Privacy Statement
Introduction
We, Wortmann Fashion Retail GmbH & Co. KG, as the operator of the online offer, are responsible for processing the personal data of the users of the online offer. You will find our contact data in the imprint of the online offer, the contact persons for questions regarding the processing of personal data are named directly in this privacy statement.
We take the protection of your privacy and your private data very seriously. We collect, store and use your personal data only in accordance with the contents of this privacy statement and the applicable data protection regulations, in particular the European General Data Protection Regulation (GDPR) and the national data protection regulations.
With this privacy policy, we would like to inform you to what extent and for what purpose personal data is processed in connection with the use of the online offer.
Personal data
Personal data is information about an identified or identifiable natural person. This includes all information about your identity, such as your name, e-mail address or postal address. Information that cannot be associated with your identity (e.g. statistical information, such as the number of users of the online offer) is not considered personal information.
You can use our online offer without disclosing your identity or personal data. We will then only collect general information about your visit to our website. However, personal data is collected from you for some of the services offered. This data will then only be processed by us for the purposes of using this online offer, in particular for providing the desired information. When collecting personal data, only the data that is absolutely necessary must be provided. Further information may also be provided on a voluntary basis. In each case, we point out whether it concerns obligatory fields or voluntary data. We will then inform you about the specific details in the corresponding section of this privacy policy.
Your personal data is not processed according to an automated decision-making process in connection with the use of our online offer.
Processing of personal information
Your data will be stored by us on specially protected servers within the European Union. These servers are protected against loss, destruction, access, modification or distribution of your data by unauthorised persons by means of technical and organisational measures. It is only possible for a few authorised persons to access your data. They are responsible for the technical, commercial or editorial support of the servers. Despite regular checks, however, it is not possible to completely protect against all risks.
Your personal data is transmitted in encrypted form via the Internet. We use SSL encryption (Secure Socket Layer) for data transmission.
Transfer of personal data to third parties
We generally only use your personal information to provide the services you have requested. Insofar as external service providers are used by us within the scope of the provision of services, they can also only access the data for the purpose of the provision of services. Through technical and organisational measures, we ensure compliance with data protection regulations and also oblige our external service providers to do so.
Furthermore, we will not pass the data on to third parties without your express consent, in particular not for advertising purposes. Your personal data will only be passed on if you yourself have consented to the data being passed on or if we are entitled or obliged to do so on the basis of legal regulations and/or official or court orders. In particular, this may involve providing information for law enforcement, security purposes or the enforcement of intellectual property rights.
Legal bases of data processing
Insofar as we obtain consent for the processing of your personal data, Art. 6 Para. 1 (a) GDPR serves as the legal basis for data processing.
Insofar as your personal data are processed because this is necessary for the fulfilment of a contract or within the framework of a contract-like relationship with you, Art. 6 Para. 1 (b) GDPR serves as the legal basis for data processing.
Insofar as we process your personal data to fulfil a legal obligation, Art. 6 Para. 1 (c) GDPR serves as the legal basis for data processing.
Art. 6 Para. 1 (f) GDPR may also be used as a legal basis for data processing if the processing of your personal data is necessary to safeguard a legitimate interest of our company or a third party and your interests, fundamental rights and freedoms do not require the protection of personal data.
Within the framework of this privacy policy, we always point out the legal basis on which we base the processing of your personal data.
Data deletion and storage time
We always delete or block your personal data if the purpose of storage ceases to apply. However, data may also be stored if this is provided for by legal requirements to which we are subject, for example with regard to statutory storage and documentation obligations. In such a case we delete or block your personal data after the end of the corresponding specifications.
Use of our online offer
Information about your computer
Each time you access our online offer, we collect the following information about your computer, regardless of your registration: your computer’s IP address, the request from your browser and the time of this request. In addition, the status and the amount of data transferred are recorded within the scope of this request. We also collect product and version information about the browser and the computer operating system used. We also record the website from which the online offer was accessed. Your computer’s IP address is only stored for the time of use of the online offer and is subsequently deleted or made anonymous by shortening it. The remaining data is stored for a limited period of time.
We use this data for the operation of the online offer, in particular to detect and eliminate errors, to determine the utilisation of the online offer and to make adjustments or improvements. These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR, which is the legal basis for such processing.
Use of cookies
Cookies are used for our online offer – as on many websites. Cookies are small text files that are stored on your computer and that store certain settings and data for exchange with the online offer from us via your browser. A cookie usually contains the name of the domain from which the cookie file was sent, information about the age of the cookie and an alphanumeric identifier.
Cookies enable us to recognise your computer and to make any settings available immediately. Cookies help us to improve our online offer and to offer you a better and even more customised service. This also includes our legitimate interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR.
The cookies we use are session cookies, which are automatically deleted after the end of the browser session. Occasionally, cookies with a longer storage period can also be used so that your preliminary settings and preferences can still be taken into account the next time you visit our website.
Most browsers are set to automatically accept cookies. However, you can disable the storage of cookies or set your browser so that it informs you as soon as cookies are sent. It is also possible to manually delete cookies that have already been saved using the browser settings. Please note that you may only be able to use our online offer to a limited extent or not at all if you refuse the storage of cookies or delete necessary cookies.
Google Analytics
We use Google Analytics for statistical evaluations. Google Analytics is a web analysis service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94034, USA ("Google"). Google Analytics uses cookies, which are text files placed on your computer to help analyse how you use the website. The information generated by the cookies concerning your use of this website is usually transmitted to and stored by Google on a server in the United States. If you activate IP address anonymisation on this website, your IP address will be shortened beforehand within member states of the European Union and other states that are a party to the Agreement on the European Economic Area. In exceptional cases only, the full IP address will be sent to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to analyse how you use the website in order to compile reports about the website activities and provide the website operator with further services linked to use of the website and the Internet. The IP address transmitted from your browser through the use of Google Analytics will not be linked to other data from Google. You can prevent the installation of cookies by activating the relevant setting in your browser software. However, if you do so, you may not be able to use all the functions of this website. You can also prevent Google from collecting and processing the data generated by the cookie relating to your use of the website (including your IP address) by downloading and installing the browser plug-in under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
For further information on this subject, please see https://tools.google.com/dlpage/gaoptout?hl=en or https://support.google.com/analytics/answer/6004245?hl=en (general information about Google Analytics and data protection). We would like to point out that on our website Google Analytics has been extended to include the code "anonymizeIp();" in order to make the IP addresses anonymous, whereby the last octet is deleted.
We believe that, due to the protective measures taken (anonymisation and the possibility of objection), data processing for the optimisation of our online offer is to be regarded as a legitimate interest in data processing in accordance with Art. 6 Para. 1 (f) GDPR.
Google Enhanced Conversion Tracking
For our website, we use the Google Enhanced Conversion Tracking service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google Enhanced Conversions complement the conversion tags used up to this point. Conversion tracking is used to compile statistics regarding the total number of website users and to acquire information about what actions they have taken. With the help of the enhanced conversions, conversions can be recorded even more precisely. Conversion data relating to our website, which is supplied by the user and collected by us as the party responsible for the website, may be sent to Google in encrypted form by means of extended conversions. Website visitors' data is encrypted by means of a one-way hash algorithm, SHA256, and does not enable conclusions to be drawn regarding the individual in question. Extended conversions are used for customers who have provided data such as an email address, name, home address or telephone number themselves, for example, when creating a customer account. This information is used to assign customers to the Google accounts in which they were logged in when they interacted with the website. In this context, it cannot be ruled out that data will be transmitted to the USA and that US security authorities may be able to access this data. For more information, please see the Google Privacy Policy at https://policies.google.com/privacy?gl=de and at https://support.google.com/google-ads/answer/9888656?hl=de.
Webtrekk
We use the services of Webtrekk GmbH, Robert-Koch-Platz 4, 10115 Berlin (www.webtrekk.com) for statistical evaluations. Webtrekk GmbH is certified by TÜV Saarland for data protection in the area of web controlling software. Within the scope of certification, the collection and processing of tracking data was checked for data protection conformity and data security.
During your visit to our website, information transmitted by your browser is collected and evaluated for our web controlling. The data is collected by means of a pixel that is linked to every website, as well as by the use of cookies.
The collected data is used to create anonymous user profiles that are used as the basis for web statistics. In this case, however, there is no personal identification of individual users or a combination with other data.
The compilation of web statistics is our legitimate interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR.
The collection and storage of data by Webtrekk GmbH may be revoked at any time with effect for the future. To do so, please click on the following link: Click here to opt out of tracking. By confirming the link, an opt-out cookie is set on your computer.
Amplitude
We also use the Amplitude analysis service from the provider Amplitude Inc, 501 2nd Street, Suite 100 San Francisco, CA 94107, USA, on our website to analyse usage.
When you use the service, your order number and your IP address are recorded in anonymised form. In addition, the service records several parameters such as clicks and page views to analyse the use of our online offering. This statistical data is used to evaluate the use of our online offering and thus optimise your visitor experience. If the order number is not recorded, only analyses without any personal reference are carried out. Further information on data protection at Amplitude can be found at: https://amplitude.com/privacy
The legal basis for the use of Amplitude is your consent in accordance with Art. 6 para. 1 lit. a) GDPR. You can withdraw your consent at any time with effect for the future. If the order number is not recorded, the legal basis is our legitimate interest in an optimised design of our online offer in accordance with Art. 6 para. 1 lit. f) GDPR.
Retargeting and remarketing
Retargeting or remarketing refers to technologies in which users who have previously visited a certain website are still shown suitable advertising even after leaving this website. For this to work, it needs to be possible to recognise Internet users beyond their own website, for which cookies of the corresponding service provider are used; in addition, the previous usage behaviour is taken into account. For example, if a user looks at certain products, these or similar products can later be displayed as advertisements on other Internet pages. It is personalised advertising adapted to the needs of individual users. For this personalised advertising, it is not necessary for the user to be identified beyond recognition. The data used for retargeting or remarketing is therefore not combined with any other data.
We use such technologies to place advertisements on the Internet. We use third-party providers for the placement of advertisements. Amongst others, we use offers from Google, which enables the automatic display of products of interest to Internet users. This function is implemented by means of cookies. For further information about this technology, please refer to Google’s privacy policies at https://policies.google.com/privacy?hl=en. The installation of cookies for Google Remarketing and Google AdWords Conversion Tracking can be prevented by applying a setting in the respective browser software by accessing the website https://policies.google.com/technologies/ads?hl=en and changing the corresponding setting.
The placement of advertising is our legitimate interest in data processing pursuant to Art. 6 Para. 1 (f) GDPR.
Registration
You can register to use our online services. To do this, you need to provide the data requested during registration, for example name, address and e-mail address. We also record the date and time of registration and the IP address. As part of the registration process, we obtain your consent for the use of the data. The advantage for you is that you do not have to enter this data again each time you use or place an order.
The legal basis for the processing of data for registration in the case of consent is Art. 6 Para. 1 (a) GDPR. If you register with us in order to fulfil or initiate a contract, the legal basis for processing the data is also Art. 6 Para. 1 (b) GDPR.
The information requested in the context of registration as a mandatory field is required for the fulfilment or initiation of a contract with us for certain services. However, you are not obliged to register as you can also order as a guest. In this case, however, you must enter all data required to process the contract with each order.
If you register, a customer account will be created for you. The data in the customer account are stored with us as long as an active customer relationship exists. If no activity can be determined for a period of three years, the status of the customer relationship is set to inactive. You can request the deletion of your customer account at any time.
Social login
To register and log in to our website, you may also use your existing profile with the social network Facebook (Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA) or with Google (Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland). For this purpose, when registering or logging in, please click on the relative symbols of Facebook or Google. By clicking on the respective symbol a new window will be opened in which you can log in to the relative provider. There, you will also be informed which data will be forwarded for the purpose of authentication and for registration or log-in. Based on your consent, further data from your profile may also be forwarded to us. We then use these data (such as your age or ‘like’ activity) to optimise our web pages and adapt them to your interests. The legal basis for data processing is your consent pursuant to Art. 6(1) letter a) GDPR.
For the purposes of authentication, a link is created between your device and the servers of the respective providers. In this way, the provider is informed in particular of your IP address, and may also receive other information about your device. We have no influence on the relative processing of data by the provider. In this respect, the privacy policy of the respective provider applies:
Facebook: http://www.facebook.com/policy.php
Google: https://policies.google.com/privacy
Order processing
We use your personal information for orders only within our company and affiliated companies and with the company commissioned to process orders.
Storage and data transfer for orders
For order processing, we work together with various companies that are responsible for payment processing and logistics. We ensure that our partners also comply with data protection regulations. We pass on your address data (name and address) to the respective transport company that delivers the ordered products to you. The legal basis for this is Art. 6 Para. 1 (b) GDPR. The processing of your personal data is necessary to fulfil the contract with you.
The data will be stored by us for as long as it is necessary to fulfil the contract. In addition, we store this data for the fulfilment of post-contractual obligations and on the basis of commercial and tax retention periods for the legally prescribed period. As a rule, this retention period is 10 years to the end of the respective calendar year.
Payment processing for orders, PayPal, Klarna
Depending on the chosen payment method, payment processing for orders may be carried out through the involvement of a service provider.
When paying by credit card, your required data such as name, address and purchase data will be forwarded to the respective credit card company.
If you pay via PayPal, you will be redirected to the PayPal website via a link. Your personal data will then be processed. This includes your name, your address, your e-mail address, telephone number, if applicable, as well as account or credit card data. Please note the general terms and conditions of business, terms of use and privacy policies of PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg on the website www.paypal.com.
In order to be able to offer you Klarna's payment options, we will transfer personal data, such as contact details and order details, to Klarna. This will enable Klarna to assess whether you can use the payment options offered by Klarna and to adapt the payment options to your needs. General information about Klarna can be found here. Your personal data will be treated by Klarna in accordance with the applicable data protection regulations and in accordance with the information in Klarna's Privacy Policy .
The legal basis for payment processing is Art. 6 Para. 1 (b) GDPR. The processing of your personal data is necessary for the fulfilment of the contract with you, whereby the method of payment can be freely chosen by you.
The data will be stored by us for as long as it is necessary to fulfil the contract. In addition, we store this data for the fulfilment of post-contractual obligations and on the basis of commercial and tax retention periods for the legally prescribed period. As a rule, this retention period is 10 years to the end of the respective calendar year.
Credit check
Depending on the chosen payment method, it may be necessary to check your creditworthiness. In this case, we will use external service providers to whom we send your data (name, address, date of birth, order value) if you have given your consent for a credit check. We transmit the data to REAL Solution Factoring GmbH, Normannenweg 32, 20537 Hamburg
The legal basis for the credit check is Art. 6 Para. 1 (a) GDPR. If you do not wish to give your consent to the credit check, you may have to select another payment method.
As part of the credit check, an estimate is obtained as to the probability of default with regard to our receivable from the purchase order. We only receive a probability value (score value) from our service provider, but no further details. On the basis of this value we will then evaluate whether the desired payment method can be offered. After completion of the check, the score value is deleted from our system and not saved within the framework of the order data. It is therefore also not possible for us to subsequently evaluate why, for example, a certain payment method was not possible.
Communication with us
You can contact us in various ways, including through the contact form on our website. You are also welcome to receive our newsletter by e-mail on a regular basis.
Contact form
If you wish to use the contact form in our online offer, we collect the personal data you provide in the contact form, in particular your name and e-mail address. We also store the IP address and the date and time of the request. We process the data transmitted via the contact form exclusively for the purpose of being able to answer your inquiry or your request.
You can decide for yourself what information you want to send us via the contact form. The legal basis for the processing of your data is your consent pursuant to Art. 6 Para. 1 (a) GDPR.
After we have dealt with the matter, the data will initially be stored in the event of any queries. Deletion of the data can be requested at any time, otherwise the data is deleted after complete settlement of the matter; legal storage obligations remain unaffected in each case.
Newsletter
When you subscribe to our newsletter, your e-mail address will be used for our own advertising purposes until you unsubscribe. You will receive regular information by e-mail on current topics and e-mails for special occasions, for example special promotions. The e-mails can be personalised and individualised based on our information about you.
If you have not given us your written consent to subscribe to our newsletter, we will use the double opt-in procedure, i.e. we will not send you a newsletter by e-mail until you have expressly confirmed to us beforehand that we should send the newsletter. We will then send you a notification e-mail and ask you to confirm that you would like to receive our newsletter by clicking on a link contained in this e-mail.
Within the scope of displaying the newsletter and accessing individual links from the newsletter, information is collected and evaluated, which is transmitted automatically. For this purpose, a cookie with unlimited duration is set the first time a link is accessed from the newsletter. If the cookie has been deleted in the meantime or you use another browser, the cookie is saved again. With the help of cookies you are recognised and your user behaviour can be evaluated on our Internet pages. The data collected is used to create personal user profiles. In this way we aim to constantly improve the service for you and to inform you even more individually about suitable offers and promotions. The links in the newsletter contain a random but unique identification number. We or external service providers who work for us may collect and store this number when you access these links from your computer to retrieve additional information from our website. The number in the links will not be merged with your name and other personally identifiable information without your express consent. You can object to the collection and evaluation of the use of links described above by clicking on [Opt-Out-Link]. If you exercise this option, an anonymous opt-out cookie is stored in your browser, which informs you of your objection and thereby prevents data collection. The opt-out cookie remains effective in the browser you are using until you delete it with the help of this browser. However, if you delete the cookie or use another browser or computer, we will no longer be able to recognise that you have declared such an objection. The evaluation of the use of the newsletter and your consent to receive the newsletter are not affected by this.
The legal basis for the processing of your data is your consent pursuant to Art. 6 Para. 1 (a) GDPR, if you have expressly registered for the newsletter. Within the framework of legal requirements, it may also be possible for you to receive our newsletter without our express consent, because you have ordered goods or services from us, we have received your e-mail address in this connection and you have not objected to receiving information by e-mail. In this case, our legitimate interest in transmitting direct mail pursuant to Art. 6 Para. 1 (f) GDPR is to be regarded as the legal basis.
If you no longer wish to receive newsletters from us, you can revoke your consent at any time with effect for the future or object to further receipt of the newsletter without incurring any costs other than the transmission costs according to the basic tariffs. Simply use the unsubscribe link contained in each newsletter or send a message to us or our data protection officer.
Social media
On our website you will find links to the social networks Facebook, Instagram, Pinterest and the video portal YouTube. You can recognise the links from the respective provider's logo.
Clicking on the links will open the corresponding social media pages to which this privacy policy does not apply. Please refer to the privacy policies of the individual providers for details of the provisions applicable there; you will find these under:
http://www.facebook.com/policy.php
https://help.instagram.com/155833707900388
https://about.pinterest.com/en/privacy-policy
No personal information is transmitted to the respective providers before the corresponding links are accessed. Your access to the linked page is also the basis for data processing by the respective providers.
Your rights and contact
We attach great importance to explaining the processing of your personal data as transparently as possible and also to informing you about the rights to which you are entitled. If you require further information or wish to exercise the rights to which you are entitled, you can contact us at any time so that we can take care of your request.
Rights of persons concerned
You have extensive rights regarding the processing of your personal data. First of all, you have a comprehensive right to information and can request the correction and/or deletion or blocking of your personal data if necessary. You may also request a limitation of the processing and have a right of objection. You also have a right to data transferability with regard to the personal data you have provided to us.
If you wish to assert any of your rights and/or receive further information, please contact our customer service. Alternatively, you can also contact our data protection officer.
Revocation of consent and objection
Once you have given your consent, it can be freely revoked at any time with effect for the future. The revocation of consent shall not affect the legality of the processing carried out on the basis of the consent until revocation. The contact person for this is also our customer service and our data protection officer.
If the processing of your personal data is not based on consent, but on another legal basis, you can object to this data processing. Your objection will lead to a review and, if necessary, termination of data processing. You will be informed of the results of the review and – if data processing is nevertheless to be continued – we will provide you with more detailed information as to why data processing is permissible.
Data protection officer and contact
We have appointed an external data protection officer who supports us in data protection issues and whom you can also contact directly. Our data protection officer and his team will be happy to answer your questions regarding our handling of personal data or further information on data protection issues:
RA Dr. Sebastian Meyer, LL.M.
c/o BRANDI Rechtsanwälte
Adenauerplatz 1, 33602 Bielefeld
Phone: +49 (0)521 / 96535-812
E-mail: dataprotection@wortmann-retail.com
If you would like to contact our data protection officer personally by e-mail, you can also reach him at sebastian.meyer@brandi.net.
Complaints
If you believe that we are not processing your personal data in accordance with this privacy policy or the applicable privacy policy, you may complain to our data protection officer. The data protection officer will then examine the matter and inform you of the result of the examination. You also have the right of appeal to a supervisory authority.
Further information and changes
Links to other websites
Our online offer may contain links to other websites. These links are usually marked as such. We do not have any influence on the extent to which the applicable data protection regulations are observed on the linked websites. We therefore recommend that you also find out about the respective privacy policies on other websites.
Changes to this privacy policy
The version of this privacy policy is shown by the date indicated (below). We reserve the right to change this privacy policy at any time with effect for the future. Changes are made in particular in the event of technical adjustments to the online offer or changes to data protection regulations. The current version of the privacy policy can always be accessed directly via the online offer. We recommend that you regularly find out about changes to this privacy policy.
Privacy policy version: May 2020