privacy and data protection
This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profile (hereinafter referred to as collectively referred to as “Online Offering”). With regard to the terms used, such as "processing" or "person responsible", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Arbnora Sula / Blerta Sula / Hair2You Ltd
6340 Baar, Switzerland
Link to the imprint: https://www.hair2you.ch/de/info/impressum.html
Types of data processed:
- Inventory data (eg, names, addresses).
- Contact information (e.g., email, phone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g. websites visited, interest in content, access times).
- Meta/communication data (e.g. device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (in the following we refer to the persons concerned collectively as "users").
purpose of processing
- Provision of the online offer, its functions and content.
- Answering contact requests and communicating with users.
- Safety measures.
- Reach measurement/marketing
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Processing" is any process or series of processes carried out with or without the aid of automated processes in connection with personal data. The term is broad and encompasses practically every handling of data.
"Pseudonymization" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is stored separately and is subject to technical and organizational measures that ensure that the personal data not assigned to an identified or identifiable natural person.
"Profiling" any type of automated processing of personal data, which consists in using this personal data to evaluate certain personal aspects relating to a natural person, in particular aspects related to work performance, economic situation, health, personal Analyze or predict that natural person’s preferences, interests, reliability, behavior, whereabouts or relocation.
The "responsible person" is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
"Processor" means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the person responsible.
Relevant legal bases
In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 (1) lit. a and Art Answering inquiries is Article 6(1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is Article 6(1)(c) GDPR, and the legal basis for processing to safeguard our legitimate interests is Article 6(1)(c) GDPR 6 Paragraph 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 Paragraph 1 lit. d GDPR serves as the legal basis.
In accordance with Art. 32 GDPR, we take appropriate technical measures, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk for the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, transfer, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 GDPR).
Cooperation with processors and third parties
If, as part of our processing, we disclose data to other people and companies (contract processors or third parties), transmit it to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if the data is transmitted to third parties, as to payment service providers, pursuant to Art. 6 Para. 1 lit. b GDPR is required for the fulfillment of the contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties to process data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 DSGVO.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this happens as part of the use of third-party services or disclosure or transmission of data to third parties, this only takes place if it is to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have the data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to that of the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
Rights of data subjects
You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
You have accordingly. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately, or alternatively, in accordance with Art. 18 GDPR, to demand a restriction of the processing of the data.
You have the right to request that you receive the data that you have provided to us in accordance with Art. 20 GDPR and to request that it be transmitted to other responsible parties.
You also have the right, in accordance with Article 77 GDPR, to lodge a complaint with the competent supervisory authority.
right of withdrawal
You have the right to revoke your consent in accordance with Article 7 (3) GDPR with effect for the future
Right to object
You can object to the future processing of data relating to you at any time in accordance with Art. 21 GDPR. The objection can be made in particular against processing for direct advertising purposes.
Cookies and the right to object to direct advertising
"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be saved. "Permanent" or "persistent" refers to cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users can also be stored in such a cookie, which are used for range measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only their cookies, we speak of "first-party cookies").
We can use temporary and permanent cookies and explain this in our data protection declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
deletion of data
The data processed by us will be deleted or their processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage requirements. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
According to legal requirements in Germany, storage takes place in particular for 10 years in accordance with §§ 147 Paragraph 1 AO, 257 Paragraph 1 No. 1 and 4, Paragraph 4 HGB (books, records, management reports, accounting documents, trading books, relevant for taxation documents, etc.) and 6 years in accordance with Section 257 Paragraph 1 Nos. 2 and 3, Paragraph 4 HGB (commercial letters).
According to legal requirements in Austria, storage takes place in particular for 7 years in accordance with § 132 Para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, list of income and expenses, etc.), for 22 years in connection with properties and for 10 years for documents related to electronically supplied services, telecommunications, radio and television services supplied to non-businesses in EU Member States and for which the Mini One Stop Shop (MOSS) is used.
In addition, we process
- Contract data (e.g. subject matter of contract, term, customer category).
- Payment data (eg, bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Order processing in the online shop and customer account
We process the data of our customers as part of the ordering process in our online shop to enable them to select and order the selected products and services, as well as their payment and delivery or execution.
The processed data includes inventory data, communication data, contract data, payment data and the persons affected by the processing include our customers, interested parties and other business partners. The processing takes place for the purpose of providing contractual services in the context of operating an online shop, billing, delivery and customer services. We use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.
The processing takes place on the basis of Art. 6 Para. 1 lit. b (implementation of order processes) and c (legally required archiving) DSGVO. The information marked as required is required for the establishment and fulfillment of the contract. We disclose the data to third parties only within the scope of delivery, payment or within the scope of legal permits and obligations to legal advisers and authorities. The data will only be processed in third countries if this is necessary to fulfill the contract (e.g. at the customer's request for delivery or payment).
Users can optionally create a user account, in particular by being able to view their orders. As part of the registration, the required mandatory information is communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention being necessary for commercial or tax reasons in accordance with Article 6 (1) (c) GDPR. Information in the customer account remains until it is deleted with subsequent archiving in the event of a legal obligation. It is the user's responsibility to back up their data before the end of the contract in the event of termination.
As part of the registration and renewed registrations as well as the use of our online services, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests, as well as the user's protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Article 6 (1) (c) GDPR.
Deletion takes place after statutory warranty and comparable obligations have expired, the necessity of storing the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation).
External payment service providers
We use external payment service providers, via whose platforms the users and we can carry out payment transactions (e.g., each with a link to the data protection declaration, PayPal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzanleitung/), Giropay (https://www.giropay.de/ legal/data-protection-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https:/ /www.americanexpress.com/de/content/privacy-policy-statement.html)
As part of the fulfillment of contracts, we use the payment service providers on the basis of Article 6 Paragraph 1 lit. b. GDPR a. In addition, we use external payment service providers on the basis of our legitimate interests in accordance with Article 6 (1) (f) GDPR in order to offer our users effective and secure payment options.
The data processed by the payment service provider includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information with confirmation or negative information about the payment. Under certain circumstances, the payment service provider may transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. We refer to the terms and conditions and data protection notices of the payment service providers.
The terms and conditions and the data protection notices of the respective payment service provider apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to this for the purpose of further information and the assertion of revocation, information and other data subject rights.
Users can create a user account. As part of the registration, the required mandatory information is communicated to the user and processed on the basis of Article 6 (1) (b) GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purpose of using the user account and its purpose.
Users can be informed by email about information relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is the user's responsibility to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all of the user's data stored during the contract period.
As part of the use of our registration and login functions and the use of the user account, we save the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests, as well as the user's protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Article 6 Paragraph 1 Letter c. GDPR. The IP addresses are anonymized or deleted after 7 days at the latest.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user is used to process the contact request and to process it in accordance with Article 6 (1) b. (in the context of contractual/pre-contractual relationships), Art. 6 Paragraph 1 lit. f. (other inquiries) GDPR processed get saved.
We delete the requests if they are no longer necessary. We review necessity every two years; Furthermore, the statutory archiving obligations apply.
hosting and email delivery
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offer.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties and visitors to this online offer on the basis of our legitimate interests in making this online offer available efficiently and securely in accordance with Art. 6 Para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract).
Collection of access data and log files
We, or our hosting provider, collect data about every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Article 6 Paragraph 1 lit. The access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider .
Log file information is stored for a maximum of 7 days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidence purposes are excluded from deletion until the respective incident has been finally clarified.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and internet usage. Pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; In addition, users can prevent the data generated by the cookie and related to their use of the online offer from being collected and processed by Google by downloading and installing the browser plug-in available under the following link: http://tools .google.com/dlpage/gaoptout?hl=de .
You can find more information on data use by Google, setting and objection options in Google's data protection declaration ( https://policies.google.com/technologies/ads ) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated ).
The personal data of the users will be deleted or made anonymous after 14 months.
Google AdWords and conversion measurement
We use the services of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 on the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. DSGVO). , United States, ("Google").
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the Google "AdWords" online marketing process to place ads on the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offering in a more targeted manner in order to only present users with ads that potentially match their interests. If, for example, a user is shown ads for products that he was interested in on other online offers, this is referred to as "remarketing".
For these purposes, when our and other websites on which the Google advertising network is active are accessed, a Google code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as " referred to as "web beacons") integrated into the website. With their help, an individual cookie, ie a small file, is stored on the user's device (comparable technologies can also be used instead of cookies). This file notes which websites the user visits, what content he is interested in and which offers the user clicked on, as well as technical information on the browser and operating system, referring websites, visiting times and other information on the use of the online offer.
We also receive an individual "conversion cookie". The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only find out the anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, we do not receive any information with which users can be personally identified.
User data is processed pseudonymously within the framework of the Google advertising network. This means that Google does not store and process, for example, the name or e-mail address of the user, but processes the relevant data in relation to cookies within pseudonymous user profiles. This means that from Google's point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who this cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google's servers in the USA.
You can find more information on data use by Google, setting and objection options in Google's data protection declaration ( https://policies.google.com/technologies/ads ) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated ).
Online presence in social media
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to be able to inform them about our services there.
We would like to point out that user data can be processed outside of the European Union. This can result in risks for the user, because it could make it more difficult to enforce the user's rights, for example. With regard to US providers who are certified under the Privacy Shield, we would like to point out that they undertake to comply with the data protection standards of the EU.
Furthermore, user data is usually processed for market research and advertising purposes. For example, usage profiles can be created from usage behavior and the resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the user. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of the personal data of the users takes place on the basis of our legitimate interests in effective information of the users and communication with the users in accordance with Article 6 Paragraph 1 lit. f GDPR. If the users are asked by the respective providers to consent to the data processing (i.e. declare their consent, for example by ticking a check box or confirming a button), the legal basis for the processing is Article 6 Paragraph 1 Letter a., Article 7 GDPR.
For a detailed description of the respective processing and the possibility of objection (opt-out), we refer to the following linked information from the providers.
Also in the case of requests for information and the assertion of user rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Integration of third-party services and content
We use content or service offers from third-party providers within our online offer on the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit Integrate services such as videos or fonts (hereinafter uniformly referred to as "content").
This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes.
The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, visiting times and other information on the use of our online offer, as well as being linked to such information from other sources.