Data Security

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Data protection declaration

Unless stated otherwise below, the provision of your personal data is neither legally nor contractually obligatory, nor required for conclusion of a contract. You are not obliged to provide your data. Not providing it will have no consequences. This only applies as long as the processing procedures below do not state otherwise.
“Personal data” is any information relating to an identified or identifiable natural person.

Server log files

You can use our websites without submitting personal data.

Every time our website is accessed, user data is transferred to us or our web hosts/IT service providers by your internet browser and stored in server log files. This stored data includes for example the name of the site called up, date and time of the request, the IP address, amount of data transferred and the provider making the request. The processing is carried out on the basis of Article 6(1) f) GDPR due to our legitimate interests in ensuring the smooth operation of our website as well as improving our services.

Your data may be transferred to third countries outside the European Union for which an adequacy decision has been made by the EU Commission. In the absence of an adequacy decision by the EU Commission, such as for transfers to the USA, the data transfers will be based on standard contractual clauses as appropriate guarantees for the protection of personal data, among other things, available at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_de

Contact

Responsible person
Contact us at any time. The person responsible for data processing is: Ulassa Ltd., Spyrou Kyrpianou Avenue 16, H&S Centre, Office 22, 6058 Larnaca Cyprus, +357 24022126, info@ulassa.com

Proactive contact of the customer by e-mail

If you make contact with us proactively via email, we shall collect your personal data (name, email address, message text) only to the extent provided by you. The purpose of the data processing is to handle and respond to your contact request.

If the initial contact serves to implement pre-contractual measures (e.g. consultation in the case of purchase interest, order creation) or concerns an agreement already concluded between you and us, this data processing takes place on the basis of Article 6(1)(b) GDPR.

If the initial contact occurs for other reasons, this data processing takes place on the basis of Article 6(1)(f) GDPR for the purposes of our overriding, legitimate interest in handling and responding to your request. In this case, on grounds relating to your particular situation, you have the right to object at any time to this processing of personal data concerning you and carried out on the basis of Article 6(1)(f) GDPR.

We will only use your email address to process your request. Your data will subsequently be deleted in compliance with statutory retention periods, unless you have agreed to further processing and use.

Collection and processing when using the contact form

When you use the contact form we will only collect your personal data (name, email address, message text) in the scope provided by you. The data processing is for the purpose of making contact.

Customer account Orders

Customer account

When you open a customer account, we will collect your personal data in the scope given there. The data processing is for the purpose of improving your shopping experience and simplifying order processing. The processing will be carried out on the basis of art. 6 (1) lit. a GDPR with your consent. You can withdraw your consent at any time by contacting us without affecting the legality of the processing carried out with your consent up to the withdrawal. Your customer account will then be deleted.

Collection, processing, and transfer of personal data in orders

When you submit an order we only collect and use your personal data insofar as this is necessary for the fulfilment and handling of your order as well as processing of your queries. The provision of data is necessary for conclusion of a contract. Failure to provide it will prevent the conclusion of any contract. The processing will occur on the basis of Article 6(1) b) GDPR and is required for the fulfilment of a contract with you.

Your data is transferred here for example to the shipping companies and dropshipping providers, payment service providers, service providers for handling the order and IT service providers that you have selected. We will comply strictly with legal requirements in every case. The scope of data transmission is restricted to a minimum.

Evaluations Advertising

Data collection when you post a comment

When you comment on an article or a contribution, we collect your personal data (name, email address, comment text) only in the scope provided by you. The processing serves to allow you to comment and to display comments. By submitting the comment you agree to the processing of the transmitted data. The processing will be carried out on the basis of art. 6 (1) lit. a GDPR with your consent. You can withdraw your consent at any time by contacting us without affecting the legality of the processing carried out with your consent up to the withdrawal. You personal data will then be deleted.

On publication of your comment the name and email address you have enteredwill be published.

On submission of your comment your IP address will also be saved in order to prevent misuse of the comment function and to ensure the security of our IT systems. By submitting the comment you agree to the processing of the transmitted data. The processing will be carried out on the basis of art. 6 (1) lit. a GDPR with your consent. You can withdraw your consent at any time by contacting us without affecting the legality of the processing carried out with your consent up to the withdrawal. Your IP address will then be deleted.

Use of your email address for mailing of newsletters

We use your email address outside of contractual processing exclusively to send you a newsletter for our own marketing purposes, if you have explicitly agreed to this. The processing will be carried out on the basis of art. 6 (1) lit. a GDPR with your consent. You can withdraw your consent at any time without affecting the legality of the processing carried out with your consent up to the withdrawal. You can unsubscribe from the newsletter at any time using the relevant link in the newsletter or by contacting us. Your email address will then be removed from the distributor.

Use of your email address for mailing of direct marketing

We use your email address, which we obtained in the course of selling a good or service, for the electronic transmission of marketing for our own goods or services which are similar to those you have already purchased from us, unless you have objected to this use. You must provide your email address in order to conclude a contract. Failure to provide it will prevent the conclusion of any contract. The processing will be carried out on the basis of art. 6 (1) lit. f GDPR due to our justified interest in direct marketing. You can object to this use of your email address at any time by contacting us. You will find the contact details for exercising your right to object in our imprint. You can also use the link provided in the marketing email. This will not involve any costs other than transmission costs at basic tariffs.

Merchandise management

Use of an external merchandise management system

We use a merchandise management system in the course of order processing for the purposes of contractual processing. For this purpose your personal data as collected in the course of the order will be sent to

JTL-Software-GmbH, Rheinstr. 7, 41836 Hückelhoven, Germany

Payment service providers

Use of PayPal Express

Our website uses the payment service PayPal Express from PayPal (Europe) S.à.r.l. et Cie, S.C.A. (22-24 Boulevard Royal, L-2449 Luxembourg; “PayPal”).

The processing of data enables us to offer you the option of paying via the PayPal Express payment service.

To integrate this payment service it is essential that PayPal collects, stores, and analyses data when you access the website (e.g. IP address, device type, operating system, browser type, device location). Cookies may be used for this purpose. Cookies allow your internet browser to be recognised.

The processing of your personal data is based on Art. 6 para. 1 lit. f GDPR out of our overriding legitimate interest in a customer-oriented offer of different payment methods. On grounds relating to your particular situation, you have the right to object at any time to this processing of personal data concerning you.

By selecting and using “PayPal Express”, the data required for payment processing will be submitted to PayPal to execute the agreement with you using the selected payment method. The data is processed on the basis of Article 6(1)(b) GDPR.

Further information on data processing when using the Paypal Express payment service can be found here in the associated data privacy policy.

The use of PayPal Check-Out
We use the PayPal Check-Out payment service of PayPal (Europe) S.à.r.l. et Cie, S.C.A. (22-24 Boulevard Royal L-2449, Luxembourg; “PayPal”) on our website. The data processing serves the purpose of being able to offer you payment via the payment service. With the selection and use of payment via PayPal, credit card via PayPal, direct debit via PayPal or “Pay Later” via PayPal, the data required for payment processing is transmitted to PayPal in order to be able to fulfill the contract with you with the selected payment method. This processing is based on Art. 6 para. 1 lit. b DSGVO.

Credit card via PayPal, direct debit via PayPal & “Pay later” via PayPal.
For individual payment methods such as credit card via PayPal, direct debit via PayPal or “Pay later” via PayPal, PayPal reserves the right, if necessary, to obtain credit information on the basis of mathematical-statistical methods using credit agencies. For this purpose, PayPal transmits the personal data required for a credit check to a credit agency and uses the information received about the statistical probability of a payment default for a weighed decision on the establishment, implementation or termination of the contractual relationship. The credit information may include probability values (score values), which are calculated on the basis of scientifically recognized mathematical-statistical methods and in the calculation of which, among other things, address data are included. Your interests worthy of protection are taken into account in accordance with the statutory provisions. The data processing serves the purpose of credit assessment for a contract initiation. The processing is carried out on the basis of Art. 6 (1) lit. f DSGVO for our overriding legitimate interest in protecting against payment default when PayPal makes advance payments.
You have the right to object at any time to this processing of personal data relating to you based on Art. 6 (1) (f) DSGVO for reasons arising from your particular situation by notifying PayPal. The provision of the data is necessary for the conclusion of the contract with the payment method requested by you. Failure to provide it will result in the contract not being concluded with the payment method you have chosen.

Local third-party providers
When paying via the payment method of a local third-party provider, the data required for payment processing is transmitted to PayPal. This processing takes place on the basis of Art. 6 para. 1 lit. b DSGVO. For the execution of this payment method, the data may then be forwarded by PayPal to the respective provider. This processing takes place on the basis of Art. 6 para. 1 lit. b DSGVO. Local third-party providers may be, for example:

– Sofort (SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany).
– giropay (Paydirekt GmbH, Stephanstr. 14-16, 60313 Frankfurt am Main, Germany)

Purchase on account via PayPal
When paying via the payment method purchase on account, the data required to process the payment is first transmitted to PayPal. For the execution of this payment method, the data is then transmitted by PayPal to Ratepay GmbH (Franklinstraße 28-29, 10587 Berlin; “Ratepay”) in order to be able to fulfill the contract with you with the selected payment method. This processing is based on Art. 6 para. 1 lit. b DSGVO. Ratepay may conduct a credit check on the basis of mathematical-statistical methods using credit agencies according to the procedure already described above. The data processing serves the purpose of credit assessment for contract initiation. The processing is carried out on the basis of Art. 6 (1) lit. f DSGVO from our overriding legitimate interest in protecting against payment default when Ratepay makes advance payments. For more information on data protection and which credit agencies Ratpay uses, please visit https://www.ratepay.com/legal-payment-dataprivacy/ and https://www.ratepay.com/legal-payment-creditagencies/.

For more information on data processing when using PayPal, please see the associated privacy policy at https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Cookies

Our website uses cookies. Cookies are small text files which are saved in a user’s internet browser or by the user’s internet browser on their computer system. When a user calls up a website, a cookie may be saved on the user’s operating system. This cookie contains a characteristic character string which allows the browser to be clearly identified when the website is called up again.

Cookies will be stored on your computer. You therefore have full control over the use of cookies. By choosing corresponding technical settings in your internet browser, you can be notified before the setting of cookies and you can decide whether to accept this setting in each individual case as well as prevent the storage of cookies and transmission of the data they contain. Cookies which have already been saved may be deleted at any time. We would, however, like to point out that this may prevent you from making full use of all the functions of this website.
Using the links below, you can find out how to manage cookies (or deactivate them, among other things) in major browsers:
Chrome Browser: https://support.google.com/accounts/answer/61416?hl=en
Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Safari: https://support.apple.com/de-de/guide/safari/manage-cookies-and-website-data-sfri11471/mac

technically necessary cookies
Insofar as no other information is given in the data protection declaration below we use only these technically necessary cookies cookies to make our offering more user-friendly, effective and secure. Cookies also allow our systems to recognise your browser after a page change and to offer you services. Some functions of our website cannot be offered without the use of cookies. These services require the browser to be recognised again after a page change.

The use of cookies or comparable technologies is carried out on the basis of Art. 25 para. 2 TTDSG. Processing is carried out on the basis of art. 6 (1) lit. f GDPR due to our largely justified interest in ensuring the optimal functionality of the website as well as a user-friendly and effective design of our range of services.
You have the right to veto this processing of your personal data according to art. 6 (1) lit. f GDPR, for reasons relating to your personal situation.

Use of Borlabs Cookie
Our website uses the consent management tool Borlabs Cookie from Borlabs – Benjamin A. Bornschein (Georg-Wilhelm-Str. 17, 21107 Hamburg, Germany; “Borlabs”).
The tool enables you to grant consents to data processing via the website, in particular the placing of cookies, and to make use of your right of revocation for consents already granted.
The processing of data serves the purpose of obtaining necessary consents for data processing and to document these, thereby complying with statutory obligations.
Cookies may be deployed for this purpose. The following information, among others, can be collected: Date and time the page was viewed, information about the browser and device you are using, UID (randomly assigned anonymous ID), opt-in and opt-out data. This data will not be passed on to third parties.
The data processing is carried out on the basis of Article 6(1)(c) GDPR to comply with a legal obligation.
More information on data protection at Borlabs can be found at: https://de.borlabs.io/borlabs-cookie/

Analysis Communication Partner program

Use of the Google Analytics
Our website uses the web analysis service Google Analytics from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”).
The processing of data serves to analyse this website and its visitors and for marketing and advertising purposes.
Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity and to provide other services to the website operator relating to website and internet use. In this process the following information, inter alia, can be collected: IP address, date and time of the website access, click path, information on the browser and the device you are using, the pages visited, referrer URL (website via which you accessed our website), location data, purchasing activities. The IP address transmitted from your browser within the scope of Google Analytics is not associated with any other data held by Google.
Google Analytics uses technology such as cookies, web storage in the browser and tracking pixels which enable an analysis of your use of the website. The information generated by these regarding your use of this website is usually transferred to a Google server in the USA and stored there. Google relies on standard contractual clauses as suitable guarantees for the protection of personal data, available at: https://policies.google.com/privacy/frameworks and https://business.safety.google/adsprocessorterms/.Both Google and the US government authorities have access to your data. Google may combine your data with other data, such as your search history, personal accounts, usage data from other devices and any other information Google has about you.

IP anonymisation is activated on this website. Google uses this to shorten your IP address beforehand within Member States of the European Union or in other signatories to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.

The use of cookies or comparable technologies is carried out with your consent on the basis of Art. 25 para. 1 p. 1 TTDSG in conjunction with Art. 6 para. 1 lit. a GDPR. The processing of your personal data is carried out with your consent on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time without affecting the legality of the processing carried out with your consent up to the withdrawal.
You can find more detailed information on the terms and conditions of use and data protection at https://www.google.com/analytics/terms/de.html and/or at https://www.google.de/intl/de/policies/ and at https://policies.google.com/technologies/cookies?hl=de.

Use of Zoom
For the execution of our online seminars/courses (hereinafter referred to as: online seminars) within the framework of an agreement for the processing of orders, we use the video conferencing tool Zoom from Zoom Video Communications, Inc. (55 Almaden Boulevard, San Jose, CA 95113, USA; “Zoom”).
You can participate in our online seminars via the Zoom app (after downloading it from the provider’s website) or via the browser version on the provider’s website. In order to participate in our online seminars, it is therefore necessary to visit the website of the provider Zoom at least once. Zoom is responsible for processing your data there.
We are responsible for the processing of your personal data in connection with our online seminars.
This data processing serves the purposes of conducting our online seminar as well as preparing and following up. For this purpose, we collect and process the following aspects of your personal data: name, e-mail address, password (if no single sign-on was used), IP address, information about the device used, date/time of the online seminar and, in case of telephone dial-up, the incoming and outgoing telephone number and country. The provision of this data is necessary for the fulfilment of the agreement concluded between you and us for the provision of the online seminar. Failure to provide this data means that you cannot participate in our online seminar.
Furthermore, we collect and process text entries made by you during the online seminar as well as video and audio transmissions of your device. You can deactivate your camera and microphone before entering the online seminar and at any time during the online seminar. In this case, no data will be recorded. If you do not want to provide data via the chat, camera or audio function, you will not be able to actively participate in the online seminar or communicate with other participants.
If we record our online seminars for follow-up purposes, in particular for subsequent provision to the respective participants, you will be informed separately before the start of the online seminar. You will also recognise a recording by the identification during the online seminar. During a recording, your name, any text entries made in the chat as well as video/audio transmissions of your device will be saved and, if necessary, subsequently transmitted to the respective participants of the online seminar.
The data collected during the execution of our online seminars are transmitted to Zoom and thus to the USA within the framework of the order processing contract.
The processing will occur on the basis of Article 6(1) b) GDPR and is required for the fulfilment of a contract with you.
Further information on data processing when using Zoom can be found at: https://zoom.us/de-de/privacy.html

Using the Amazon Partner Program
We use the “AmazonPartnerNet” partner program from Amazon EU S.a.r.l. (5 Rue Plaetis, L-2338 Luxembourg; “Amazon”).
We have configured advertising on our website as links to offers on various Amazon websites. Amazon uses cookies. These cookies ensure the correct billing for the partner program. By using cookies Amazon can identify when you have clicked on an advertising link and can trace the origin of an order generated via the advertising link.
The data processing, particularly the setting of cookies, is carried out on the basis of Article 6(1)(f) GDPR due to our overriding legitimate interest in measuring the success of partner advertising and thereby the correct billing of commissions as part of the partner program. On grounds relating to your particular situation, you have the right to object at any time to this processing of personal data concerning you and carried out in accordance with Article 6(1)(f) GDPR.
You can prevent the storage of cookies by choosing corresponding technical settings in your internet browser; we would, however, like to point out that this may prevent you from making full use of all the functions of this website. You then won’t be included in the conversion tracking statistics.
The data privacy policy with detailed information on the use of the data by Amazon can be found at https://www.amazon.de/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=3312401

Plug-ins

Use of the Google Tag Manager
Our website uses the Google Tag Manager from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “Google”). This application manages JavaScript tags and HTML tags which are used in particular to implement tracking and analysis tools. The data processing serves to facilitate the needs-based design and optimisation of our website. The Google Tag Manager itself neither stores cookies nor processes personal data. It does, however, enable the triggering of further tags which may collect and process personal data. You can find more detailed information on the terms and conditions of use and data protection at https://www.google.com/intl/de/tagmanager/use-policy.html

Use of YouTube
Our website uses the function for embedding YouTube videos by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; “YouTube”). YouTube is a company affiliated with Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).
This feature shows YouTube videos in an iFrame on the website. The option “advanced privacy mode” is enabled here. This prevents YouTube from storing information on visitors to the website. It is only if you watch a video that information is transmitted to and stored by YouTube. Your data may be transmitted to the USA. For the USA, no adequacy decision from the EU Commission is available.

The data transfer takes place, among other things, on the basis of standard contractual clauses as suitable guarantees for the protection of personal data, which can be viewed at: https://policies.google.com/privacy/frameworks.

The use of cookies or comparable technologies is carried out with your consent on the basis of Art. 25 para. 1 p. 1 TTDSG in conjunction with Art. 6 para. 1 lit. a GDPR. The processing of your personal data is carried out with your consent on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time without affecting the legality of the processing carried out with your consent up to the withdrawal.
Further information on the data collected and used by YouTube and Google and your associated rights and options for protecting your privacy can be found in YouTube’s privacy policy (https://www.youtube.com/t/privacy).

Rights of persons affected and storage duration

Duration of storage

After contractual processing has been completed, the data is initially stored for the duration of the warranty period, then in accordance with the retention periods prescribed by law, especially tax and commercial law, and then deleted after the period has elapsed, unless you have agreed to further processing and use.

Rights of the affected person

If the legal requirements are fulfilled, you have the following rights according to art. 15 to 20 GDPR: Right to information, correction, deletion, restriction of processing, data portability. You also have a right of objection against processing based on art. 6 (1) GDPR, and to processing for the purposes of direct marketing, according to art. 21 (1) GDPR.

Right to complain to the regulatory authority

You have the right to complain to the regulatory authority according to art. 77 GDPR if you believe that your data is not being processed legally.

Right to object

If the data processing outlined here is based on our legitimate interests in accordance with Article 6(1)f) GDPR, you have the right for reasons arising from your particular situation to object at any time to the processing of your data with future effect.

If the objection is successful, we will no longer process the personal data, unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests or rights and freedoms, or the processing is intended for the assertion, exercise or defence of legal claims.

If personal data is being processed for the purposes of direct advertising, you can object to this at any time by notifying us. If the objection is successful, we will no longer process the personal data for the purposes of direct advertising.

last update: 29.11.2022