Data protection / privacy policy

Data protection / privacy policy

Data protection

This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereby briefly "data") within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profile (hereinafter Together referred to as "online offer"). With regard to the terms used, such as "processing" or "responsible", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Responsible

Vin Vin
Christoph Cyll
Susannenstrasse 18
20357 Hamburg
Germany
info@vinvin-naturel.com

Types of processed data:

- inventory data (e.g., names, addresses).
- Contact details (e.g., email, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., visited websites, interest in content, access times).
-Meta/communication data (e.g., device information, IP addresses).

Categories of people affected

Visitors and users of the online offer (hereinafter referred to as a “user”), we summarize the people concerned.

Purpose of processing

- Providing the online offer, its functions and content.
- Answering contact inquiries and communication with users.
- Safety measures.
- Measuring range/marketing

Used terms

"Personal data" is all information that relates to an identified or identifiable natural person (hereinafter "data subject"); A natural person is regarded as identifiable, which can be identified directly or indirectly, in particular by assigning to an identifier such as a name, to an identification number, on site data, for an online detection (e.g. cookie) or for one or more special characteristics, the expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.

"Processing" is every process carried out with or without the help of automated procedures or any such series of transaction in connection with personal data. The term extends wide and comprises practically every handling of data.

"Pseudonymization" The processing of personal data in a way that the personal data can no longer be assigned to a specific data without the involvement of additional information, provided that the additional information is kept separately and are subject to technical and organizational measures that ensure that the personal data are not assigned to an identified or identifiable natural person.

"Profiling" of any type of automated processing of personal data that is used in the fact that this personal data is used in order to evaluate certain personal aspects that relate to a natural person, especially about aspects regarding work performance, economic situation, health, personal Prevention, interests, reliability, behavior, place of residence or change of location of this natural person to analyze or predict.

The natural or legal person, authority, institution or other body, which decides on the purposes and means of processing personal data alone, is referred to as the "person responsible".

"Processor" a natural or legal person, authority, institution or other body that processes personal data on behalf of the person responsible.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for the obtaining of consent is Art. 6 Para. 1 lit. a and Art. 7 GDPR, the legal basis for the processing of our services and implementation of contractual measures as well as Answering inquiries is Art. 6 Para. 1 lit. b GDPR, the legal basis for the processing to fulfill our legal obligations is Art. 6 Para. 1 lit. c GDPR, and the legal basis for processing our legitimate interests is type 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require processing of personal data, Art. 6 Para. 1 lit. d GDPR serves as a legal basis.

Safety measures

In accordance with Art. 32 GDPR, taking into account the status of the art, implementation costs and the type, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk of the rights and freedoms of natural persons, suitable technical And organizational measures to ensure a level of protection that is appropriate to the risk.

The measures include in particular the securing of confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, passing on, securing availability and separation. Furthermore, we have set up procedures that ensure a perception of affected rights, deletion of data and reaction to the risk of the data. We also take into account the protection of personal data in the development or selection of hardware, software as well as procedures, in accordance with the principle of data protection through technology design and through data protection -friendly default settings (Art. 25 GDPR).

Cooperation with order processors and third parties

If we reveal data to other persons and companies (order processors or third parties), transmit them to them or otherwise grant you access to the data, this is only done on the basis of a legal permission (e.g. if the data is transmitted to third parties, as required to payment service providers, according to Art. 6 Para. 1 lit. b GDPR for the fulfillment of the contract), you have agreed to provide a legal obligation or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data based on a so -called "order processing contract", this is based on Art. 28 GDPR.

Transmission to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this is done as part of the use of third parties or disclosure or transmission of data to third parties, this is only done if to fulfill our (before) contractual obligations, based on your consent, based on a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permits, we only process or have the data processed in a third country if the special requirements of Art. 44 ff. GDPR. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or observing by officially recognized special contractual obligations (so -called “standard contract clauses”)).

Rights of the persons concerned

You have the right to request confirmation of whether the data in question is processed and information about this data as well as further information and copy of the data in accordance with Art. 15 GDPR.

You have accordingly. Art. 16 GDPR the right to request the completion of the data relating to it or to correct the incorrect data relating to it.

In accordance with Art. 17 GDPR, you have the right to request that data be deleted immediately or, as an alternative, to request a restriction of the processing of the data in accordance with Art. 18 GDPR.

You have the right to request that the data you have provided to us to receive us in accordance with Art. 20 GDPR and to request it to be sent to other those responsible.

According to Art. 77 GDPR, you also have the right to submit a complaint to the responsible supervisory authority.

Right of withdrawal

You have the right to revoke consent in accordance with Art. 7 Para. 3 GDPR with effect for the future

Right to object

You can object to the future processing of the data relating to you in accordance with Art. 21 GDPR at any time. The objection can be carried out in particular against the processing for direct marketing purposes.

Cookies and right of objection in direct advertising

Small files that are stored on users' computers are called “cookies”. Different information can be saved within the cookies. A cookie primarily serves to save the information about a user (or the device on which the cookie is stored) during or after visiting within an online offer. Temporary cookies or "session cookies" or "transient cookies" are called cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, the content of a shopping cart can be stored in an online shop or a login status. Cookies are referred to as "permanent" or "persistent", which are also stored even after the browser is closed. For example, the login status can be saved if the users visit them after several days. In such a cookie, the interests of the users that are used for range measurement or marketing purposes can also be stored in such a cookie. Cookies, which are offered by other providers as the person responsible who operates the online offer, are offered as the “third party cookie” (otherwise if only their cookies are spoken of “first party cookies”).

We can use temporary and permanent cookies and clarify this as part of our data protection declaration.

If users do not want cookies to be saved on their computer, you will be asked to deactivate the corresponding option in the system settings of your browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general contradiction to the use of cookies used for the purpose of online marketing can be used for a variety of services, especially in the case of tracking, via the US side http://www.aboutads.info/choices/ Or the EU page http://www.youronlinechoices.com/ be explained. Furthermore, the storage of cookies can be achieved in the settings of the browser by means of their shutdown. Please note that not all functions of this online offer may be used.

Deletion of data

The data we process will be deleted in accordance with Art. 17 and 18 GDPR or restricted in their processing. Unless expressly stated in the context of this data protection declaration, the data stored by us will be deleted as soon as they are no longer necessary for their purpose and no legal retention obligations are opposed to deletion. If the data is not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies e.g. to data that must be kept for commercial or tax reasons.

According to legal requirements in Germany, storage takes place in particular for 10 years in accordance with Sections 147 (1) AO, 257 Paragraph 1 No. 1 and 4, Paragraph 4 HGB (books, records, positioning reports, booking documents, trade books, for taxation relevant Documents, etc.) and 6 years in accordance with Section 257 (1) No. 2 and 3, Paragraph 4 HGB (trade letters).

According to legal requirements in Austria, the storage is given in particular for 7 J in accordance with Section 132 (1) BAO (accounting documents, documents/invoices, accounts, documents, business papers, establishment of income and expenses, etc.), for 22 years in connection with land and for 10 years in connection with electronic services, telecommunications, radio and television services that are provided to non-entrepreneurs in EU member states and for which the mini-one-stop shop (MOSS) is used.

Business -related processing

In addition, we process
- Contract data (e.g., subject of the contract, term, customer category).
- Payment data (e.g., bank details, payment history)
by our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Order processing in the online shop and customer account

We process the data of our customers as part of the order processes in our online shop to enable you to select and order the selected products and services, as well as their payment and delivery or execution.

The processed data include inventory data, communication data, contract data, payment data and the people concerned are our customers, interested parties and other business partners. The processing takes place for the purpose of providing contract services as part of the operation of an online shop, settlement, delivery and customer services. Here we use session cookies for storing the shopping cart content and permanent cookies for storing the login status.

The processing takes place on the basis of Art. 6 Para. 1 Lit. B (implementation of order processes) and C (legally required archiving) GDPR. The information marked as necessary are required to justify and fulfill the contract. We only reveal the data to third parties as part of delivery, payment or within the framework of the legal permits and obligations towards legal advisors and authorities. The data is only processed in third countries if this is necessary to fulfill the contract (e.g. on customer requirements for delivery or payment).

Users can optionally create a user account by being able to view their orders in particular. As part of the registration, the necessary mandatory information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account. Subject to the storage of their storage, Art. 6 Para. 1 lit. c GDPR is necessary for commercial or tax reasons. Information remains in the customer account until it deleted with subsequent archiving in the event of a legal obligation. It is the responsibility of users to secure their data before the contract has been terminated.

As part of registration and re-registration as well as the use of our online services, we save the IP address and the time of the respective user story. The storage takes place on the basis of our legitimate interests, as well as the user in protection against misuse and other unauthorized use. This data is not passed on to third parties, unless it is required to pursue our claims or there is a legal obligation in accordance with Art. 6 Para. 1 lit. c GDPR.

The deletion takes place at the expiry of statutory warranty and comparable obligations, the necessity of the storage of the data is checked every three years; In the case of the statutory archiving obligations, the deletion takes place after the expiry (end of commercial law (6 years) and tax law (10 years).

External payment service provider

We use external payment service providers, through whose platforms the users and we can make payment transactions (e.g. PayPal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full).

As part of the fulfillment of contracts, we set the payment service providers based on Art. 6 Para. 1 lit. b. GDPR. In addition, we set external payment service providers based on our legitimate interests in accordance with Art. 6 Para. 1 lit. b. GDPR to offer our users effective and safe payment options.

The data processed by the payment service providers include inventory data, such as the name and address, bank details, such as account numbers or credit card numbers, passwords, TANs and test sums as well as the contract, sums and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored in them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information. Under certain circumstances, the data from the payment service providers are transmitted to economic information. This transmission aims for identity and credit check. To do this, we refer to the terms and conditions and data protection instructions of the payment service providers.

The terms and conditions and the data protection instructions of the respective payment service providers apply to the payment transactions, which can be called up within the respective websites or transaction applications. We refer to this also for further information and assertion of cancellation, information and other affected rights.

Administration, financial accounting, office organization, contact management

We process data as part of administrative tasks as well as organization of our company, financial accounting and compliance with the legal obligations, such as archiving. We process the same data that we process as part of the provision of our contractual services. The processing bases are Art. 6 Para. 1 lit. c. GDPR, Art. 6 Para. 1 Lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.

We disclose or transmit data to the financial administration, consultants, such as, tax consultants or auditors as well as other fees and payment service providers.

We also store information about suppliers, organizers and other business partners on the basis of our business interests, e.g. for later contact. We basically store this majority of company -related data.
 

Business analyzes and market research

In order to be able to recognize our business economically, to be able to recognize market tendencies, customer and user requests, we analyze the data available to us on business processes, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata based on the type. 6 para. 1 lit. f. GDPR, whereby the data subjects include customers, interested parties, business partners, visitors and users of the online offer.

The analyzes are carried out for the purpose of business evaluations, marketing and market research. We can take into account the profiles of the registered users with information, e.g. on their services. The analyzes serve us to increase user -friendliness, the optimization of our offer and business. The analyzes alone serve us and are not revealed externally, unless it is anonymous analyzes with summarized values.

If these analyzes or profiles are personal, you will be deleted or anonymized with the termination of the users, otherwise after two years from the conclusion of the contract. In addition, the overall commercial analyzes and general tendency regulations are created anonymously if possible.
 

Newsletter

With the following information, we inform you about the content of our newsletter as well as the registration, shipping and statistical evaluation procedures as well as your right to object. By subscribing to our newsletter, you agree to the reception and the procedure described.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter referred to as "newsletter") only with the consent of the recipients or a legal permit. If the content of its content is described as part of a registration for the newsletter, you are decisive for the consent of the users. In addition, our newsletter contains information about our services and us.

Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that you will receive an email after registration, in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with third-party email addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and the confirmation period, as well as the IP address. The changes from the data stored by the shipping service provider are also logged.

Registration data: To register for the newsletter, it is sufficient if you enter your email address. Optionally, we ask you to specify a name for personal addressing in the newsletter.

The sending of the newsletter and the success measurement associated with it takes place on the basis of the consent of the recipient in accordance with Art. 6 Para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 Paragraph 2 No. 3 UWG or on the basis of the statutory permission According to Section 7 (3) UWG.

The login procedure is recorded on the basis of our legitimate interests in accordance with Art. 6 Para. 1 Lit. f GDPR. Our interest is aimed at the use of a user -friendly and secure newsletter system, which serves both our business interests and meets the expectations of the users and also allows us to prove consent.

Termination/revocation - You can cancel the reception of our newsletter at any time, i.e. revoke your consent. You can find a link to cancel the newsletter at the end of each newsletter. We can save the email addresses carried out for up to three years based on our legitimate interests before we delete them in order to be able to prove a former consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual application for deletion is possible at any time, provided that the former existence of consent is also confirmed.
 

Newsletter - Mailchimp

The newsletter is dispatched using the shipping service provider "Mailchimp", a newsletter shipping platform by the US provider Rocket Science Group, LLC, 675 Ponce de Leon Ave Ne #5000, Atlanta, GA 30308, USA. You can view the data protection regulations of the shipping service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC D/B/A MailChimp is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with the European data protection level (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The shipping service provider is deployed on the basis of our legitimate interests in accordance with Art. 6 Para. 1 Lit. f GDPR and an order processing contract in accordance with Art. 28 Para. 3 S. 1 GDPR.

The shipping service provider can use the data of the recipient in pseudonym form, i.e. without assignment to a user to optimize or improve your own services, e.g. to use the technical optimization of the newsletter or for statistical purposes. However, the shipping service provider does not use the data of our newsletter receivers to write it down or to pass the data on to third parties.

Newsletter - success measurement

The newsletters contain a so-called "Web Beacon", i.e. a pixel-sized file that is opened by our server when the newsletter is opened, or if we use a shipping service provider, from the server of which. As part of this access, technical information, such as information on the browser and your system, as well as your IP address and time of access, is first collected.

This information is used to technical improvement the services based on the technical data or the target groups and their reading behavior based on which access locations (which can be determined with the help of the IP address) or access times. Statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter receivers. However, it is neither our endeavor, nor, if used, to observe individual users that of the shipping service provider. The evaluations serve us much more to recognize our users' reading habits and adapt our content to them or to send different content according to the interests of our users.

Online presences in social media

We maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to be able to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines apply their respective operators.

Unless otherwise stated in the context of our data protection declaration, we process the data of the users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.

Integration of services and third -party content

We use the content or service offers from third-party providers within our online offer based on our legitimate interests (i.e. interest in analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. 1 lit. f. GDPR) To integrate services such as videos or fonts (hereinafter referred to as “content”).

This always presupposes that the third-party providers perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore necessary to present this content. We only strive to use such content whose respective providers only use the IP address to deliver the content. Third providers can also use so-called pixel tags (invisible graphics, also known as "Web Beacons") for statistical or marketing purposes. The "Pixel tags" can be used to evaluate information on how visitor traffic is evaluated on the pages of this website. The pseudonymous information can also be stored in cookies on the user device and, among other things, technical information on the browser and operating system, referring websites, visiting time as well as further information on the use of our online offer, as well as such information from other sources are connected. 

Use of Facebook Social Plugins

On the basis of our legitimate interests (i.e. interest in analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. GDPR) Social Plugins ("plugins") of the social network facebook.com, which by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland ("Facebook"). The plugins can represent interaction elements or content (e.g. videos, graphics or text articles) and can be recognized by one of the Facebook logos (white "f" on blue tile, the terms "like", "like" or a "thumbs up" sign ) or are marked with the addition "Facebook Social Plugin". The list and appearance of the Facebook social plugins can be viewed here:https://developers.facebook.com/docs/plugins/.

Facebook is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

If a user calls a function of this online offer that contains such a plugin, his device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted directly to the user's device and integrated from it into the online offer. User profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore informs the users according to our level of knowledge.

By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user has logged in on Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example press the Like button or make a comment, the corresponding information is transmitted directly to Facebook from your device and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save his IP address. According to Facebook, only an anonymized IP address is stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as the related rights and setting options for the protection of the privacy of users can be found in Facebook's data protection information:https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link with his member data stored on Facebook, he must log out of Facebook before using our online offer and delete his cookies. Further settings and contradictions for the use of data for advertising purposes are possible within the Facebook profile settings:https://www.facebook.com/settings?tab=ads Or on the US sidehttp://www.aboutads.info/choices/ Or the EU pagehttp://www.youronlinechoices.com/. The settings are platform independently, i.e. they are taken over for all devices such as desktop computers or mobile devices.

Twitter

Within our online offer, functions and content of the Twitter service, offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. This can include, for example, content such as images, videos or texts and buttons with which users make their favor with regard to the content, can subscribe to the authors of the content or our contributions. If the users are members of the Twitter platform, Twitter can assign the call to the above content and functions to the users' profiles there. Twitter is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Data protection: https://twitter.com/de/privacy, Opt-out: https://twitter.com/personalization.

Instagram

Within our online offer, functions and content of the Instagram service, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. This can include, for example, content such as images, videos or texts and buttons with which users make their favor with regard to the content, can subscribe to the authors of the content or our contributions. If the users are members of the Instagram platform, Instagram can assign the call to the above content and functions to the users' profiles there. Instagram data protection declaration: http://instagram.com/about/legal/privacy/. 

Pinterest

Within our online offer, functions and content of the Pinterest service, offered by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA, can be integrated. This can include, for example, content such as images, videos or texts and buttons with which users make their favor with regard to the content, can subscribe to the authors of the content or our contributions. If the users are members of the Pinterest platform, Pinterest can assign the call to the above content and functions to the users' profiles there. Pinterest data protection declaration: https://about.pinterest.com/de/privacy-policy.