply us with the email address you also use for your member account so that we can link the two. The phone number is linked via the optional entry of this email address, which we request in the chat. If the link to your member account is successful, we will inform you of this both in the WhatsApp chat and by email, and the information from your MARC O’POLO COMMUNITY membership (🡪 Section E) will then be used to personalise the WhatsApp newsletter. | Newsletter subscription data, newsletter opt-in data, push notification data. We use Emarsys profile data for personalisation. (🡪Section B.IV) Order data (--> C.1) This data is stored in your member account (🡪Section E.1). | No automated decision-making takes place. | Article 6(1)(a) of the General Data Protection Regulation (consent). If you did not consent to the personalisation of newsletter content when you subscribed to the newsletter, personalisation takes place on the basis of Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is to tailor the newsletter to your interests. (However, personalisation based on your browsing behaviour on our website, as described here, will only take place if, in addition to your newsletter subscription, you have also given your consent to ‘personalisation’ (or at least consent to personalisation via ‘Emarsys’) via our privacy and cookie settings (🡪 Section B.IV).) | Email newsletter provider, WhatsApp provider, lettershop, loyalty tool |
| Conducting customer surveys for market research purposes and pseudonymised analysis of market research data to further develop and improve the content of our offering. | Market research data. | No automated decision-making takes place. | Balancing of interests (Article 6(1)(f) of the General Data Protection Regulation). Our legitimate interest is the further development and improvement of our offering. | Survey agency. |
| Storage and processing for evidential purposes in connection with the potential assertion, exercise or defence of legal claims. | Newsletter subscription data, newsletter opt-in data. | No automated decision-making takes place. | Article 6(1)(f) of the General Data Protection Regulation (balancing of interests). Our legitimate interest is the assertion, exercise or defence of legal claims. | Email newsletter providers, WhatsApp providers, system and service email providers. |
Details about the recipients of personal data and the transfer of personal data to third countries and/or international organisations
| Recipient | Role of the recipient | Transfer to third countries and/or to international organisations | Adequacy decision or appropriate or adequate guarantees for transfers to third countries and/or international organisations |
|---|---|---|---|
| Hosting provider Current CRM hosting: Microsoft Ireland Operations Ltd (South County Business Park, Dublin, D18, Ireland) Hosting E-Shop currently: (currently: commercetools GmbH, Adams-Lehmann-Str. 44, 80797 Munich, Germany). | Data processor. | EU and USA. EU and USA. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Microsoft is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list In addition, the parties have entered into EU Standard Contractual Clauses in accordance with Article 46(5) of the General Data Protection Regulation. An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA and the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj No adequacy decision by the European Commission within the meaning of Article 45(3) of the General Data Protection Regulation is in place for transfers to Australia and Singapore. Commerctools GmbH has Standard Contractual Clauses (SCCs) in place which have been approved in accordance with Article 46 of the General Data Protection Regulation. |
| Email newsletter provider Emarsys eMarketing Systems AG Hans-Fischer-Straße 10 80339 Munich | Data processor. | EU and UK. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj |
| WhatsApp newsletter provider chatarmin.com GmbH Kaiserstraße 89/2/3 1070 Vienna, Austria | Data processor. | EU and USA. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj The transfer of personal data to the USA is carried out via subcontractors of Chatarmin Ad. In addition to the adequacy decision, the parties have entered into EU Standard Contractual Clauses in accordance with Article 46(5) of the General Data Protection Regulation. |
| System and service email providers (currently: Amazon SES, Amazon Web Services EMEA SARL, 5 rue Plaetis, Luxembourg, L-2338, Luxembourg). | Data processors | EU and USA. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Amazon is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list In addition, the parties have entered into EU Standard Contractual Clauses in accordance with Article 46(5) of the General Data Protection Regulation. |
| Survey agency (currently: SurveyMonkey Europe UC, 2nd Floor, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland) | Data processors. | EU and USA. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As SurveyMonkey is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list |
| Data transmission service providers from social networks Zapier Inc., 548 Market St #62411, San Francisco, California 94104, USA | Data processor. | USA. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Zapier is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: https://www.dataprivacyframework.gov/list In addition, the parties have entered into EU Standard Contractual Clauses in accordance with Article 46(5) of the General Data Protection Regulation. |
| Talon.One GmbH Wiener Straße 10, 10999 Berlin | Data processor. | EU and UK. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj |
| App push notification provider Bloomreach B.V. Fred. Roeskestraat 109, 1076 EE Amsterdam, Netherlands | Data processor | EU and USA. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj As Bloomreach is self-certified under the Data Privacy Framework, this adequacy decision also applies to transfers to this recipient. Details on self-certification can be found here: |
E. Information on the processing of personal data of participants in the customer loyalty scheme
Information on the processing of personal data of participants in the customer loyalty scheme
We operate the MARC O’POLO COMMUNITY loyalty programme. In connection with the operation of the loyalty programme, we process participants’ personal data, in particular for
Provision of the web applications in the online shop, where participants can provide their data to register for the loyalty programme,
to carry out the double opt-in procedure,
to operate a customer database,
to provide the loyalty programme services described in Part C of the Terms and Conditions and on the website,
to carry out customer surveys,
to send promotional content by post, to communicate about the programme by post, WhatsApp, push notifications, email or telephone,
to ensure IT security in the online shop, and
for evidential purposes or to comply with statutory retention obligations.
Provided you have given your consent, we also process your data to send personalised promotional content via the communication channels you have selected, to carry out a personalised analysis of your affinity with MARC O’POLO products, and to display personalised banner adverts.
The loyalty programme includes high-street stores operated by us or by our retail partners (participating high-street stores hereinafter collectively referred to as ‘High-Street Stores’). An overview of the current participating physical stores can be viewed in our Store Finder at http://www.qolzirvaxune.site/stores. There, you can view the nearest stores to a specified location or postcode. We mark the physical stores participating in the loyalty programme with graphic icons in the overview of your search results in the Store Finder. In addition, the country-specific shops operated by us take part in the loyalty programme; these can be accessed via the website (for Germany, for example, http://www.qolzirvaxune.site/de-de/ ) or via the terminals in the physical stores (the version of the country-specific shop accessible via the terminals in the physical stores is referred to below as the ‘store version’). An overview of the individual country shops can be found in Part A, Section 1.1 of our Terms and Conditions. In the following, the physical shops and the respective country shop, including the ‘Store Version’, are collectively referred to as ‘Participating Shops’.
Below you will find detailed information on this:
Information about the personal data we process
| Categories of personal data we process | Personal data in the categories | Sources of data | Obligation to make the data available | Duration of storage |
|---|---|---|---|---|
| Customer master data | Mandatory data that you provide when registering for the loyalty programme: title, first name, surname, date of birth, postal address, email address, password. When registering in a physical store: the store through which you registered. | Participant in the loyalty programme. | Providing your customer details is required to take part in the loyalty programme. Failure to provide this mandatory information means that you will not be able to take part in the loyalty programme. | We will store this data for as long as you remain registered with the loyalty programme. We also store this data for evidential purposes in connection with the assertion, exercise or defence of legal claims, and for a transitional period of one year from the end of the year in which you deregistered, and in the event of any legal disputes, until such disputes are resolved. |
| We will save the high-street store where you registered for the loyalty programme as your ‘favourite store’ in your customer account. Based on your postal address, we also identify the physical store and the nearest factory outlet to your place of residence and store this information in our member database. In addition, we assign each participant in the loyalty programme a personal membership number and a referral ID for referring friends. | Generated automatically. | - | We will store this data for as long as you remain registered with the loyalty programme. We also store this data for evidential purposes in connection with the assertion, exercise or defence of legal claims, and for a transitional period of one year from the end of the year in which you deregistered, and in the event of any legal disputes, until such disputes are resolved. | |
| Registration log data | Log data that we collect when you register for the loyalty programme. This includes: country, language used and date of your registration, as well as the participating store where you completed the registration. | Generated automatically. | - | We store this data for as long as you remain registered with the loyalty programme. We also store this data for evidential purposes in connection with the assertion, exercise or defence of legal claims, and for a transitional period of four years from the end of the year in which you deregistered, and in the event of any legal disputes, until such disputes are resolved. |
| Participant details | Information provided by participants in their customer account or when placing orders in the country-specific shop. This includes your contact details (first name and surname), your telephone number, your date of birth, your email address, the delivery and billing addresses you have used, as well as your payment methods, your preferred communication channels and marketing content, your favourite store, whether you wish to collect points as part of the loyalty programme, and your wish list and boards (in the app only) that you have created in the country-specific shop. Information on points earned, start date of membership, member level achieved, and start date of the level. | Participants in the Customer Loyalty Scheme. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide the data, we will be unable to make certain functions of your customer account available and will be unable to personalise our promotional content based on your participant details. | We store this data for as long as you remain registered with the loyalty programme. We also store this data for evidential purposes in connection with the assertion, exercise or defence of legal claims, and for a transitional period of three years from the end of the year in which you opted out, and in the event of any legal disputes, until such disputes are resolved. We also retain this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the type of documentation, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| Identification data for new customer acquisition | When participating in the ‘Refer a Friend’ programme, an identification ID is automatically generated. This ID tracks which friends have been referred by a customer. The following are also recorded: time of registration, referrer ID | Generated automatically | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to display the website content in the language you have selected. | We store this data for as long as you remain registered with the loyalty programme. |
| Purchase history | Information about your purchases, provided that you identify yourself as a participant in the loyalty programme when making a purchase in a high-street shop, or that you identify yourself as a participant in the country-specific shop by entering your login details. This includes details of the items purchased (item description, item number, quantity, size, colour, price, currency, payment method and number of points earned), as well as the location (online shop or country, town and branch for high-street shops), the time of the respective purchase and the delivery status. | Participating stores | - | We store this data for as long as you remain registered with the loyalty programme. We also store this data in anonymised form so that we can analyse it for internal statistical purposes. |
| Article data | Information about your choice of products, which we require to process the extended ordering and reservation options described in the Terms and Conditions. This includes information about the item you have selected (item number, colour, size, price) and the transaction number. | Generated independently. | - | We store this data as part of your purchase history for as long as you remain registered with the loyalty programme. We also store this data in anonymised form so that we can analyse it for internal statistical purposes. |
| Customer service enquiry data | Information that you provide to us in your enquiries to customer service by telephone or via the online contact form, e.g. the subject and background of your enquiry. | Participant in the loyalty programme. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide this data. If you do not provide this data, we will be unable to personalise our promotional content and shopping advice based on this data. | We store this data for a maximum of 12 months. Your data may be stored outside your customer account for longer than 12 months. (Section F) We also store this data for evidential purposes to enable us to assert, exercise or defend legal claims, and furthermore for a transitional period of four years from the end of the year in which you unsubscribed, and in the event of any legal disputes, until such disputes are resolved. |
| HTTP data | Log data generated automatically for technical reasons when you access the online shop via the Hypertext Transfer Protocol (HTTP): IP address, type and version of your internet browser, operating system used, the page accessed, the previously visited page (referrer URL), date and time of access. | Participant in the loyalty programme. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to make the requested website content available. | Data is stored in server log files in a form that allows the identification of the data subjects for a maximum period of 7 days, unless a security-related incident occurs (e.g. a DDoS attack). In the event of a security-related incident, server log files are stored until the security-related incident has been resolved and fully investigated. |
| Service usage data | Information regarding the nature and scope of the services you have used as part of the loyalty programme, in particular the extended ordering and booking options you have utilised and the vouchers you have redeemed. | Generated automatically | - | We store this data for as long as you remain registered with the loyalty programme. |
| Segment profile data | Assignment to participant segments, which we determine by analysing customer master data, participation details, purchase history, customer service enquiry data, and data that we collect with your consent via the personalisation tools Emarsys and Bloomreach ( → B.IV), and service usage data. | Generated independently. | - | We store this data for as long as you remain registered with the loyalty programme |
| Market research data | Information that we collect as part of customer surveys for market research purposes, in order to analyse, in pseudonymised form, in particular the satisfaction of our participants and to improve the content of our programme. | Participants in the Customer Loyalty Scheme. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to carry out surveys and analyses for market research purposes. | We store this data in pseudonymised form for a maximum of 38 months. We also store this data in anonymised form in order to analyse it for internal statistical purposes. |
| Advert management data | Information regarding any consent you have given for advertising, as well as any objections you may have raised to advertising. This includes the subject matter, date and time of the consent, the IP address of the device used to give consent, and the subject matter, date and time of any withdrawal of consent or objection to the processing of personal data for advertising purposes. | Participants in the Customer Loyalty Scheme. | The provision of data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide the data, we will be unable to take your consents or your objections to marketing into account. | We store this data for as long as consent remains in force or, where we carry out marketing activities without consent, for as long as we do so on the basis of the information provided to you regarding such marketing. We also store this data for evidential purposes in order to assert, exercise or defend legal claims, and for a transitional period of three years from the end of the year in which you withdrew your consent or we ceased the relevant marketing activity, and, in the event of any legal disputes, until such disputes are resolved. |
| Event booking details | Information relating to registration for an event organised by Marc O’Polo. This includes first name, surname, customer number, email address for further notifications and consent to the terms and conditions of booking and participation. | Participant in the loyalty programme. | Provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If you do not provide this data, you will not be able to register for an event. | We store this data until the event follow-up is completed, 3 months after the event has taken place. |
Details about the processing of personal data
| Purpose of the processing of personal data | Categories of personal data we process | Automated decision-making | Legal grounds and legitimate interests | Recipient |
|---|---|---|---|---|
| Provision of the web applications in the online shop, where you can provide us with your data to register for the loyalty programme. | HTTP data, customer master data, login log data. | No automated decision-making takes place. | Balancing of interests (Article 6(1)(f) of the General Data Protection Regulation). Our legitimate interest is the provision of the website content accessed by the participant. | Hosting service providers, online shop developers |
| Operation of a customer database in which we maintain and keep up to date customer master data and participant details. | Customer master data, participant details. | No automated decision-making takes place. | Balancing of interests (Article 6(1)(f) of the General Data Protection Regulation). Our legitimate interest is the operation of a well-organised customer database as the basis for the optimal management of customer data. | Hosting service provider, lettershop. |
| Provision of extended ordering and reservation options. As part of the reservation and collection options for items described in Part C, sections 2.4.1 and 2.4.2 of the Terms and Conditions, which you can access via one of our country shops, we will forward the item details required for holding the items (item number, colour, size, transaction number, item price) as well as the customer master data required for your identification and notification to the high-street shop, which will hold your requested item(s) for you. We will then inform you of the successful holding of the items by email. If you make use of the option described in Part C, Section 2.4.4 of the Terms and Conditions to place online orders in one of our country-specific shops via a device in the physical shops, staff in the physical shops may view your customer master data and subscriber details stored in your customer account in order to assist you with the ordering process and/or to log into your customer account. | Product data, customer master data, subscriber details. | No automated decision-making takes place. | Performance of a contract (Article 6(1)(b) of the General Data Protection Regulation). | Physical Stores. |
| Provision of the customer account functions and a convenient ordering process in the country-specific shop. We use the email address and password you provided during registration as your login details for your customer account. In your customer account, you can easily manage the customer details, subscriber information, marketing preferences and your wish list that you have provided. If you are logged into your customer account whilst placing an order in the country-specific shop, the information requested during the ordering process (e.g. the billing address) will be automatically pre-filled with the data stored in the customer database to make the ordering process even more convenient for you. Based on your purchase history, we provide you with an overview of your previous purchases in the participating stores within your customer account and display the processing and delivery status for orders placed in the Country-Shop. | Customer master data, participant details, purchase history, HTTP data, payment data. | No automated decision-making takes place. | Performance of a contract (Article 6(1)(b) of the General Data Protection Regulation). | Hosting service providers, online shop developers. |
| Recording of purchase history in the participating stores in order to calculate your respective points balance for the issuance of vouchers on this basis and to display it in your customer account. | Purchase history, customer master data. | No automated decision-making takes place. | Performance of a contract (Article 6(1)(b) of the General Data Protection Regulation). | Participating stores. |
| Calculation of your current points balance. Sending reminders regarding the redemption of points, level upgrades, level downgrades and the possible expiry of points by post, WhatsApp, push notifications or email. | Customer master data, purchase history. | No automated decision-making takes place. | Performance of a contract (point (b) of Article 6(1) GDPR). | Mail service provider, Lettershop, communication agency. |
| Participation in the Refer-a-Friend Program. Members can invite friends to join the Marc O’Polo COMMUNITY via a personalized registration link. If their friends register and make a purchase, the referring member receives a bonus. | Identification Data for New Customer Acquisition | No automated decision-making takes place. | Balancing of Interests (Article 6(1)(f) of the General Data Protection Regulation). Our legitimate interest is to recruit new customers. | Loyalty Tool, CRM |
| Provision of a customer helpline where you can enquire about your current points balance and other information, such as details regarding your membership, special events and promotions, or new collections. In order to provide you with the best possible personalised advice, customer helpline staff may access your data stored in the customer database | All data described in section E.1. | No automated decision-making takes place. | Performance of a contract (Article 6(1)(b) of the General Data Protection Regulation). | Customer service provider. |
| Sending information material on the components of the loyalty programme, as well as relevant, personalised advertising for our own offers (e.g. information about MARC O’POLO, product information, newsletters, invitations to take part in customer surveys, and exclusive offers or invitations to competitions, events and promotions organised by participating stores) by post. For this purpose, we use the postal address you provided when registering for the loyalty programme or which you have saved in your customer account as your billing address. We use the title and your name provided during registration to address you personally and to tailor gender-specific content in our promotional materials. We use the date of birth you have provided to send you personalised birthday greetings and information tailored to your age. We use the store where you registered, stores located near the address you may have provided, or the details of your favourite store in your customer account to send you invitations to store-related events and promotions. We use your participant details, purchase history, service usage data and segment profile data to provide you with content tailored to your personal preferences. | Customer master data, segment profile data, Advert management data. | No automated decision-making takes place. | Balance of interests (point (f) of Article 6(1) GDPR). We have a legitimate interest in using the postal address for direct marketing. | Mail service provider, lettershop, communication agency. |
| Provision of information by post, email, WhatsApp, push notifications, in-app messages or by telephone, insofar as this is necessary for the operation of the loyalty programme or the services provided in this context (hereinafter collectively referred to as ‘programme communications’). Programme communications include, in particular, emails, telephone calls or postal information confirming your registration, notifications regarding your points balance, expiry of points, level upgrades, level downgrades or information regarding the administrative processing of your purchases or the services you have used, such as notification of the arrival of an order or reservation at a high street shop, the resolution of complaints or till errors, information on the tailor’s alteration service or the arrangement of exclusive shopping appointments. | Customer master data, participant details, product data. | No automated decision-making takes place. | Performance of a contract (Article 6(1)(b) of the General Data Protection Regulation). | Physical Stores, system and service e-mail provider, lettershop, mail service provider, communication agency. |
| To carry out customer surveys for market research purposes and pseudonymised analyses of market research data in order to develop and improve the content and features of the Customer Loyalty Scheme. | Market research data. | No automated decision-making takes place. | Balance of interests (point (f) of Article 6(1) GDPR). We have a legitimate interest in the development and improvement of the Customer Loyalty Scheme. | Survey agency, hosting service provider, online store developer. |
| To guarantee the security of the IT infrastructure used to provide the online store, especially to identify, combat and document disruptions in a legally sound manner (e.g. DDoS attacks). Data are stored temporarily in log files on our web server and evaluated for this purpose. | HTTP data. | No automated decision-making takes place. | Point (f) of Article 6(1) GDPR (balance of interests). We have a legitimate interest in guaranteeing the security of the IT infrastructure used to provide the online store, especially so as to identify, combat and document disruptions in a legally sound manner (e.g. DDoS attacks). | Hosting service provider, online store developer. |
| Storage to serve as evidence for the purposes of filing, exercising or defending against legal claims. | Customer master data, e-mail opt-in data, registration log data, participant details, customer service enquiry data, Advert management data. | No automated decision-making takes place. | Balance of interests (point (f) of Article 6(1) GDPR). We have a legitimate interest in filing, exercising or defending against legal claims. | Customer service provider |
| Accurate accounting and storage in order to comply with contractual and legal storage obligations, especially under tax and commercial law. | Customer master data, participant details. | No automated decision-making takes place. | To comply with a legal obligation (point (c) of Article 6(1) GDPR), especially to meet the legal requirements of proper accounting and legal storage obligations, especially under tax and commercial law. Additionally, the legal ground is the performance of a contract to which the data subject is party (point (b) of Article 6(1) GDPR). | Customer service provider |
| Participant management for events; sending event-related information by email. | Customer master data, participant details. | No automated decision-making takes place. | Consent | Hosting service provider Event management tool |
| Purpose of the processing of personal data | Categories of personal data we process | Automated decision-making | Legal grounds and legitimate interests | Recipient |
|---|---|---|---|---|
| To send information about the elements of the Customer Loyalty Scheme as well as relevant, personalised adverts for our own offers (e.g. information about MARC O‘POLO, product information, newsletters, invitations to take part in customer surveys, exclusive offers or invitations to take part in competitions, events and offers from participating stores) through the communication channels selected by the participant (post, e-mail, SMS, WhatsApp, Push message, in-app message or by phone). For this purpose, we use the current information we have stored in our customer database. You can select or modify the channels of communication at any time in your customer account. We use the title and name you provided when you registered in order to address you personally and show gender-specific content in our promotional material. We use your date of birth to send you personalised birthday wishes and information tailored to your age. We use the store in which you registered, stores near to the address you provided (if you have done so) or your favourite store in your customer account to send you invitations to events and offers in connection with the store. We use your participant details, purchase history, online user profile data, service usage data and segment profile data to send you content tailored to your personal preferences. Additionally, we shall send you reminder e-mails if you do not complete orders in the online store or there are still articles on your wish list in the customer account. | Customer master data, participant details, online user profile data, purchase history, service usage data, segment profile data. | No automated decision-making takes place. | Consent (point (a) of Article 6(1) GDPR). | E-mail service provider, survey agency, lettershop, mail service provider, communication agency. |
| Personalised analysis of participants’ affinity for MARC O’POLO products within the loyalty programme, for the purposes of personalising and tailoring advertising content to individual needs. To this end, we use various analytical methods that enable us to personalise advertising content as effectively as possible and tailor it to your specific personal interests, which we derive from all the information stored in our customer database. To this end, we also analyse insights gained through the marketing and personalisation technologies from Emarsys and Bloomreach used on our website (--> Section B.IV). As part of this process, we also assign our customers to specific target groups, towards whom we direct our advertising campaigns. These include the following segment categories: Purchase activity (lead, new, active, inactive, lost), willingness to pay (zero, basic, full return, good, top, unknown), purchase frequency (zero order, single order, slow shopper, medium shopper, heavy shopper), discount affinity, channel preference, product preference, last purchase category. By personalising advertising content, we aim to ensure that you primarily receive information that we consider to be of particular interest to you. | All data from Section E.1, order and returns data (--> Section C.1). Emarsys and Bloomreach profile data (--> Section B.IV) | No automated decision-making takes place. | Consent (Article 6(1)(a) of the General Data Protection Regulation). | Survey agency. |
Details about the recipients of personal data and the transfer of personal data to third countries and/or international organisations
| Recipient | Role of the recipient | Transfer to third countries and/or to international organisations | Adequacy decision or appropriate or adequate guarantees for transfers to third countries and/or international organisations |
|---|---|---|---|
| Hosting service provider Current CRM hosting: Microsoft Ireland Operations Ltd (South County Business Park, Dublin, D18, Ireland) Current e-shop hosting: (currently: commercetools GmbH, Adams-Lehmann-Str. 44, 80797 Munich, Germany). | Data processors | EU and USA. EU, UK, USA, Australia, Singapore. | There is no adequacy decision by the European Commission within the meaning of Article 45(3) of the General Data Protection Regulation. Microsoft has Standard Contractual Clauses (SCCs) that have been approved in accordance with Article 46 of the General Data Protection Regulation. An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA and the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj No adequacy decision by the European Commission within the meaning of Article 45(3) of the General Data Protection Regulation is in place for transfers to Australia and Singapore. Commerctools GmbH has Standard Contractual Clauses (SCCs) which have been approved in accordance with Article 46 of the General Data Protection Regulation. |
| E-mail service provider (currently: Emarsys eMarketing Systems AG, Hans-Fischer-Str. 10, 80339 Munich, Germany). | Data processor. | EU and UK. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj |
| System and service e-mail provider (currently: Amazon SES, Amazon Web Services EMEA SARL, 5 rue Plaetis, Luxembourg, L-2338, Luxembourg) | Data processor. | EU and USA. | There is no adequacy decision by the European Commission within the meaning of Article 45(3) of the General Data Protection Regulation. Amazon has Standard Contractual Clauses (SCCs) that have been approved in accordance with Article 46 of the General Data Protection Regulation. |
| Physical Stores / participating stores (where these are operated by sales partners) An overview of our currently participating Physical Stores is available in our store finder at www.qolzirvaxune.site/stores. You can use the store finder to display the closest stores to a given location or post code. The Physical Stores which are participating in the Customer Loyalty Scheme have graphic icons next to them in the overview of your search results in the store finder. | Processors, where they assist with the services of the Customer Loyalty Scheme described in part C of the GTC and on the website, especially the extended ordering and reservation options described in section 2.4.1, 2.4.2 and 2.4.4 of part C of the GTC or Scheme Communication. The Physical Stores are the controllers with regard to the collection and transfer of your purchase history to us. | Germany (EU) | - |
| Survey agency (currently: SurveyMonkey Europe UC, 2nd Floor, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland) | Data processor. | Dublin (Ireland) – European Union (EU) | - |
| Customer service provider (currently: Ströer X GmbH, Ströer Allee 1, 50999 Cologne). | Data processor. | Germany (EU) | - |
| Mail service provider (currently: Deutsche Post AG (Charles-de-Gaulle-Str. 20, 53113 Bonn, Germany) and UPS, United Parcel Service (Deutschland S.à r.l. & Co. OHG, Görlitzer Str. 1, 41456 Neuss, Germany). | Controller | Germany (EU) | - |
| Lettershops (currently: optilyz GmbH, Neue Schönhauser Str. 19, 10178 Berlin) | Data processor. | Germany (EU) | - |
| Online store developer: MOBIZCORP EUROPE LTD. Viernheim office, August-Bebel-Strasse 26 68519 Viernheim Germany | Data processor. | Germany (EU) | - |
| E-mail sender: Emarsys eMarketing Systems AG, Hans-Fischer-Str. 10, 80339 Munich, Germany | Data processor. | EU and UK. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj |
| Hosting service provider for event management tool eveeno, Andreas Bothe, Ellenbogen 8, 91056 Erlangen | Data processor | European Union (EU) | - |
| Loyalty Tool: Talon.One GmbH Wiener Straße 10, 10999 Berlin | Data processor. | EU and UK. | An adequacy decision by the European Commission within the meaning of Art. 45 GDPR is in place for the transfer of personal data to the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj |
F. Information about the processing of personal data of users of our customer service
Information about the processing of personal data of users of our customer service
On the website and in the app, we offer you the option to get in touch with our customer service team via a contact form or a chat function. Furthermore, we offer you the option to speak to a member of our customer service team via our helpline or to contact our customer service team by email.
We process the information you provide to our customer service team in order to deal with your enquiry, for example, questions regarding an order. Where necessary, we also store this information for evidential purposes to assert, exercise or defend legal claims, or to comply with statutory retention obligations, in particular those under commercial and tax law. If you have verified your status as a participant in our loyalty programme, we also store this data for a period of 12 months from the resolution of the enquiry, so that we can take it into account in the event of any further enquiries.
Insofar as this is necessary to process your enquiry, we may also access further information that we may already hold in connection with your orders in our online shop (see Section C) or your participation in our loyalty programme (see Section E).
When using the contact forms or the chat function on the website or in the app , the browser or the app , certain information is sent to our website’s server for technical reasons, such as your IP address. We process this information to provide the contact forms/chats on the website and to ensure the security of the IT infrastructure used for this purpose.
To measure the quality of our customer service, we compile aggregated analyses of the nature of enquiries and the time taken to process each one. With your consent, we also record your telephone calls with our customer service team and analyse these recordings to improve our customer service.
You will find detailed information on this below:
Information about the personal data we process
| Categories of personal data we process | Personal data in the categories | Sources of data | Obligation to make the data available | Duration of storage |
|---|---|---|---|---|
| HTTP data. | Log data generated automatically for technical reasons when accessing contact forms or chat functions on the website and when using our native app via the Hypertext Transfer Protocol (Secure) (HTTP(S)). On the website: This includes your IP address, the type and version of your web browser, the operating system used, the page accessed, the previously visited page (referrer URL), and the date and time of access. In the app: These include your IP address, the type and version of the HTTP component used in the app, the operating system used or the operating system of the end device, the page accessed or the web address of a technical service (API endpoint) accessed by the app via which data is received or provided, the previously visited page (referrer URL), and the date and time of access. | User of the website or app. | The provision of this data is not required by law or contract, nor is it necessary for the conclusion of a contract. There is no obligation to provide the data. If the data is not provided, we will be unable to display the requested content on the website. | Data is stored in server log files in a form that allows the identification of the data subjects for a maximum period of 7 days, unless a security-related incident occurs (e.g. a DDoS attack). In the event of a security-related incident, server log files are stored until the security-related incident has been resolved and fully investigated. |
| E-mail data | Log data which are generated for technical reasons when e-mails are received. This includes the date and time of the e-mail, the e-mail address, IP addresses and information about the servers involved in the e-mail correspondence. | Users for e-mail correspondence | The provision of data is not required by law or by a contract and is not necessary for the conclusion of a contract. No obligation to make the data available exists. If you do not provide the data, you will be unable to contact us by e-mail. | Data are stored in server log files in a format which makes it possible to identify the data subjects for up to seven days unless a security incident occurs (e.g. a denial-of-service attack). If a security incident does occur, server log files shall be stored until the security incident has been overcome and fully investigated. |
| Enquiry data. | Data that you provide to us via contact forms on the website or app, via chat, by telephone or by email when making enquiries to our customer service team. This includes the information you provide to us via the relevant communication channel. In particular, this may include the following data: name, date of birth, address, telephone number, email address and the content of your enquiry. | Customer service users. | The provision of data is not required by law or by a contract and is not necessary for the conclusion of a contract. No obligation to make the data available exists. If you do not provide the data, we will be unable to process your enquiry. | Data will be stored until your enquiry has been resolved. If you have verified your status as a participant in our loyalty programme, we will also store the data for a maximum of 12 months as ‘customer service enquiry data’ (see Section E). We also store this data for evidential purposes in connection with the potential assertion, exercise or defence of legal claims for a transitional period of 12 months following the resolution of your enquiry and, in the event of any legal disputes, until such disputes are resolved. We also retain this data to the extent that statutory retention obligations exist, in particular under commercial and tax law. Depending on the nature of the documents, retention obligations under commercial and tax law may be six or ten years (Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)). |
| This includes our own documentation of your enquiry such as summaries of the communication between you and us, phone logs and, in the case of enquiries in writing (i.e. the contact form and e-mail), our assessment of the nature and urgency of the enquiry. | Generated independently. | - | ||
| Phone data | This includes log data such as your phone number and the duration of the call. | Customer hotline users. | The provision of data is not required by law or by a contract and is not necessary for the conclusion of a contract. No obligation to make the data available exists. If you do not provide the data, you will be unable to contact us by phone. | We shall store the data for as long as necessary in order to achieve the purposes described below. |
| Phone recording data | This includes the recording of the phone calls between you and our customer service as well as documentation of your consent and the transcript of the conversation which is automatically generated from the recordings | Customer hotline users. | The provision of data is not required by law or by a contract and is not necessary for the conclusion of a contract. No obligation to make the data available exists. If you do not provide the data, we cannot use the data to improve our customer service. | We shall store the data for as long as necessary in order to achieve the purposes described below. |
Details about the processing of personal data
| Purpose of the processing of personal data | Categories of personal data we process | Automated decision-making | Legal grounds and legitimate interests | Recipients |
|---|---|---|---|---|
| Provisionof our contact and chat forms on the website or app and receiving enquiries via these channels. For this purpose, HTTP data is processed temporarily on our web server. | HTTP data, Enquiry data. | No automated decision-making takes place. | Point (f) of Article 6(1) GDPR (balance of interests). We have a legitimate interest in providing the website content accessed by the user. | CRM service provider Also for the contact form: Hosting provider. |
| To guarantee the security of the IT infrastructure used to provide the form, especially to identify, combat and document disruptions in a legally sound manner (e.g. DDoS attacks). Data are stored temporarily in log files on our web server and evaluated for this purpose. | HTTP data. | No automated decision-making takes place. | Point (f) of Article 6(1) GDPR (balance of interests). We have a legitimate interest in guaranteeing the security of the IT infrastructure used to provide the form, especially so as to identify, combat and document disruptions in a legally sound manner (e.g. DDoS attacks). | Hosting provider. |
| To provide a customer hotline and receive enquiries by phone. Log data are processed temporarily on our systems for this purpose. | Phone data, Enquiry data. | No automated decision-making takes place. | Point (f) of Article 6(1) GDPR (balance of interests). We have a legitimate interest in providing a customer hotline so as to offer personal advice. | Customer service provider. |
| To provide an e-mail system in order to make it possible to contact our customer service and receive enquiries by e-mail. Log data are processed temporarily on our systems for this purpose. | E-mail data, Enquiry data. | No automated decision-making takes place. | Point (f) of Article 6(1) GDPR (balance of interests). We have a legitimate interest in providing an e-mail system in order to make it possible to contact our customer service. | E-mail service provider |
| To measure the quality of our customer service: We generate aggregated evaluations of the nature of an enquiry and of the time taken to process each one in order to determine how long it takes on average for our customer service staff to process each type of enquiry. These aggregated evaluations do not contain any personal data relating to our customers. | Phone data, enquiry data. | No automated decision-making takes place. | Point (f) of Article 6(1) GDPR (balance of interests). We have a legitimate interest in measuring the quality of our customer service. . | CRM service provider, customer service provider |
| To process your enquiry. If you are a verified customer, we can retrieve stored data concerning you in order to process the enquiry. For example, this might be your purchase history in order to process a return. In the case of written enquiries (i.e. the contact form and e-mail), we perform an automated evaluation of the nature and urgency of enquiries in order to prioritise the order in which we process them. For this reason, our system identifies certain key words in the enquiry in order to evaluate the nature of the enquiry (e.g. a question about an order or advice about a product) and its urgency on the basis of the ‘mood’ of the wording. | Enquiry data Depending on the enquiry in question, potentially also the following data concerning your orders, even if you check out as a guest: Contact details, Shipping data, Order data, Customer data, Transaction e-mail data, Order and return values, Advert management data (for more details, see section C.1) Depending on the enquiry in question, potentially also the following data concerning your participation in our Customer Loyalty Scheme: Customer master data, Participant details, Purchase history, Article data, Customer service enquiry data, Service usage data, Segment profile data, Advert management data (for more details, see section E.1) | No automated decision-making takes place. | Where your enquiry concerns a contract to which you are party or steps prior to entering into a contract: Point (b) of Article 6(1) GDPR (performance of a contract or in order to take steps prior to entering into a contract). Otherwise: Point (f) of Article 6(1) GDPR (balance of interests). In this case, we have a legitimate interest in processing your enquiry efficiently. | Customer service provider, CRM service provider, Loyalty Tool |
| To record and evaluate telephone calls in order to improve our customer service: With your consent, we record your phone calls with our customer service and automatically convert the audio recordings into transcripts. We evaluate these transcripts automatically – and in some cases manually – and use the findings to train our customer service employees. We do not process any personal data relating to our customers for such training. | Phone recording data | No automated decision-making takes place. | Point (a) of Article 6(1) GDPR (consent). | Customer service provider |
| Storage and processing to serve as evidence for the purposes of filing, exercising or defending against legal claims. | Enquiry data. | No automated decision-making takes place. | Point (f) of Article 6(1) GDPR (balance of interests). We have a legitimate interest in filing, exercising or defending against legal claims. | Customer service provider. |
| Storage of data in order to comply with statutory storage obligations, especially those imposed by tax or commercial law. Depending on the nature of the documents, we may be obliged to store the data for six or ten years in accordance with tax and commercial law (Section 147 AO and Section 257 HGB). | Enquiry data. | No automated decision-making takes place. | Point (c) of Article 6(1) GDPR (compliance with a legal obligation). | Customer service provider. |
Details about the recipients of personal data and the transfer of personal data to third countries and/or international organisations
| Recipient | Role of the recipient | Transfer to third countries and/or to international organisations | Adequacy decision or appropriate or adequate guarantees for transfers to third countries and/or international organisations |
|---|---|---|---|
| Hosting provider (currently: commercetools GmbH, Adams-Lehmann-Str. 44, 80797 Munich, Germany) | Processor. | EU, UK, USA, Australia, Singapore | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA and the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj There is no adequacy decision by the European Commission within the meaning of Article 45(3) of the General Data Protection Regulation for transfers to Australia and Singapore. Commerctools GmbH has Standard Contractual Clauses (SCCs) which have been approved in accordance with Article 46 of the General Data Protection Regulation. |
| CRM service provider (currently: Microsoft Ireland Operations Ltd, South County Business Park, Dublin, D18, Ireland) | Processor. | EU. | - |
| Customer service provider (currently: Ströer X GmbH, Ströer Allee 1, 50999 Cologne). | Processor. | EU. | - |
| E-mail service provider (currently: Emarsys eMarketing Systems AG, Hans-Fischer-Strasse 10, 80339 Munich, Germany) | Processor. | EU and UK. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj |
| Loyalty Tool: Talon.One GmbH Wiener Straße 10, 10999 Berlin | Data processor. | EU and UK. | An adequacy decision by the European Commission within the meaning of Art. 45 GDPR is in place for the transfer of personal data to the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj |
G. Information about the processing of personal data of participants in our competitions
Information about the processing of personal data of participants in our competitions
On our website, our app and, where applicable, via other channels (e.g. entry postcards), we occasionally offer the opportunity to take part in various competitions. We process the information you provide in the relevant entry forms (which may be pre-filled for our subscribers to reminder emails) for the purpose of running the relevant prize draw and awarding the relevant prizes in accordance with the relevant terms and conditions of participation, which you have accepted.
In addition, for some competitions, we offer you the option to sign up for reminder emails, through which we will inform you about our competitions, as explained in more detail in the relevant registration form. We process the information collected in this context to confirm your subscription and to provide the reminder emails.
We also store the information collected in connection with participation in prize draws or the subscription to reminder emails for evidential purposes, to enable us to assert, exercise or defend legal claims and, where applicable, to fulfil statutory retention obligations, in particular those under commercial and tax law.
When you take part in competitions or subscribe to reminder emails via our website or app (e.g. competition or registration forms), the browser used on your device or the app, for technical reasons, certain information is sent to our website’s server, such as your IP address. We process this information to make the forms available on the website or app. To ensure the security of the IT infrastructure used to operate the website, this information is also temporarily stored in a so-called web server log file. When using such forms on our website, you often also have the option to subscribe to our newsletter. More detailed information on the processing of personal data in connection with the newsletter can be found in Section D of this privacy policy.
Below you will find more detailed information on the processing of personal data in connection with taking part in competitions and signing up for reminder emails on our website or app:
Details about the processing of personal data
| Categories of personal data we process | Personal data in the categories | Sources of data | Obligation to make the data available | Duration of storage |
|---|---|---|---|---|
| Form HTTP data. | Log data generated automatically for technical reasons when forms are accessed to enter a competition and to sign up for competition reminder emails on the website, and when using our native app via the Hypertext Transfer Protocol (Secure) (HTTP(S)). On the website: This includes your IP address, the type and version of your web browser, the operating system used, the page accessed, the previously visited page (referrer URL), and the date and time of access. In the app: These include your IP address, the type and version of the HTTP component used in the app, the operating system used or the operating system of the end device, the page accessed or the web address of a technical service (API endpoint) accessed by the app via which data is received or provided, the previously visited page (referrer URL), and the date and time of the access. | Competition participants (only when they enter the competition using a form on our website, e.g. competition or registration forms). | The provision of data is not required by law or by a contract and is not necessary for the conclusion of a contract. No obligation to make the data available exists. If you do not provide the data, we will be unable to provide the website content you wish to access. | Data are stored in server log files in a format which makes it possible to identify the data subjects for up to six weeks unless a security incident occurs (e.g. a denial-of-service attack). If a security incident does occur, server log files shall be stored until the security incident has been overcome and fully investigated. |
| Participant form data. | Data you share with us in the participation form for a competition. This includes the information you provide to us in each participation form and we need in order to execute the competition in accordance with the terms and conditions of participation that you have accepted. The specific data that we ask for depend on the competition in which you are participating. We normally collect your name and e-mail address at the very least. We also collect other data depending on the type of competition, and will provide you with information about such data in each participation form. | Competition participants. | You must provide these data in order to participate in a competition. No obligation to make the data available exists. If you do not provide the data, you will be unable to participate in the competition. | Data shall be stored until the end of the competition in question. Additionally, we shall store these data as evidence for the purposes of filing, exercising or defending against legal claims for a transition period of three years from the end of the year in which you shared the data with us or until the end of any ongoing legal disputes. Furthermore, we shall store the data for longer if we are subject to a statutory storage obligation, especially under tax or commercial law. Depending on the nature of the documents, we may be obliged to store the data for six or ten years in accordance with tax and commercial law (Section 147 AO and Section 257 HGB). |
| Winner data. | Additional data you share with us because you have won a competition. This includes information we need in order to award the prize such as your full name, address, clothes or shoe size and whether or not you have accepted the prize. | Winners of a competition. | The provision of data is not required by law or by a contract and is not necessary for the conclusion of a contract. No obligation to make the data available exists. If you do not provide the data, we will be unable to deliver your prize. | Data shall be stored until the end of the competition in question. Additionally, we shall store these data as evidence for the purposes of filing, exercising or defending against legal claims for a transition period of three years from the end of the year in which you shared the data with us or until the end of any ongoing legal disputes. Furthermore, we shall store the data for longer if we are subject to a statutory storage obligation, especially under tax or commercial law. Depending on the nature of the documents, we may be obliged to store the data for six or ten years in accordance with tax and commercial law (Section 147 AO and Section 257 HGB). |
| Prize data. | Data about the prizes won by each winner. This includes information about what winner won which prize. | Generated independently. | - | Data shall be stored until the end of the competition in question. Additionally, we shall store these data as evidence for the purposes of filing, exercising or defending against legal claims for a transition period of three years from the end of the year in which you shared the data with us or until the end of any ongoing legal disputes. Furthermore, we shall store the data for longer if we are subject to a statutory storage obligation, especially under tax or commercial law. Depending on the nature of the documents, we may be obliged to store the data for six or ten years in accordance with tax and commercial law (Section 147 AO and Section 257 HGB). |
| Reminder e-mail subscription data. | Data we collect when you sign up for any reminder e-mails about our competitions. This includes the following information: E-mail address, title, first name, surname. | Subscribers to reminder e-mails. | The provision of data is not required by law or by a contract and is not necessary for the conclusion of a contract. No obligation to make the data available exists. If you do not provide the mandatory information, we will be unable to send you reminder e-mails. | We shall store these data for the period of time indicated in the subscription form for the reminder e-mail in question. This period of time normally matches the period of time indicated in the terms and conditions of participation for the competition in question. We shall store these data as evidence for the purposes of filing, exercising or defending against legal claims for a transition period of three years from the end of the year in which you left the scheme or in which the period of reminder e-mails ended, or until the end of any ongoing legal disputes. |
| Reminder e-mail opt-in data. | Log data which are generated for technical reasons when you subscribe to and unsubscribe from reminder e-mails. This includes the date and time of your subscription to the reminder e-mail, the date and time the subscription e-mail was sent as part of the double opt-in procedure, the date and time your subscription was confirmed as part of the double opt-in procedure, the IP address of the device used to confirm the subscription and the date and time you unsubscribe from the reminder e-mails, if applicable. | Subscribers to reminder e-mails. | The provision of data is not required by law or by a contract and is not necessary for the conclusion of a contract. No obligation to make the data available exists. If you do not provide the data, we will be unable to send you any reminder e-mails. | We shall store these data for the period of time indicated in the subscription form for the reminder e-mail in question. This period of time normally matches the period of time indicated in the terms and conditions of participation for the competition in question. We shall store these data as evidence for the purposes of filing, exercising or defending against legal claims for a transition period of three years from the end of the year in which you left the scheme or in which the period of reminder e-mails ended, or until the end of any ongoing legal disputes. |
Details about the processing of personal data
| Purpose of the processing of personal data | Categories of personal data we process | Automated decision-making | Legal grounds and legitimate interests | Recipient |
|---|---|---|---|---|
| Only when entering a competition via an online form on our website or app, e.g. competition or registration forms: Submission of the (where applicable, pre-filled) forms for entering a competition and the form for signing up for reminder emails on the website or app: For this purpose, data is processed temporarily on our web server. If you have signed up for a reminder email and accessed the entry form via the entry link in your reminder email, we will pre-fill the entry form with the data you provided when signing up for the reminder email. To this end, we append a randomly generated (hash) value to the entry links, which enables us to link this to your consent-based email subscription data. You can change this data at any time before submitting the entry form. | Form HTTP data, potentially reminder e-mail subscription data. | No automated decision-making takes place. | Point (f) of Article 6(1) GDPR (balance of interests). We have a legitimate interest in providing the website content accessed by the user. | Hosting provider. |
| Only when entering a competition via an online form on our website or app, e.g. competition or registration forms: Ensuring the security of the IT infrastructure used to provide the forms for entering a competition and for signing up for reminder emails, in particular to detect, rectify and document malfunctions (e.g. DDoS attacks) in a manner that preserves evidence: To this end, data is temporarily stored in log files on our web server and analysed. | Form HTTP data, | No automated decision-making takes place. | Point (f) of Article 6(1) GDPR (balance of interests). We have a legitimate interest in guaranteeing the security of the IT infrastructure used to provide the forms, especially so as to identify, combat and document disruptions in a legally sound manner (e.g. DDoS attacks). | Hosting provider. |
| To register for each competition and determine the winners of each competition in accordance with the terms and conditions of participation that you have accepted. | Participant form data, prize data. | Winners are drawn at random. The prize draw is performed automatically with no human intervention. | Point (b) of Article 6(1) GDPR (performance of a contract or in order to take steps prior to entering into a contract). | Hosting provider, WhatsApp provider. |
| To notify winners and provide the prizes in accordance with the terms and conditions of participation that you have accepted. | Participant form data, winner data, prize data. | No automated decision-making takes place. | Point (b) of Article 6(1) GDPR (performance of a contract or in order to take steps prior to entering into a contract). | Potentially the delivery company. |
| Double opt-in procedure to confirm a subscription to reminder e-mails: For this purpose, we send an e-mail asking you to confirm the e-mail address you provided when you registered. A subscription will only be activated when the subscriber confirms the e-mail address by clicking on the confirmation link in the e-mail. | Reminder e-mail subscription data, reminder e-mail opt-in data. | No automated decision-making takes place. | Point (f) of Article 6(1) GDPR (balance of interests). We have a legitimate interest in documenting your consent to receive reminder e-mails for legal reasons. | Hosting provider. |
| To send reminder e-mails to people who have signed up for reminder e-mails. We use the optional information you provide when you register in order to address you by name in the reminder e-mails. | Reminder e-mail subscription data, reminder e-mail opt-in data. | No automated decision-making takes place. | Point (a) of Article 6(1) GDPR (consent). | Hosting provider. |
| Storage and processing to serve as evidence for the purposes of filing, exercising or defending against legal claims. | Participant form data, winner data, prize data, reminder e-mail subscription data, reminder e-mail opt-in data. | No automated decision-making takes place. | Balance of interests (point (f) of Article 6(1) GDPR). We have a legitimate interest in filing, exercising or defending against legal claims. | - |
| Storage of data in order to comply with statutory storage obligations, especially those imposed by tax or commercial law. Depending on the nature of the documents, we may be obliged to store the data for six or ten years in accordance with tax and commercial law (Section 147 AO and Section 257 HGB). | Participant form data, winner data, prize data. | No automated decision-making takes place. | Compliance with a legal obligation (point (c) of Article 6(1) GDPR). | - |
Details about the recipients of personal data and the transfer of personal data to third countries and/or international organisations
| Recipient | Role of the recipient | Headquarters of the recipient | Adequacy decision or appropriate or adequate guarantees for transfers to third countries and/or international organisations |
|---|---|---|---|
| Hosting provider (currently: commercetools GmbH, Adams-Lehmann-Str. 44, 80797 Munich, Germany) | Data processor. | EU, UK, USA, Australia, Singapore | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA and the UK. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj There is no adequacy decision by the European Commission within the meaning of Article 45(3) of the General Data Protection Regulation for transfers to Australia and Singapore. Commerctools GmbH has Standard Contractual Clauses (SCCs) which have been approved in accordance with Article 46 of the General Data Protection Regulation. |
| WhatsApp provider chatarmin.com GmbH Kaiserstraße 89/2/3 1070 Vienna, Austria | Data processor. | EU and USA. | An adequacy decision by the European Commission within the meaning of Article 45 of the GDPR is in place for the transfer of personal data to the USA. The adequacy decision is available here: https://eur-lex.europa.eu/eli/dec_impl/2023/1795/oj The transfer of personal data to the USA is carried out via subcontractors of chatarmin. In addition to the adequacy decision, the parties have entered into EU Standard Contractual Clauses in accordance with Article 46(5) of the General Data Protection Regulation. |
| Delivery company Arvato distribution GmbH, Carl-Bertelsmann-Str. 32, 33330 Gütersloh, Germany | Processor. | EU | - |
| System and service e-mail provider (currently: Amazon SES, Amazon Web Services EMEA SARL, 5 rue Plaetis, Luxembourg, L-2338, Luxembourg). | Processor. | EU and USA. | There is no adequacy decision by the European Commission within the meaning of Article 45(3) of the General Data Protection Regulation. Amazon has Standard Contractual Clauses (SCCs) that have been approved in accordance with Article 46 of the General Data Protection Regulation. |
H. Information about the use of cookies and similar technologies
Information about the use of cookies and similar technologies
In connection with our website or app and as well as the services provided on the website or app, we use cookies and similar tracking technologies. In doing so, we utilise the processing and storage functions of the browser on your device or the app and collect information from the browser’s storage on your device or the app. Detailed information on this is provided below.
General information on cookies and similar technologies (app)
Cookies on our website: Cookies are small text files containing information that may be placed on the user’s device via the browser when they visit a website. When the website is visited again using the same device, the cookie and the information stored within it can be retrieved.
Similar technologies in our app (SDKs and local storage):
For technical reasons, our mobile app does not use traditional web cookies. Instead, we use similar technologies to fulfil the same purposes (e.g. statistical measurements, error analysis, optimised user guidance and marketing):
Local app storage (Shared Preferences / NSUserDefaults): These are local, protected storage areas within your smartphone’s operating system (Android/iOS) in which the app stores small fragments of data (e.g. your login status, language settings or a pseudonymous ID) locally. Similar to cookies, this data remains stored on your device either temporarily or permanently until the app is uninstalled or the app storage is manually cleared.
Software Development Kits (SDKs): An SDK is a programming interface provided by the relevant third-party provider (e.g. Google, Bloomreach, AppsFlyer) that is integrated directly into our app’s code. It enables the app to read pseudonymised interaction data and device-specific identifiers (such as the advertising IDs ‘IDFA’ for iOS or ‘GAID’ for Android) and to transmit them to the relevant provider for analysis or marketing purposes.
Legally, these app technologies are subject to the same data protection requirements as web cookies (in particular Section 25 of the TDDDG). Unless they are technically absolutely necessary for the app to function, we use them only with your express consent (opt-in).
When you use the app, log data is generated via the Hypertext Transfer Protocol (Secure) (HTTP(S)). The following data is processed: your device (model and IMEI), operating system, the (sub-)page accessed, the date and time of access, country (based on IP address), and technical usage data (e.g. which products were viewed, shopping basket information, completion of a purchase). So-called IP anonymisation is enabled in the app. This means that the IP address, which is transmitted for technical reasons,isanonymised prior to storage by truncating the IP address (by deleting the last octet of the IP address).
1. First-party and third-party cookies/technologies
Depending on where a cookie originates, a distinction can be made between so-called first-party cookies and third-party cookies:
| First-party cookies or first-party technologies | Cookies that are set and accessed by the website operator as the data controller or by a data processor commissioned by the operator. Cookies and similar technologies that are used and processed by us or by a data processor commissioned by us on our behalf. Within the app, this may include, in particular, locally stored information and SDKs, provided these are used exclusively on our behalf. |
| Third-party cookies or third-party technologies | Cookies set and accessed by data controllers other than the website operator, who do not act as data processors on behalf of the website operator. Cookies and similar technologies provided or operated by external providers, through which information may be transmitted to or read by these providers. In our app, such technologies may be used in particular in the form of SDKs. |
2. Transient and persistent cookies
Depending on their duration, a distinction can also be made between so-called transient and persistent cookies:
| Transient cookies (session cookies) | Cookies that are automatically deleted when you close your browser. |
| Persistent cookies | Cookies that remain stored on your device for a specific period after you close your browser. |
3. Cookies requiring consent and those not requiring consent
Depending on their function and intended purpose, the use of certain cookies may require the user’s consent. In this respect, cookies can be categorised according to whether the user’s consent is required for their use:
| Cookies not requiring consent Cookies | Cookies whose sole purpose is to facilitate the transmission of a message via an electronic communications network. |
| Cookies that are strictly necessary for the provider of an information society service, which has been expressly requested by the subscriber or user, to be able to provide that service (‘Strictly necessary cookies’). | |
| Cookies requiring consent | Cookies used for any purpose other than those mentioned above. |
Administration of the cookies used on this website
1. Giving consent to the use of cookies and similar technologies (app) and managing cookies via the privacy and cookie settings
Where the user’s consent is required for the use of certain cookies, we will only set these cookies when you use the website and the app if you have previously given your consent to do so. Information on whether consent is required for the use of a cookie can be found in the details regarding the cookies used on this website in Section H.III of this privacy policy.
Consent on the website (cookie banner): When you visit our website, we display a ‘cookie banner’ in which you can give your consent to the use of cookies on this website by clicking a button. By clicking the button provided for this purpose, you have the option to consent to the use of all cookies described in detail in Section H.III of this Privacy Policy. Alternatively, by clicking on the ‘Cookie Settings’ button (LINK TO https://www.qolzirvaxune.site/on/demandware.store/Sites-MOP-Site/de_DE/Home-CookieSettings), you can make a personalised selection of cookies and adjust your selection at a later date. We also store your consent and, where applicable, your individual cookie selections on your device in the form of a cookie (‘opt-in cookie’) so that, the next time you visit the website, we can determine whether you have already given your consent. The opt-in cookie has a limited validity period of a maximum of 6 months.
Consent within the app (in-app consent banner): When you launch our app for the first time, we display a ‘consent banner’. Here, you can specify whether you wish to consent to the use of analytics, marketing and personalisation technologies within the app.
You can withdraw or amend this consent at any time, with effect for the future, directly in the app’s settings under the ‘Privacy and Cookie Settings’ menu item. As soon as you withdraw your consent, the relevant SDK will be deactivated and no further data will be read, stored locally or transmitted.
Strictly necessary cookies cannot be disabled via this website’s cookie management function. However, you can disable these cookies generally in your browser at any time.
2. Managing cookies via browser settings
You can also manage the use of cookies via your browser settings. Different browsers offer different ways of configuring cookie settings. You can find further detailed information on this, for example, at http://www.allaboutcookies.org/ge/cookies-verwalten
However, we would like to point out that some features of the website may not work, or may no longer work properly, if you disable cookies in your browser altogether.
Cookies used on the website
The following cookies may be used on this website:
1. Essential cookies for the basic use of the website.
No consent is required for these cookies.
| Name | First party / third party | Purpose and content | Period of validity |
|---|---|---|---|
| Commerce Tools | |||
| ai_session | First party | This cookie is linked with Microsoft Application Insights which collects statistical usage and telemetry data for applications developed on the basis of the Azure cloud platform. It is a unique, anonymous cookie for identifying sessions | One day |
| ai_user | First party | This cookie is linked with Microsoft Application Insights which collects statistical usage and telemetry data for applications developed on the basis of the Azure cloud platform. It is a unique, anonymous cookie for identifying sessions | One day |
| country | First party | This cookie records the country from which the page is accessed in order to display the correct language/country variant of the shop. | One day |
| csmopb | First party | This cookie stores the shopping basket. Required for the shop’s functions | Four weeks |
| csmcg | First party | This cookie stores the customer segment of the MARC O’POLO customer. | Four weeks |
| csmopr | First party | A cookie which Reco stores (Dynamic Yield or Amazon Web Services) | Six months |
| csmoprs | First party | Cookie that stores the Reco session (DY or AWS) | Session |
| csmopw | First-party | Cookie that stores information about the wishlist | four weeks |
| MopSessionType | First party | Cookie that sets the user type (60 days) | 60 Days |
| MopSession | First party | Cookie, which ensures the long-term authentication of the user (60 days) | 60 Days |
| MopSessionHeader | First party | Cookie that ensures the short-term authentication of users (60 days) | 60 Days |
| csmtc | First party | A cookie which stores your chosen main categories (men and women) | Four weeks |
| csmabs | First Party | Cookie for the AB-Test assignment | four weeks |
| lang | First party | A cookie which identifies the user language | Four weeks |
| customerStub | First party | A cookie which recognises customers at the checkout in order to show returning customers an auto-completed registration form. Is only activated at the checkout and not on the store page | Six weeks |
2. Marketing cookies for the use of marketing technology and advertising networks
These cookies require your consent.
Google Ads remarketing cookies
These cookies are used by the web tracking tool Google Ads Remarketing which strategically targets users of the website for the purposes of (re)targeting (section B.II). At the time this privacy policy was generated, the following cookies were used for this purpose. In the meantime, our advertising partner might have added new cookies or modified the purposes, content and durations of storage of its cookies within its own field of responsibility. Therefore, for more information, please also refer to the privacy policy of our advertising partner; a link can be found in section B.II.
| NID SID DIE IDE ANID DSID FLC AID TAID exchange_uid __gads gac | First party | These cookies are used by the Google Ads remarketing pixel, a web tracking tool which strategically targets users of the website (this is known as (re)targeting; see section B). We have incorporated the Google Ads remarketing pixel into our store; when a visitor visits our store, the pixel is loaded and it stores a cookie (tag) in the user’s browser to tag that user. Information is stored in the cookie depending on what pages of the store the customer has visited; if, for example, the customer has viewed various products, this information is stored so product adverts can be shown to the customer on other websites. In this case, the product IDs are stored in the cookie. In general, we add the product ID, the price, the page type and the number of products to the cookies for this reason. Besides the cookie settings on our website, the user can deactivate personalised advertising from Google in general: https://adssettings.google.com/authenticated | Persistent: 60 days |
| Microsoft Advertising These cookies are used by the web tracking tool Microsoft Advertising which strategically targets users of the website for the purposes of (re)targeting ( section B.II). At the time this privacy policy was generated, the following cookies were used for this purpose. In the meantime, our advertising partner might have added new cookies or modified the purposes, content and durations of storage of its cookies within its own field of responsibility. Therefore, for more information, please also refer to the privacy policy of our advertising partner; a link can be found in section B.II. | |||
| MUID MUIDB _uetsid _uetvid | Third party | These cookies are used by the Google Ads remarketing pixel, a web tracking tool which strategically targets users of the website (this is known as (re)targeting; see section B). We have incorporated the Google Ads remarketing pixel into our store; when a visitor visits our store, the pixel is loaded and it stores a cookie (tag) in the user’s browser to tag that user. Information is stored in the cookie depending on what pages of the store the customer has visited; if, for example, the customer has viewed various products, this information is stored so product adverts can be shown to the customer on other websites. In this case, the product IDs are stored in the cookie. In general, we add the product ID, the price, the page type and the number of products to the cookies for this reason. Besides the cookie settings on our website, the user can deactivate personalised advertising from Microsoft Ads in general: https://support.microsoft.com/en-us/microsoft-edge/microsoft-edge-browsing-history-for-personalized-advertising-and-experiences-37aa831e-6372-238e-f33f-7cd3f0e53679 | One year |
| Criteo cookies These cookies are used by the web tracking tool Criteo which strategically targets users of the website for the purposes of (re)targeting (section B.II). At the time this privacy policy was generated, the following cookies were used for this purpose. In the meantime, our advertising partner might have added new cookies or modified the purposes, content and durations of storage of its cookies within its own field of responsibility. Therefore, for more information, please also refer to the privacy policy of our advertising partner; a link can be found in section B.II. | |||
| ASP.NET_Sessionid | Third party | The session ID is used to identify a browser on the server unequivocally. | Session |
| r.ack | Third party | A cookie which is mainly used for Safari. | 1 hour |
| uid | Third party | Identifies users for the purposes of remarketing (displaying dynamic banners with the most important product-specific recommendations on the basis of statistical data and data collected through surfing) | One year |
| optout | Third party | Opt-out cookie. Enables the user to opt out of the Criteo service. | Five years |
| uic | Third party | Identifies the context of the user, e.g. what stage of the purchase process the user is in, if the user has viewed one or more products or if a product has been added to the basket. It enables us to evaluate, for example, how likely the user is to make a purchase on the basis of his or her browser history and actions on the website. | Six months |
| evt | Third party | Event cookie. This contains information about the last page visited on our website. It is used in the product recommendation during the banner display process. | Six months |
| udc | Third party | Dynamic inventory selection. It contains a list of sellers where the user is profitable and supports tagging and de-tagging functionality. Criteo works with a very large number of sellers in Germany. A seller usually has one or more websites on which Criteo displays its adverts. De-tagging a user means that a user who, for example, has purchased a product is de-tagged for that product. | Six months |
| acdc | Third party | Advanced Criteo data collection. It contains (optional) additional data in connection with the user, e.g. whether the user is visiting the website from a mobile or stationary end device. It is used to improve campaign performance continuously. | Six months |
| zdi | Third party | Passback loop detection. This registers how often a user triggers a passback in a zone of a publisher. Publishers are a variety of marketers within our network where we display adverts for our customers. | Six months |
| eid | Third party | External ID. This contains the user ID of our publishers/marketers. It is used to sell our mid-market inventory. We have a variety of marketers in our network. If it is not used, it is our policy to re-sell the inventory we have purchased. | Six months |
| opt | Third party | The opt cookie contains information about whether a user has opted out of our service or the service of one of the marketers on our network and therefore no longer wishes to receive personalised adverts. | One year |
| cto_bundle | Third Party | The cto_bundle cookie helps to improve tracking results and records visitor behaviour in order to provide more relevant adverts. | One year |
| Meta pixel cookies These cookies are used on our website for the Facebook pixel (section B.II). At the time this privacy policy was generated, the following cookies were used for this purpose. In the meantime, our advertising partner might have added new cookies or modified the purposes, content and durations of storage of its cookies within its own field of responsibility. Therefore, for more information, please also refer to the privacy policy of our advertising partner; a link can be found in section B.II. | |||
| c_user | First party | Is used together with the xs cookie to authenticate your identity with Facebook (user ID). | 90 days |
| datr | First party | Browser ID and time stamp Identifies the browser for the purposes of security and website integrity, including account restoration and the identification of potentially compromised accounts. | Persistent: Two years |
| sb | First party | Browser ID and time stamp Identifies the browser for the purposes of log-in authentication | Persistent: Two years |
| wd | First party | Screen or window dimensions Makes it possible to optimise the display on the user’s monitor | Persistent: Seven days |
| xs | First party | Session ID, creation time, authentication value, secure session status, caching group ID. Is used together with the C_user cookie to authenticate the identity of the user with Facebook. | Persistent: 90 days |
| TikTok Pixel cookies These cookies are used for the TikTok Pixel tool on our website (🡪Section B.II). At the time of writing this privacy notice, the following cookies were in use. Our advertising partner may since have added new cookies or modified the purposes, content and retention periods of the cookies. For further information, we therefore refer you to our advertising partner’s privacy policy, which is linked inSection B.II. | |||
| _tt_enable_cookie | First-party | To measure and improve the performance of your advertising campaigns and to personalise the user experience (including adverts) on TikTok. | 390 days (13 months) |
| _ttp | Third Party | To measure and improve the performance of your advertising campaigns and to personalise the user experience (including adverts) on TikTok. | 390 days (13 months) |
| retailAds These cookies are used by the advertising network operated by retailAds to promote our products as effectively as possible, including the display of personalised, interest-based advertising and the billing of advertising campaigns with our advertising partners (🡪Section B.II). At the time of writing this privacy notice, the following cookies were in use for this purpose. Our advertising partner may since have added new cookies or modified the purposes, content and retention periods of the cookies. For further information, we therefore refer you to our advertising partner’s privacy policy, which is linked inSection B.II. | |||
| bId | Third Party | Defines a browser-specific ID to identify a new click on the same browser. | One year |
| aw***** (The cookie name varies for each advertiser, but consists of the letters ‘aw’ followed by an ID representing the advertiser, e.g. aw1001.) | Third party | Set when you click on one of our links. Stores IDs for referring websites, adverts you have clicked on, the group of adverts to which the advert belongs, the time you clicked on it, the ID for the type of advert, the product ID and any referrers that the referring website adds to the click. | 30 days |
| AWSESS | Third party | Stored when you view an advert, also to ensure we do not keep showing you the same advert. An ID for the advert you have viewed. Expires at the end of the session when you close your browser | Session |
| awpv***** (The cookie name varies for each advertiser, but consists of the letters ‘aw’ followed by an ID representing the advertiser, e.g. awpv1001.) | Third party | Set when you view an advert. Stores an ID for the website on which the advert is displayed and the time at which you viewed the advert. | 24 hours |
| _aw_m_***** (The cookie name varies for each advertiser, but consists of the letters ‘aw’ followed by an ID representing the advertiser, e.g. _aw_m_1001.) Tracking cookies set by the advertiser on the advertiser’s domain for AWIN | |||
| bId | Third party | Defines a browser-specific ID in order to identify a new click in the same browser. | One year |
| aw***** (Although the cookie name is different for every advertiser, the letters are ‘aw’ followed by an ID representing the advertiser, e.g. aw1001.) | Third party | Activates when you click on one of our links. It stores IDs for referring websites, adverts you click on, groups of adverts to which the advert belongs, the time you clicked on it, the ID of the type of advert, the ID of the product and all references which the referring website adds to the click. | 30 days |
| AWSESS | Third party | Stores when you see an advert in order to ensure that we do not always show you the same advert. An ID for the advert you have seen. Expires at the end of the session when you close your browser | Session |
| awpv***** (Although the cookie name is different for every advertiser, the letters are ‘aw’ followed by an ID representing the advertiser, e.g. awpv1001.) | Third party | Activates when you see an advert. Stores an ID for the website on which the advert is displayed and the time when you saw the advert. | 24 hours |
| _aw_m_***** (Although the cookie name is different for every advertiser, the letters are ‘aw’ followed by an ID representing the advertiser, e.g. _aw_m_1001.) Tracking cookies which are used by the advertiser for AWIN in the advertiser’s domain. | Third party | Set when you click on one of our links. Stores IDs for referring websites, adverts you have clicked on, the advert group to which the advert belongs, the time you clicked on it, the ID for the type of advert, the product ID and any referrers that the referring website adds to the click. | 30 days |
| Google Ads conversion pixel cookies These cookies are used the Google Ads conversion pixel, a web tracking tool which evaluates user actions (conversion tracking) (see section B.II). At the time this privacy policy was generated, the following cookies were used for this purpose. In the meantime, our advertising partner might have added new cookies or modified the purposes, content and durations of storage of its cookies within its own field of responsibility. Therefore, for more information, please also refer to the privacy policy of our advertising partner; a link can be found in section B.II. | |||
| Conversion AID DSID TAID | First party | These cookies are used the Google Ads conversion pixel, a web tracking tool which evaluates user actions (conversion tracking) (see section B.II). They contain placeholders for the following information: · Unique ID to recognise returning visitors · Page type (e.g. order confirmation page, product details page, basket), · Order number · Net basket price (excluding delivery costs, excluding VAT, excluding payment costs, excluding vouchers) · Product numbers and prices The conversion pixel stores the purchasing and surfing habits of users. This includes the following information: · What product the customer purchased and at what price · What pages the customer navigated to · What was the total price of products in the basket This information is used to gauge the success of the adverts (e.g. whether the use of banners and videos generated revenue). Additionally, these data are used to pseudonymised customers and add them to retargeting lists in order to show them personalised adverts or exclude them from campaigns (e.g. excluding men from a campaign for women). (see also ‘Google Ads remarketing cookies’ above) | Persistent: 60 days |
| Doubleclick/Floodlight These cookies are used by the web tracking tool Doubleclick/Floodlight which strategically targets users of the website for the purposes of (re)targeting and conversion tracking (section B.II). At the time this privacy policy was generated, the following cookies were used for this purpose. In the meantime, our advertising partner might have added new cookies or modified the purposes, content and durations of storage of its cookies within its own field of responsibility. Therefore, for more information, please also refer to the privacy policy of our advertising partner; a link can be found in section B.II. | |||
| DSID | Third party | Campaign optimisation. | 14 days |
| IDE | Third party | Contains a randomly generated user ID. Google can use this ID to recognise the user across various websites and domains and show personalised adverts. | One year |
| vscr_vid | Third party | Campaign optimisation. | One year |
| _fbp | Third party | Campaign optimisation. | 30 days |
| Tectumedia These cookies are used by the web tracking tools Google, Display.me, Mervellousmachine, mpnrs.com and Doubleclick which are incorporated into the website by means of the Tectumedia container (section B.II). At the time this privacy policy was generated, the following cookies were used for this purpose. In the meantime, our advertising partner might have added new cookies or modified the purposes, content and durations of storage of its cookies within its own field of responsibility. Therefore, for more information, please also refer to the privacy policy of our advertising partner; a link can be found in section B.II. | |||
| dsply_nth_3749 | Third party | Campaign optimisation. | One year |
| dsply_nin_3793 | Third party | Campaign optimisation. | One year |
| dsply_dlkl_3793 | Third party | Campaign optimisation. | Six months |
| dsply_ost_3749 | Third party | Campaign optimisation. | One year |
| dsply_ost_3793 | Third party | Campaign optimisation. | Six months |
| dsply_kc_3749 | Third party | Campaign optimisation. | One year |
| dsply_kc_3793 | Third party | Campaign optimisation. | One year |
| dsply_dlkl_3749 | Third party | Campaign optimisation. | One year |
| dsply_vid | Third party | Campaign optimisation. | One year |
| ata | Third party | Campaign optimisation. | One year |
| Outbrain These cookies are used by the advertising network operated by Outbrain to advertise our products as effectively as possible, including displaying personalised, interest-based adverts and paying for the advertising campaigns with our promotional partners (section B.II). At the time this privacy policy was generated, the following cookies were used for this purpose. In the meantime, our advertising partner might have added new cookies or modified the purposes, content and durations of storage of its cookies within its own field of responsibility. Therefore, for more information, please also refer to the privacy policy of our advertising partner; a link can be found in section B.II. | |||
| OBUID | Third party | Contains the pseudonymised user ID of the user and is used to track user actions, e.g. to click on an advert, conversion tracking or to carry out retargeting campaigns. | Three months |
| AUID | Third party | Contains the pseudonymised user ID of the user and is used to track user actions on mobile devices, e.g. to click on an advert, conversion tracking or to carry out retargeting campaigns. | 90 days |
| Pinterest These cookies are used on our website for the Pinterest Pixel (section B.II). At the time this privacy policy was generated, the following cookies were used for this purpose. In the meantime, our advertising partner might have added new cookies or modified the purposes, content and durations of storage of its cookies within its own field of responsibility. Therefore, for more information, please also refer to the privacy policy of our advertising partner; a link can be found in section B.II. | |||
| _pin_unauth | First party | Used by Pinterest to track how users use the services. | One year |
| _pinterest_sess | Third party. www.pinterest.com | The Pinterest login cookie is used to store the log-in status of a user in a browser. It is updated when a user logs into Pinterest (or logs out). This cookie contains the Pinterest ID of the user (a random pseudonymised integer) as well as the user’s authentication token (if the user is logged into Pinterest). | Session |
| _pinterest_ct, _pinterest_ct_mw, _pinterest_ct_rt | Third party. www.pinterest.com | These are identical in terms of content; they only contain a user ID and the time stamp that was generated for the cookie. | One year |
| Emarsys eMarketing Systems AG | |||
| scarab.visitor | First party | Browser-ID – Identifies the browser for the purposes of log-in authentication | One year |
| cdv | Third party | Browser-ID – Identifies the browser for the purposes of log-in authentication | One year |
| scarab.profile | First party | Information about the user profile, searched products etc. as well as script performance metrics (load/run speed etc.) – these cookies are encrypted | One year |
| xp | Third party | Information about the user profile, searched products etc. as well as script performance metrics (load/run speed etc.) – these cookies are encrypted | One year |
| scarab.mayAdd & scarab.mayViewed | First party | Session cookies which we use to track click paths and articles in the basket. | Duration of the web session |
| s | Third party | Session cookies which we use to track click paths and articles in the basket. | Duration of the web session |
| RTB House These cookies are used by the web tracking tool RTB House for targeted advertising to website users (re-)targeting (🡪 Section B.II). At the time of writing this privacy policy, the following cookies were in use for this purpose. Our advertising partner may since have added new cookies or modified the purposes, content and retention periods of the cookies. For further information, we therefore refer you to our advertising partner’s privacy policy, which is linked inSection B.II. | |||
| u | Third-party | Data relating to user activity on the client’s website, in particular whether the user has clicked the ‘Order’ button; IDs or categories of products viewed by the user; IDs of products added to the shopping basket and/or purchased by the user; total value of the order and order reference This data is not combined with other sources of PII. | One year |
| ts | Third-party | Time of user activity | One year |
| Reddit Inc. These cookies are used by the web tracking tool Reddit for (re)targeting website users with personalized advertising (🡪 Section B.II). At the time this privacy policy was created, the following cookies were in use for this purpose. Our advertising partner may have since added new cookies or modified the purposes, content, and retention periods of the cookies. For further information, we therefore refer you to our advertising partner’s privacy policy, which is linked in Section B.II. | |||
| _rdt_uuid | First-Party | Contains an anonymous ID that is used for accurate mapping. | 90 days |
| _rdt_cid | First-Party | Saves the click ID when someone visits the online store via a Reddit ad. | 90 days |
3. Analytics cookies for web analytics technologies
These cookies require your consent.
| Google Analytics cookies These cookies are used by the web analytics tool Google Analytics to capture and analyse user behaviour on our website in order to improve the website (see section B). | |||
| _ga | First party | This cookie contains a unique visitor ID and is used to tell users apart. | Persistent: Two years. |
| _gid | First party | This cookie contains a unique visitor ID and is used to tell users apart. | Persistent: 24 hours. |
| _gat | First party | This cookie is used to throttle the demand rate. | Transient. |
| __utma | First party | This cookie stores the number of visits by every visitor and the date and time of the first visit, earlier visits and the current visit. | Persistent: Two years. |
| __utmt | First party | This cookie is used to throttle the demand rate. | Transient. |
| __utmb | First party | This cookie is used to track how long a visitor spends on a website, i.e. when the visit starts and ends. The cookie stores the time when a visitor accesses a page. | Transient. |
| __utmc | First party | This cookie is used to track how long a visitor spends on a website, i.e. when the visit starts and ends. The cookie stores the time when a visitor leaves a page. | Persistent: 30 minutes. |
| __utmv | First party | This cookie stores the visitor category to which a user belongs. | Persistent: Two years. |
| __utmz | First party | This cookie stores the source or campaign which explains how a user has arrived on the website. | Persistent: Six months. |
| AB Tasty | |||
| ABTasty | First-party | AB Tasty uses the cookie to transmit test data (visitor ID, test and variant IDs, timestamps). | 13 months |
| ABTastySession | First-party | In AB Tasty Session, the cookie is used to transmit the start, duration and end of the session. | Session-based |
| Factfinder (Session Storage) | |||
| ssmopffcmi | First-party | Campaign Storage – Identifies the Factfinder campaign via which the user reached the product | Stored in session storage for the duration of the session |
| ssmopffsi | First Party | Session ID – A randomly generated ID that groups together all events generated within a session. | Stored in session storage for the duration of the session |
| ssmopffui | First-party | User ID – A randomly generated ID that groups together all events generated by a user. | Stored in session storage for the duration of the session |
4. Personalisation cookies for personalisation technologies
These cookies require your consent.
| adnymics GmbH | |||
| AWSALB | Third Party | Users’ click and purchase behaviour is analysed to enable the creation of a parcel insert containing personalised product recommendations for the user in the event of an order. | 13 months |
| AWSALBCORS | Third Party | Users’ click and purchase behaviour is analysed to enable the creation of a parcel insert containing personalised product recommendations for the user in the event of an order. | 13 months |
| Epoq-Cookies | |||
| eqe | First party | The epoq recommendation tool is used to optimise our website in order to make your visit to the site a personal experience through tailored recommendations and content. We use the page content the user has accessed to recommend comparable or related products or other content that may be relevant to them. | Persistent: 30 days |
| eqsid | First party | Session | |
| __cfduid | First party | Persistent: 365 days | |
| Saiz | |||
| ARRAffinitySameSite | First party | The ARRAffinitySameSite cookie is used to evenly distribute usage requests of the widget so that the SAIZ widget always loads quickly. | 20 Minutes |
| Fittingbox | |||
| LastSessionUuid | First Party | This ID is used to track whether the user had already started the Virtual Try On module before. | Session-based |
| fitstate | First Party | This cookie identifies whether the user is using a photo or the camera mode for Virtual Try On. | Session-based |
| dataPrivacyTermsAccepted | First Party | The user has accepted the privacy notice. | 30 minutes |
| dataPrivacyTermsAnswerExpiration_date | First Party | Period during which you can use Virtual Try On indefinitely without a privacy notice reappearing. | 30 minutes |
SDKs and similar technologies used in the app
The following SDKs may be used in the app:
1. Essential SDKs and technologies for the informational use of the app.
No consent is required for these SDKs and technologies.
| Description | First Party / Third Party | Purpose and content | Validity period |
|---|---|---|---|
| Firebase for Crashlytics | |||
| Firebase Crashlytics SDK | Third Party | App stability analysis and error reporting: This SDK is used to record system crashes and technical errors within our app in real time. If an error or crash occurs in the app, technical reports (crash reports) are automatically sent to Google’s servers. In the process, anonymised device details (e.g. device model, installed version of the app, available storage space, operating system version) as well as temporary, device-specific installation IDs are read and processed for error tracking. This is technically essential to ensure the secure, error-free and stable delivery of the app’s content. | Session-based / Until uninstallation The error reports and temporary IDs are temporarily stored in the system for the duration of the error resolution and are deleted once the session is closed or the reported system error has been resolved. |
| Usercentrics SDK | First-party | We use the Usercentrics Apps SDK to record, manage and document the consents you have given or refused. | The SDK permanently stores the consent status locally, together with a controller ID, until the consent decision is updated. |
| Language selection data (stored in the device’s local storage) | First-party | Provision of the app in the selected language. This is technically essential for displaying text within the app in the selected language. | Language selection data is stored permanently in the app. |
| Consent data (stored in the device’s local storage) | First-party | Storage of the permissions specified for the app. | Consent data is stored permanently in the app. Storage is device-specific. |
| Shopping basket data (stored in the device’s local storage) | First-party | Storage of the items you add to your shopping basket. | Shopping basket data is stored without logging in for the duration of the session. Upon logging in, this data is stored permanently in your profile. |
2. Marketing SDKs for the use of marketing technologies and advertising networks.
Your consent is required for these SDKs and technologies.
| Description | First Party / Third Party | Purpose and content | Validity period |
|---|---|---|---|
| AppsFlyer | |||
| AppsFlyer SDK | Third Party | App attribution, campaign measurement and deep linking (OneLink): The integrated SDK uses your device’s local storage and your operating system’s advertising IDs (IDFA/GAID) to measure the performance of mobile adverts. It stores temporary IDs locally on your device to determine which advertising campaign led to the app installation, as well as click IDs to facilitate deep linking redirects. The data is processed in a pseudonymised form and transmitted to advertising networks (such as Google Ads and Meta) for campaign management. | Local identifiers are stored on the device on a temporary basis for the duration of the session (deep linking) or remain active until the app is uninstalled or consent is withdrawn. |
3. Analytics SDKs for the use of web analytics technologies
Your consent is required for these SDKs and technologies.
| Description | First-party / Third-party | Purpose and content | Validity period |
|---|---|---|---|
| Firebase for Google Analytics | |||
| Firebase SDK | Third Party | In-app behaviour analysis and performance metrics: This analytics SDK is used in our mobile app to record and statistically analyse user behaviour within the app in a pseudonymised manner. To this end, interactions (e.g. accessing specific screens, clicking buttons, in-app purchases) and app crash reports are collected. The SDK reads your device’s advertising IDs (IDFA/GAID) and a unique app instance ID generated by Firebase, and stores small data packets in the app’s local storage for session management. The data helps us to identify technical issues, improve the app’s user-friendliness and understand how actively our app is being used. | The pseudonymous identifiers remain stored in the local app storage until the app is uninstalled, the app cache is manually cleared, or consent is withdrawn in the app settings. |
4. Personalisation SDKs for the use of personalisation technologies
Your consent is required for these SDKs and technologies.
| Description | First-party / Third-party | Purpose and content | Validity period |
|---|---|---|---|
| Bloomreach | |||
| Bloomreach SDK | Third Party | The SDK automatically records app events (e.g. installation, session start) as well as user-defined interactions in order to analyse usage behaviour and segment users based on their behaviour. Each event is assigned a device ID; logged-in users are recognised across devices by means of a unique identifier (e.g. email address) and assigned to a unified user profile. In addition, the SDK registers the device to receive push notifications and manages the push tokens required for this. It also enables the display of personalised in-app messages, dynamic content areas and an in-app message box. All recorded events and profile information are transmitted in real time to the Bloomreach Engagement Platform. | Push tokens: 120 days; reset when the app is launched. |
I. App permissions
App permissions
Push notifications: With your consent, the app may send push notifications to your device. You can change this permission at any time in your device settings. The various push options and their respective purposes are described in Section D .
Tracking permission: Depending on the operating system, you can allow or deny the app access to tracking technologies via a system prompt and subsequently change this permission in your device settings – on iOS, in particular via App Tracking Transparency (ATT). (Irrespective of this, you can select separately in the consent banner whether your data may be used for analytics and/or marketing purposes.)
J. Information on the rights of data subjects
General information on the rights of data subjects
As a data subject, you have the following rights with regard to the processing of your personal data:
● Right of access (Article 15 GDPR)
● Right to rectification (Article 16 GDPR)
● Right to erasure (‘right to be forgotten’) (Article 17 GDPR)
● Right to restriction of processing (Article 18 GDPR)
● Right to data portability (Article 20 GDPR)
● Right to object (Article 21 GDPR)
● Right to withdraw consent (Article 7(3) GDPR)
● Right to lodge a complaint with a supervisory authority (Article 77 GDPR)
If you wish to exercise your rights, you can contact us using the information provided in section A.
For information about any particular methods and mechanisms that make it easier for you to exercise your rights, especially your rights to data portability and to object, please refer to the information about how personal data are processed in sections B to F of this privacy policy.
Below you will find more detailed information about your rights with regard to the processing of your personal data:
Right to rectification
As a data subject, you have a right to rectification in line with the requirements of Article 16 GDPR.
In particular, this means that you have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you, as well as the right to have incomplete personal data completed.
For full details about your right to rectification, please refer to Article 16 GDPR at http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.
Right of access
As a data subject, you have a right to access information in line with the requirements of Article 15 GDPR.
In particular, this means that you have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed. If this is the case, you also have a right to information about these personal data and to the information set out in Article 15(1) GDPR. In particular, this information includes the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipient to whom the personal data have been or will be disclosed (points (a), (b) and (c) of Article 15(1) GDPR).
For full details about your right of access, please refer to Article 15 GDPR at http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.
Right to erasure (‘right to be forgotten’)
As a data subject, you have a right to erasure (‘right to be forgotten’) in line with the requirements of Article 17 GDPR.
This means that you have the right to obtain from us the erasure of personal data concerning you without undue delay, and we have the obligation to erase personal data without undue delay where one of the grounds set out in Article 17(1) GDPR applies. For example, this can be the case when personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed (point (a) of Article 17(1) GDPR).
Where we have made the personal data public and are obliged to erase the personal data, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data (Article 17(2) GDPR).
In an exceptional case, the right to erasure (‘right to be forgotten’) does not apply to the extent that the processing is necessary for the reasons set out in Article 17(3) GDPR. For example, this can be the cast where the processing is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims (points (b) and (e) of Article 17(3) GDPR).
For full details about your right to erasure, please refer to Article 17 GDPR at http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.
Right to restriction of processing
As a data subject, you have a right to restriction of processing in line with the requirements of Article 18 GDPR.
This means that you have the right to obtain from us restriction of processing if one of the criteria set out in Article 18(1) GDPR is met. This can be the case, for example, if you contest the accuracy of the personal data. In this case, processing shall be restricted for a period enabling us to verify the accuracy of the personal data (point (a) of Article 18(1) GDPR).
Restriction means the marking of stored personal data with the aim of limiting their processing in the future (Article 4(3) GDPR).
For full details about your right to restriction of processing, please refer to Article 18 GDPR at http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.
Right to data portability
As a data subject, you have a right to data portability under the conditions of Article 20 of the General Data Protection Regulation.
This means that you 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 and you have the right to transmit those data to another controller without hindrance from us, where the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) of the General Data Protection Regulation or on a contract pursuant to point (b) of Article 6(1) of the General Data Protection Regulation and the processing is carried out by automated means (Article 20(1) of the General Data Protection Regulation).
For information on whether processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) of the General Data Protection Regulation or on a contract pursuant to Article 6(1)(b) of the General Data Protection Regulation, please refer to the information on the legal bases of processing in sections B to F of this data protection information.
In exercising your right to data portability, you also have the right to have the personal data transmitted directly from us to another controller, where technically feasible (Article 20(2) of the General Data Protection Regulation).
The full scope of your right to restriction of processing can be found in Article 20 of the General Data Protection Regulation, which you can access at the following link: http://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32016R0679.
Right to object
As a data subject, you have a right to object in line with the requirements of Article 21 GDPR.
We shall expressly make you aware of your right to object when we first communicate with you at the very latest.
More detailed information about this is available below:
1. right to object on grounds relating to the particular situation of the data subject
As the data subject, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the General Data Protection Regulation, including profiling based on those provisions.
Information on whether processing is based on Article 6(1)(e) or (f) of the General Data Protection Regulation can be found in the information on the legal bases of processing in sections B to F of this data protection information.
In the event of an objection on grounds relating to your particular situation, we will no longer process the personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
The full scope of your right to object can be found in Article 21 of the General Data Protection Regulation, which you can access at the following link: http://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32016R0679.
2. right to object to direct marketing
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Information on whether and to what extent personal data is processed for direct marketing purposes can be found in the information on the purposes of processing in sections B to F of this data protection information.
In the event of an objection to processing for direct marketing purposes, we will no longer process the personal data concerned for these purposes.
The full scope of your right to object can be found in Article 21 of the General Data Protection Regulation, which you can access at the following link: http://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32016R0679.
Right to withdraw consent
If processing is based on consent in accordance with point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR, you, the data subject, have the right to withdraw your consent at any time pursuant to Article 7(3) GDPR. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. We shall make you aware of this before you grant consent.
For information about whether processing is taking place on the basis of consent in accordance with point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR, please refer to the information about the legal grounds on which processing is based in sections B to F of this privacy policy.
Right to lodge a complaint with a supervisory authority
As a data subject, you have the right to lodge a complaint with a supervisory authority under the conditions of Article 77 of the General Data Protection Regulation.
The supervisory authority responsible for us is
Bavarian State Office for Data Protection Supervision
Promenade 18, 91522 Ansbach
+49 (0) 981 180093-0
K. Information about the terminology from the General Data Protection Regulation used in this data protection information
Information about the terminology from the General Data Protection Regulation used in this data protection information
The definitions of the terminology used in this privacy policy are the same as in the General Data Protection Regulation.
For full details about the definitions in the General Data Protection Regulation, please refer to Article 4 GDPR at http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.
Below you will find more detailed information about the most important key terms of the General Data Protection Regulation on which this privacy policy is based:
● ‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
● ‘Data subject’ is the identified or identifiable natural person to whom personal data relate;
● ‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
● ‘Profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
● ‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
● ‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
● ‘Recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
● ‘Third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
● ‘International organisation’ means an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries;
● ‘Third country’ means a country that is not a Member State of the European Union (EU) or European Economic Area (EEA);
● ‘Special categories of personal data’ means data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
L. Status and changes to this privacy policy
Status and changes to this privacy policy
This privacy policy is dated 07.08.2026.
Due to technical advancements and/or changes to statutory and/or official requirements, it might become necessary to amend this privacy policy.
The current version of the privacy policy is always available at www.qolzirvaxune.site.