PRIVACY INFORMATION
This privacy policy informs you about how we handle your data. To make the processing of your data transparent, the following information gives you an overview of these processing activities. This privacy policy contains general information about how we handle your data as well as information about your rights under the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG).
CONTENTS
I. General information
II. Data processing on our website
III. Data processing on our Facebook and Instagram pages
IV. Other data processing activities
The controller responsible for data processing is ROY ROBSON FASHION GmbH & Co. KG (hereinafter referred to as “we” or “us”).
I. GENERAL INFORMATION
1. CONTACT
If you have any questions or suggestions regarding this information, or if you would like to contact us to exercise your rights, please address your request to:
ROY ROBSON FASHION GmbH & Co. KG
Bleckeder Landstraße 18–20
21337 Lüneburg
Germany
Tel.: +49 (0) 4131 / 887-0
Email: info@royorbson.com
2. LEGAL BASES
The data protection term “personal data” refers to all information relating to an identified or identifiable natural person.
We process personal data in compliance with the relevant data protection regulations, in particular the GDPR and the BDSG. We only process data on the basis of statutory permission. We process personal data only with your consent (Art. 6(1)(a) GDPR), for the performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR), for compliance with a legal obligation (Art. 6(1)(c) GDPR), or where processing is necessary for the purposes of our legitimate interests or those of a third party, provided that your interests or fundamental rights and freedoms do not override those interests (Art. 6(1)(f) GDPR).
3. STORAGE PERIOD
Unless otherwise stated in the following information, we store data only for as long as is necessary to achieve the purpose of processing or to fulfil our contractual or statutory obligations. Statutory retention obligations may arise in particular from commercial or tax law requirements.
4. CATEGORIES OF DATA RECIPIENTS
We use processors in connection with the processing of your data. Processing operations carried out by such processors include, for example, hosting, maintenance and support of IT systems, customer and order management, order processing, accounting and invoicing, marketing measures, and the destruction of files and data carriers. Processors do not use the data for their own purposes, but process the data exclusively on our behalf and are contractually obliged to ensure appropriate technical and organisational data protection measures.
In addition, we may transmit your personal data to bodies such as postal and delivery services, our bank, tax advisers/auditors, or the tax authorities. Where your data is transmitted to additional recipients, we will inform you in the respective processing section.
5. PROCESSING WHEN EXERCISING GDPR RIGHTS
If you exercise your rights pursuant to Articles 15 to 22 GDPR, we process the personal data transmitted for the purpose of implementing these rights and being able to provide evidence of this. Data stored for the purpose of providing information and preparing such information will only be processed for this purpose and for data protection monitoring purposes; otherwise, processing will be restricted in accordance with Art. 18 GDPR.
This processing is based on Art. 6(1)(c) GDPR in conjunction with Articles 15 to 22 GDPR and Section 34(2) BDSG.
6. YOUR RIGHTS
As a data subject, you have the right to exercise your data subject rights against us. In particular, you have the right to request access to your personal data (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR), and data portability (Art. 20 GDPR). If you have given us consent, you may withdraw it at any time with effect for the future (Art. 7(3) GDPR). If you believe that the processing of personal data concerning you infringes the GDPR, you have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR).
7. RIGHT TO OBJECT
In accordance with Art. 21(1) GDPR, you have the right to object, on grounds relating to your particular situation, to processing based on Art. 6(1)(e) or (f) GDPR. If we process personal data about you for direct marketing purposes, you may object to such processing pursuant to Art. 21(2) and (3) GDPR.
8. DATA PROTECTION OFFICER
You can reach our data protection officer at: datenschutzbeauftragter@royrobson.com
II. DATA PROCESSING ON OUR WEBSITE
When you use the website, we collect information that you provide yourself. In addition, certain information about your use of the website is automatically collected by us during your visit. Under data protection law, an IP address is generally also considered personal data.
1. PROCESSING OF SERVER LOG FILES
When our website is used purely for informational purposes, general information transmitted by your browser to our server is initially stored automatically. This generally includes: browser type/version, operating system used, page accessed, previously visited page (referrer URL), IP address, date and time of the server request, and HTTP status code. Processing is carried out to safeguard our legitimate interests and is based on Art. 6(1)(f) GDPR. This processing serves the technical administration and security of the website. The stored data is deleted after seven days unless further review is necessary due to specific indications of unlawful use.
2. DATA TRANSFER TO THE USA
Visiting our website may involve the transfer of certain personal data to the USA. Where personal data is transferred to third countries, this is done only in accordance with the requirements of the GDPR, for example on the basis of an adequacy decision, standard contractual clauses, or another legally recognised transfer mechanism.
3. DEALER AREA
If, as a dealer, you would like to use our dealer area, for example to download image and film material from our collections, registration via the website is required. Information marked as mandatory is required in order to complete registration. The data provided is processed for the purpose of providing the service. Processing is based on Art. 6(1)(b) GDPR.
4. COOKIES AND COMPARABLE TECHNOLOGIES
RENEW OR CHANGE COOKIE CONSENT
Please use the cookie settings on the website to renew or change your cookie consent.
We use cookies and comparable technologies on our website. Cookies are small text files stored by your browser when you visit a website. This identifies the browser used and allows it to be recognised again by our web server. We use so-called “session cookies”, which are deleted when the browser session ends. Other cookies (“persistent cookies”) are automatically deleted after a predefined period, which may vary depending on the cookie.
Access to information stored on your device, or the storage of information on your device, takes place only where this is technically necessary or where you have given your consent. The legal basis for technically necessary access or storage is Section 25(2) TDDDG. Where consent is required, the legal basis is Section 25(1) TDDDG. Any subsequent processing of personal data is carried out on the basis of the relevant GDPR legal basis stated in this privacy policy.
The use of cookies is partly technically necessary for the operation of our website. We also use cookies and comparable technologies to measure the reach of our website and analyse the use of our website. In addition, we may use cookies and comparable technologies to track user behaviour across websites and devices, provided the required consent has been given.
5. GOOGLE ANALYTICS
We use the Google Analytics service of Google LLC (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to evaluate visits to our website. Google uses cookies and comparable technologies that enable an analysis of your use of our website. It cannot be ruled out that information generated about users’ use of our website will be transferred to and stored in the USA.
The storage of information on your device or access to information on your device in connection with Google Analytics takes place only with your consent pursuant to Section 25(1) TDDDG. The further processing of personal data in connection with Google Analytics is based on your consent pursuant to Art. 6(1)(a) GDPR. You may withdraw your consent at any time with effect for the future through the cookie settings.
6. META PIXEL
We use the Meta Pixel on our website, a Meta Business Tool provided by Meta Platforms Ireland Limited (Meta Platforms Ireland Ltd./EU). Information about Meta’s processing of personal data can be found in Meta’s data policy at https://www.facebook.com/about/privacy.
The Meta Pixel is a JavaScript code snippet that enables us to track the activities of visitors on our website. This tracking is called conversion tracking. For this purpose, the Meta Pixel may collect and process event data such as actions and activities on our website, pixel information, clicked buttons, HTTP header information such as IP addresses, browser information, page location and referrer, and information about the status of disabling or restricting ad tracking.
Some of this event data consists of information stored on the device you use. The storage of information by the Meta Pixel, or access to information already stored on your device, takes place only with your consent pursuant to Section 25(1) TDDDG. The further processing of personal data is based on your consent pursuant to Art. 6(1)(a) GDPR.
7. EMBEDDED THIRD-PARTY SERVICES AND CONTENT
On our website, we use services and content provided by third-party providers. For certain embedded services we use a two-click solution. When the two-click solution is used, no connection to the third-party provider is established initially; instead, a placeholder is first loaded from our own server. Contact with the external server is only established after an additional click on the respective placeholder.
Data processing for optional embedded content takes place with your consent and is based on Art. 6(1)(a) GDPR. Where the embedding requires storage of or access to information on your device, this takes place on the basis of Section 25(1) TDDDG. Technically necessary embedded services may be processed on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR and, where applicable, Section 25(2) TDDDG.
We may embed services such as Google Maps for displaying maps, YouTube for displaying videos, Google Web Fonts for displaying fonts, Google reCAPTCHA for checking whether form entries are made by a natural person, and fonts from Monotype. When using services from providers outside the European Economic Area, a transfer of personal data to third countries may occur in accordance with the applicable GDPR requirements.
III. DATA PROCESSING ON OUR FACEBOOK AND INSTAGRAM PAGES
When you visit our Facebook or Instagram page, through which we present our company or individual products from our range, certain information about you is processed. Facebook Ireland Ltd. (Ireland/EU) is responsible for the processing of personal data carried out through the platform. Further information is available at https://www.facebook.com/privacy/explanation.
1. PROCESSING OF PAGE INSIGHTS
Facebook provides us with anonymised statistics and insights for our Facebook and Instagram pages, which help us understand the types of actions people take on our page (“Page Insights”). This processing serves our legitimate interest in evaluating page interactions and improving our page. The legal basis is Art. 6(1)(f) GDPR.
2. PROCESSING OF DATA PROVIDED TO US VIA OUR PAGE
We also process information that you have provided to us via our Facebook or Instagram page. Such information may include your Facebook/Instagram name, contact details, or a message to us. If your request relates to the conclusion or performance of a contract with us, Art. 6(1)(b) GDPR is the legal basis. Otherwise, we process the data on the basis of our legitimate interest in contacting people who make enquiries (Art. 6(1)(f) GDPR).
IV. OTHER DATA PROCESSING ACTIVITIES
1. CONTACT BY EMAIL
If you send us a message using the contact email address provided, we will process the transmitted data for the purpose of responding to your enquiry. We process this data on the basis of our legitimate interest in contacting people who make enquiries. The legal basis is Art. 6(1)(f) GDPR.
2. CONTRACTUAL RELATIONSHIP
To establish or carry out the contractual relationship with our customers, suppliers, and business partners, it is regularly necessary to process the personal data provided to us, such as the name and contact details of the respective contact persons. The legal basis for this processing is Art. 6(1)(f) GDPR, based on our legitimate interest. Further data processing may take place if you have consented (Art. 6(1)(a) GDPR) or if this serves to fulfil a legal obligation (Art. 6(1)(c) GDPR).
3. EMAIL ADVERTISING
Within the scope permitted by law under Section 7(3) UWG, we are entitled to use the email address you provided when placing an order or registering for direct advertising of our own similar products. If you do not wish this, you may object to the corresponding use of your email address at any time by sending an email to info@royorbson.com or by using the unsubscribe link in our email communication, where available.
4. APPLICATIONS
If you apply to our company, we process your application data exclusively for purposes related to your interest in current or future employment with us and the handling of your application. Your application will only be processed and reviewed by the relevant contacts within our company. If we are unable to offer you employment, we will retain the data you have submitted for up to six months after any rejection, unless statutory provisions prevent deletion, further storage is necessary for evidentiary purposes, or you have expressly consented to longer storage. The legal basis is Section 26(1) sentence 1 BDSG.
5. WP STATISTICS
This website uses the WP Statistics analysis tool to statistically evaluate visitor access. The provider is Veronalabs, ARENCO Tower, 27th Floor, Dubai Media City, Dubai, Dubai 23816, UAE (https://veronalabs.com). With WP Statistics, we can analyse the use of our website. WP Statistics records log files and actions taken by website visitors on the page, such as clicks and views. The data collected with WP Statistics is stored exclusively on our own server and is not passed on to WordPress.
This analysis tool is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in the anonymised analysis of user behaviour in order to optimise both our website and our advertising. If corresponding consent has been requested, for example consent to the storage of cookies, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG; consent may be withdrawn at any time.