Basic Information and Mandatory Disclosures
What is Personal Data?
Personal data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not personal data. This includes, for example, the number of users of a website.
What is processing?
"Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Responsible for data processing
Responsible for data processing is:
Unit 30-31, Gosport Business Centre,
Aerodrome Road, Gosport,
Hampshire PO13 0FQ, UK
General Information on Data Processing
- The legal bases of processing
All personal data that we obtain from you via the website will be processed for the purposes described in more detail below. This is done within the framework of the DPA and the GDPR or with your consent. In particular, we process personal data only when processing is permitted and if:
- you have given your consent,
- the data is necessary for the fulfilment of a contract / pre-contractual measures,
- the data is necessary for the fulfilment of a legal obligation or
- the data is necessary to protect the legitimate interests of our company, provided that your interests are not overridden.
- Your data subject rights
The following rights are available to you as a data subject:
- the right to information,
- the right to rectification,
- the right to erasure,
- the right to restriction of data processing,
- the right to data portability,
- the right to object to data processing,
- the right to revoke any consent you have given, and
- the right to lodge a complaint with the competent supervisory authority.
Please contact us at any time with questions and suggestions regarding data protection and/or to enforce your rights, using firstname.lastname@example.org.
- Exercising your rights
If you wish to access your personal data or exercise any of the rights listed above, you should apply in writing, providing evidence of your identity. Any communication from us in relation to your rights as detailed above will be provided free of charge. However, in case of requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or refuse to act on the request.
- Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please contact us using email@example.com.
- The competent supervisory authority
The Information Commissioner`s Office (ICO) is the relevant authority in the UK. The ICO is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK (www.ico.org.uk). If you believe that the processing of your personal data is not lawful, you can lodge a complaint with a data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach any Supervisory Authority.
- International data transfer
In the course of our business and website operations, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside the UK and the EEA. Where we transfer data outside the UK or the EEA, we make sure to use the necessary and appropriate safeguards to ensure that the security of your personal data is maintained and guaranteed. In particular those include standard contractual clauses, binding corporate rules and data processing agreements. If you have any questions relating to our third-party providers, please refer to their relevant Privacy Policies or contact us for further details using firstname.lastname@example.org.
- Storage and retention of your data
We process and store your personal data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period (in particular commercial and tax law) exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
We have implemented technical and administrative security measures to protect your personal data against loss, destruction, manipulation, and unauthorised access. All our employees and service providers working for us are bound by the applicable data protection laws.
Nonetheless, databases or data sets that include personal data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose personal data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after the breach was discovered.
Processing of Automatically Collected Data
a) Collection of access data and log files
We, also collect data on every access to our website. The access data includes the name of the website accessed, 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 security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest in providing an appealing website.
We use the store system Shopify of the service provider Shopify International Limited ("Shopify"), for the purpose of hosting and displaying the shop on the basis of processing on our behalf. All data collected on our website is processed on Shopify's servers. As part of Shopify's services, data may also be transferred to Shopify Inc, 150 Elgin St, Ottawa, ON K2P 1L4, Canada, Shopify Data Processing (USA) Inc, Shopify Payments (USA) Inc or Shopify (USA) Inc as part of further processing on our behalf. In the event that data is transferred to Shopify Inc. in Canada, the appropriate level of data protection is guaranteed. Further processing on servers other than the aforementioned of Shopify will only take place within the framework communicated below. The legal basis for the data processing is our legitimate interest in providing an appealing website and shop.
d) Google Remarketing (Google Ads)
We have integrated Google Remarketing services on our website. Google Remarketing is a function of Google Ads that enables a company to display advertisements to Internet users who have previously visited the company's website. The integration of Google Remarketing thus allows a company to create user-related advertising and consequently to display interest-relevant advertisements to the Internet user.
The purpose of Google Remarketing is to display interest-relevant advertising. Google Remarketing enables us to display advertisements via the Google advertising network or to have them displayed on other Internet pages that are tailored to the individual needs and interests of Internet users.
You have the option to object to interest-based advertising by Google. To do this, the data subject must call up the link www.google.com/settings/ads from any of the internet browsers he or she uses and make the desired settings there.
Data processing when you submit Personal Data to our website and shop
On our website, we offer you the opportunity to register by providing Personal Data. The data is entered in the registration form is transmitted to us and stored and includes your full name, your e-mail address, and your password. We will also send you a verification e-mail to ensure that the account creation is made for the intended person. The processing of the data for this registration thus serves the fulfilment of the contract of use or the implementation of pre-contractual measures. You can delete your account at any time either by using the delete function in your account or by contacting us.
b) Storage of data in your account
For the conclusion and processing of contracts, we require contact details, such as name, delivery and billing address and e-mail address, as well as information on the type of payment method you have chosen. You can store this data in your account. In addition, we use your data to maintain our customer database so that only accurate data is stored by us. In order to avoid typing errors and to ensure that the items you have ordered reach you, we check the completeness and accuracy of your address when you enter it.
Following your order, you will receive a corresponding order confirmation as well as further documents, which we are obliged to provide in order to fulfil our legal information obligations for an effective conclusion of a contract with you.
c) Guest order
You have the option to place your orders as a guest. If you choose this order type, you do not have to register before placing an order. Please note that you will have to enter your data again for each subsequent order.
We collect, process, and use the information you provide in the context of a guest order for the purpose of executing the contract. We store the information you provide for the period of processing and handling your order. Afterwards, your data will be deleted unless you decide to activate your customer account within 14 days after placing your order. Data that we are required to store due to legal, statutory, or contractual retention obligations will be blocked instead of being deleted to prevent it being used for other purposes. The processing of the data serves the fulfilment of the contract with you.
d) Order confirmation/dispatch confirmation
In order to process the contract and provide you with our services, for example the web shop or to send you your order, we use your contact details to send you registration confirmations, customer service information, order confirmations, contract documents or payment processing information. We are obliged to send you these documents in order to comply with our legal information obligations for an effective conclusion of a contract with you. The processing of your data is therefore necessary to fulfil our legal information obligations for an effective conclusion of a contract with you.
e) Legal Obligations
Based on our legal obligation and our legitimate interest, we use and store your Personal Data and technical information to the extent necessary to prevent or prosecute misuse or other illegal behaviour on our website, e.g., to maintain data security in the event of attacks on our IT systems. This also takes place insofar as we are legally obliged to do so, for example due to official or court orders, and for the exercise of our rights and claims as well as for legal defence.
f) Financial Information
To make a purchase, you may need to provide a valid payment method (e.g., credit or debit card). Your payment information will be collected and processed by our authorised payment vendor ShopPay and PayPal. We do not directly collect or store credit or debit card numbers ourselves in the ordinary course of processing transactions. Accordingly, the data is processed on the basis of our contractual relationship.
g) Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. Furthermore, based on our business interests, we store information on tutors, and other business partners, e.g., for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
Disclosure or transfer of Personal Data
We do not transfer or disclose your information to third parties unless there is a legal basis for such disclosure. Example of such a basis is typically consent from you or a legal basis that requires us to disclose the data.
For the operation and optimisation of our website and our shop and for the processing of contracts, various service companies work for us, e.g., for central IT services or the hosting of our website, for the payment and delivery of products, or order fulfilment, to whom we pass on the data required for the fulfilment of the task (e.g., name, address).
Some of these companies act for us by way of commissioned processing and may therefore use the data provided exclusively in accordance with our instructions. In this case, we are legally responsible for appropriate data protection measures at the companies we commission. We therefore agree on specific data security measures with these companies and monitor them regularly.
In contrast, order processing, in these cases we transmit data to third parties for their own use in order to process the contract to the necessary logistics companies and the postal service provider specified when the order was placed.
If we use service providers in third countries, we take additional measures to ensure an adequate level of data protection for the transfer of Personal Data and thus ensure that the transfer is generally permissible and that the special requirements for a transfer to a third country are met (e.g., by concluding standard contracts and additional guarantees, supplementary technical and organisational measures such as encryption or anonymisation).
We will disclose your data to third parties or government agencies within the framework of existing data protection laws if we are legally obliged to do so, e.g., due to official or court orders, or if we are entitled to do so, e.g., because this is necessary for the prosecution of criminal offenses or for the exercise and enforcement of our rights and claims.
Sending information, Advertising and Direct Marketing
We use your data for sending information ordered by you about our offer and other promotions from us to the e-mail address provided by you. If you purchase goods on our website or forget something in your shopping cart, we may send you information on our own similar goods to your specified e-mail address even without your consent. The legal basis for this data processing is our legitimate interest because advertising related products by way of direct advertising represents a legitimate interest for us as a business and the provider of this website. You may object to the processing of your Personal Data for the purpose of direct advertising at any time without giving reasons by unsubscribing via the unsubscribe link at the end of each e-mail or by contacting us.
Insofar as you have also given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
Analysis and Marketing
a) Shopify Statistics
We use the Shopify Statistics feature on our website. This allows us to measure the reach of our website and provides us with statistical analysis of visitor behaviour on our website. The data is processed on servers of Shopify, which we have commissioned with the processing. The legal basis for the data processing in connection with the Shopify statistics function is our legitimate interest in the analysis of user behaviour on our website. You can object to this processing at any time in the cookie settings.
b) Shopify Analytics
Shopify will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Shopify may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Shopify's behalf.
c) Google Tag Manager
We use Google Tag Manager, a web analytics service provided by Google, Inc. This service allows website tags to be managed via an interface. The Google Tag Manager only implements tags. No cookies are set, and no Personal Data is collected. The Google Tag Manager triggers other tags that may collect data. The Google Tag Manager does not access this data. If a deactivation has been made at domain or cookie level, it remains in place for all tracking tags, insofar as these are implemented with the Google Tag Manager. More information on the Google Tag Manager can be found at the following link: http://www.google.com/tagmanager/use-policy.html. The legal basis for this data processing is my legitimate interest.
e) Google Analytics
On the basis of our legitimate interests and your consent (i.e., interest in the analysis, optimisation, and economic operation of our website) Google Analytics, a web analytics service provided by Google Inc. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server and stored there.
Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous user profiles can be created from the processed data.
The IP address transmitted by your browser will not be merged with other data from Google. You can prevent the storage of cookies by setting your browser accordingly. You can also prevent the collection of the data generated by Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
f) Facebook Remarketing (Facebook pixel, Facebook conversion, Facebook ads)
On the same legal basis as Google Analytics, we use so-called "Facebook pixels" of the social network Facebook, which is operated by Meta Platforms Inc. With the help of the Facebook pixels (_fbp and fr), it is possible for Facebook to determine the visitors of our website as a target group for the display of advertisements, so-called "Facebook ads".
You can object to the collection by the Facebook pixels and use of your data for the display of Facebook ads. To do so, you can visit the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads or declare the objection via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/
Miscellaneous and Closing
Automated decision-making including profiling does not take place.
Personal data and children
Our services are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal data from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact.
Online presences in social media
Concerns and Contact