Data Protection Policy

Data Protection

This Data Protection Policy refers to the nature, scope and purpose of personal data processing (hereinafter referred to as “data”) relating to our websites, features and content thereof, as well as the external presence such as our social media profiles (collectively referred to as “online offer”). With regard to the terminology used, e.g. “processing” and “controller”, we refer to the definitions stimulated in Article 4 of the General Data Protection Regulation (GDPR).

Collection, Processing & Use of Personal Data

Types of Processed Data:

  • Personal data (e.g. name, address).
  • Contact data (e.g. email address, telephone number).
  • Content data (e.g. text input, images, videos).
  • Usage data (e.g. websites visited, interest in content, access time).
  • Meta and communications data (e.g. device information, IP addresses)

Categories of Data Subjects

  • Visitors and users of the online offer (hereinafter referred to as “user”).
  • Customers utilising our website (hereinafter referred to as “user”).

Processing Purposes

  • Provision of the online offer, its functions and content.
  • Processing of all orders including the related physical processes, in particular, that of package dispatch and in respect to the possible reverse transaction in case of warranty.
  • Responding to contact requests and communication with users.
  • Security measures
  • Audience measurement/marketing

Definitions

“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

In accordance with Article 13 of the GDPR, we provide information in regard to the legal basis of our data processing. Provided the legal basis in the data protection statement is mentioned, the following applies: The legal basis for obtaining consent is Article 6 paragraph letter 1 and Article 7 of the GDPR, the legal basis for the processing for the fulfilment of our services and the execution of contractual measures as well as the answer to inquiries is Article 6 paragraph 1 letter b of the GDPR, the legal basis for the processing in order to fulfil our legal obligations is article 6 (1) letter c of the GDPR, and the legal basis for the processing in order to safeguard our legitimate interests is Article 6 (1) letter. f of the GDPR. Processing is necessary in order to protect the vital interests of the data subject or of another natural person as stated in Article 6 paragraph 1 letter d of the GDPR.

Withdrawal

You have the right to consent according to. Art. 7 para. 3 of the GDPR. This right to consent also applies to data processed in the future.

You may at any time object to the future processing of your data in accordance with Art. 21 of the GDPR. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Rights of the Data Subject

The user shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the controller shall provide a copy of the personal data undergoing processing as in accordance with Article 15 of the GDPR.

The user shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data or incomplete personal data concerning him or her in accordance with Article 16 of the GDPR.

The user shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay in accordance with Article 17. The user shall have the right to obtain from the controller restriction of processing of personal data in accordance with Article 18 of the GDPR.

The user shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided in accordance with Article 20 of the GDPR.

The user shall have the right to lodge a complaint with a supervisory authority in accordance with Article 77 of the GDPR.

Data Usage for Advertising Purposes

Your personal data is used to improve your shopping experience and shape it to suit your requirements. The information used to achieve this is the data already available to us, e.g. via your internet connection, the chosen end device, the operating system, the date, the time at which our website was visited or the pages accessed as well as information that was provided to us by you. You may object to the use of your personal data for advertising purposes at any time. A notification via email, letter or fax would suffice. You can find our contact details here.

Cookies

Cookies are small text files that are stored on a user’s computers. Different types of information can be stored within the text files. A cookie is primarily used to store information about a user (i.e. the device on which the cookie is stored) during or after their visit on a website. Session cookies are cookies that are deleted after a user leaves a website and closes the browser. In the case of session cookies, the contents of a shopping cart in an online shop or a login status are saved. Persistent cookies remain stored even after the browser has been closed. Thus, a login status, for instance, will be saved if the user visits the website after several days. Likewise, user interests can be stored which as used for range measurement or marketing purposes. A third-party cookie refers to cookies that are offered by providers that do not manage the website that is being visited. Cookies offered by the person that manages the website are called first-party cookies.

We can use session or persistent cookies and clarify these in the context of our privacy policy.

The user is requested to disable the settings in their browser if they do not want any cookies stored, Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of the website being visited.

A general contradiction explaining the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookie can be switched off in the browser settings. Please note that, once the settings have been changed, not all the features available on this website may be used.

Google Analytics with “Anonymize IP” Extention

Based on our legitimate interests (i.e. interest in the analysis, optimisation and economical operation of our online offering pursuant to Art. 6 (1), letter f. GDPR), we use Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookies regarding the use of the online offering by the user is generally transmitted to a Google server in the USA where it is stored.

Google is certified under the Privacy Shield agreement and thereby guarantees compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google uses this information on our behalf in order to evaluate the use of our online offering by the users, compile reports about the activities within this online offering and provide us with additional services related to the use of this online offering and the internet. In doing so, pseudonymised usage profiles for the users may be prepared from the processed data.

We only use Google Analytics with activated IP anonymisation. This means that the IP address of users within member states of the European Union or other states in the European Economic Area is shortened by Google. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there.

The IP address transferred by the user’s browser is not combined with other data by Google. Users can prevent the storage of cookies by configuring the settings of their browser software accordingly. Furthermore, users can prevent the capture of data generated by the cookie and related to their use of the online offering by Google as well as the processing of these data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Further information about the use of data by Google, settings and rights to object is available in the Google data privacy statement (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

The personal data of users are erased or anonymised after 14 months.

Google Universal Analytics

We use Google Analytics in the “Universal Analytics” version. “Universal Analytics” is a Google Analytics process that prepares the user analysis on the basis of a pseudonymised user ID and thereby creates a pseudonymised user profile with information from the use of various devices (known as cross-device tracking).

Formation of Target Groups with Google Analytics

We use Google Analytics in order to display the advertisements placed within advertising services of Google and its partners only to those users who have shown an interest in our online offering, or who exhibit certain characteristics (e.g. interest in certain topics or products determined based on the websites that are visited), which we transmit to Google (known as Remarketing Audiences or Google Analytics Audiences). With the help of Remarketing Audiences, we also want to ensure that our advertisements correspond to the potential interests of users.

Social Media Online Presence

We maintain a social media online presence and other platforms in order to communicate with customers, interested parties and active users, and to inform them about our services. When viewing the respective networks and platforms, the business conditions and data processing policies of the respective operators apply.

We would like to point out that the users’ data may be processed outside the European Union. This may result in risks to users because e.g. the enforcement of user rights could be made more difficult. With respect to US providers certified under the Privacy Shield, we point out that they are committed to respecting EU privacy standards.

Furthermore, the user’s data is usually processed for market research and advertising purposes. Thus, e.g. user profiles are created from user behaviour and the resulting interests of the users. The usage profiles may, in turn, be used to e.g. place advertisements inside and outside the platforms that are presumably in line with users’ interests. For these purposes, cookies are usually stored on the users’ computers, in which the user behaviour and the interests of the users are stored. Furthermore, in the usage profiles, data can also be stored independently of the devices used by the users (in particular if the users are members of the respective platforms and logged in to them).

The processing of personal data linked to the user is based on our legitimate interests in effective information of users and the communication with users in accordance with. Art. 6 para. 1 lit. f. GDPR. If the users are asked by the respective providers for consent to data processing (that is, they declare their agreement, for example, by ticking a checkbox or confirmation a button), the legal basis of the processing is in accordance to Art. 6 para. a., Art. 7 GDPR.

For a detailed description of the respective processing and the possibilities of contradiction (opt-out), we refer to the following linked information of the provider.

Also, in the case of requests for information and the assertion of user rights, we point out that these can be claimed most effectively from the providers. Only the providers have access to the data of the users and can take appropriate measures directly and provide information. If you still need help, then you can contact us.

  • Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland) – data privacy statement: https://www.facebook.com/about/privacy/, Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
  • Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – data privacy statement: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
  • Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – data privcy statement/opt-out: http://instagram.com/about/legal/privacy/.

Security Measures

Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:

the pseudonymisation and encryption of personal data;

the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;

a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.

Server Log Files

We automatically collect and store information in so-called server log files, which your browser automatically sends to us when enquiring about our website. The information comprises:

  • the type and version of the browser used
  • the operating system used
  • referrer URL
  • the hostname of the computer being accessed
  • time of the server request

This mainly serves as quality assurance of our services. The data cannot be assigned to specific persons. The data is not merged with other data sources. We reserve the right to check this data retrospectively if specific indications for illegal use come to our attention.

Data Erasure

The data processed by us is deleted or the processing thereof limited in accordance with Articles 17 and 18 of the GDPR. Unless explicitly stated in this Privacy Policy, the data stored by us is deleted as soon as it is no longer required for its purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.

According to the legal requirements in Germany, the storage takes place for 10 years according to §§ 147 paragraph 1 AO, 257 paragraph 1 No. 1 and 4, paragraph. 4 HGB (books, records, management reports, accounting documents, trading books, for taxation relevant Documents, etc.) and 6 years in accordance with § 257 (1) no. 2 and 3, para. 4 (commercial letters).

According to legal regulations in Austria, the storage takes place in for 7 years in accordance with § 132 exp. 1 BAO (accounting documents, documents / invoices, accounts, documents, business documents, statement of income and expenses, etc.), for 22 years in connection with land and for 10 years in the case of documents related to electronically supplied services, telecommunications, broadcasting and television services provided to non-EU companies in EU Member States for which the Mini-One-Stop-Shop (MOSS) is used.

In the event of deletion, our system will be rendered unrecognizable and unrecoverable using an irreversible pseudonymization procedure.

Contact Details

For questions concerning the collection, processing or use of your personal data, for information, rectification, blocking or deletion of data as well as the revocation of consent, please contact: office@brozzl.com

Web Tracking Tools

In the context of retargeting and banner advertisements, we use third-party services. This is usually done using cookies or pixels. Thus, promotional offers will be more useful and interesting for you.

Data Security

Your payment data will be encrypted during the order process. We secure our website and other systems by means of technical and organisational measures against the loss, destruction, access, modification and dissemination of your data by unauthorized persons. You should always keep your access information confidential and close the browser window when you have finished communicating with us, especially if you share the computer with others.

We store the wording of a contract, sending you the order data and our Terms and Conditions via email. You can also read up on our Terms and Conditions here . All previous order can be viewed within your customer account.