Privacy Policy

PRIVACY POLICY (last modified on 12.10.2021)

1. Name and contact data of the controller for data processing as well as the company's data protection officer:

This privacy policy applies for data processing by:

Controller:

Unger GmbH & Co. KG
Neuer Wall 35 20354 Hamburg Germany
Phone +49 (0)40 600 88 50*
Fax +49 (0)40 600 885 208
Email: service@unger-fashion.com

 

The company's data protection officer can be accessed at the above address, c/o the data protection officer, or by email at datenschutz@unger-fashion.com .

2. The collection, storage and deletion of personal data as well as the manner and purpose of its use:

a) When visiting the website:

When visiting our website UNGER-FASHION.COM, the browser used on your device will automatically send information to our website server. This information will be temporarily stored in a so-called log file. In this process, the following information will be collected without your involvement and stored until automatic deletion:

• IP address of the requesting computer,

• Date and time of access,

• Name and URL of the file accessed,

• Website from which the access occurs (referrer URL),

• The web browser and potentially also the operating system used by your computer as well as the name of your access

provider.

We will process the above data for the following purposes:

• Guaranteeing a smooth connection to the website,

• Guaranteeing comfortable use of our website,

• Assessing system security and stability as well as

• for other administrative purposes.

The legal basis for data processing is Art. 6 (1) Sentence 1 (f) GDPR. Our legitimate interest is derived from the purposes for data collection listed above. Under no circumstances will we use the collected data in order to draw conclusions about your personal identity.

b) When subscribing to the newsletter:

If you have expressly consented pursuant to Art. 6 (1) Sentence 1 (a) GDPR, we will use your email address to regularly send you our newsletter. To receive the newsletter, it is sufficient to provide an email address.

When mailing the newsletter, a so-called web beacon is used (Clause 4). This allows us to analyse the success of the newsletter using key performance indicators such as clicked links, and to optimise our services using the information obtained. Your data will only be transferred to third parties in order to technically manage newsletter mailing through a service provider operating in compliance with data protection legislation, allowing us to carry out mailing and analysis.

Unsubscribing is possible at any time, for instance by following a link at the end of each newsletter. Alternatively, you can send an email to service@unger-fashion.com at any time indicating your desire to unsubscribe.

c) Order and payment data:

• In order to record, handle and carry out your order, your data will be transferred to contract service providers where necessary, for instance to the agents delivering the products.

• Payment data will be collected in encrypted form and exclusively used to handle the transaction in question. Except for the payment method of purchase on account, Unger does not obtain any knowledge or access to bank and credit card details. Settlement will be handled exclusively by the service provider in question.

• As a registered customer, you can select the option "Save payment data" in the order process. If you do so, sensitive credit card data will be saved securely and easily using a so-called "alias" (token) in your account for future purchases.

• Under "My Account" or "My Payment Data" you can manage or delete the stored information. If you do not wish to save a credit card in your profile, you can also enter the data again during each order.

d) Registration data:

During the order process you are given the option of creating a customer account with us. This account saves your address data including email address and orders. For your next order, you will only need to enter your customer name and a password. This password must be kept secret.

e) Credit rating

In case we provide advance services, e.g. for a purchase on account within the UNGER Fashion Concierge selection, we check your creditworthiness regularly and in specific instances where there is a legitimate interest, also for existing clients. For this process, we work together with Creditreform Boniversum GmbH, Hammfelddamm 13, 41460 Neuss, from whom we receive the data required for this purpose. For this specific aim, we transmit your name and contact details to Creditreform Boniversum GmbH. The legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Our legitimate interest base on reasons of creditor and credit protection. The information is under Art. 14 DSGVO on the data processing taking place at Creditreform Boniversum GmbH can download here: www.boniversum.de/eu-dsgvo/ 

f) Deletion of data:

The data you have saved with us will only be stored as long as it is required for optimal fulfilment.

• The data in the customer account will be stored until you delete the account.

• The order data will be stored until the order has been fulfilled even without a customer account.

The data will then be deleted unless statutory retention obligations apply. This deletion does not apply to data which we require in order to fulfil outstanding tasks or to assert our rights and claims, nor to data which we are required to retain according to statutory regulations. In this case, the data will be blocked against further use.

 
3. Transferring data:

Your personal data will not be transferred to third parties for reasons other than the intended purposes. Data will only be transferred to third parties if:

● You have given your express consent pursuant to Art. 6 (1)(a) GDPR,

● Transfer is necessary according to Art. 6 (1)(f) GDPR for the establishment, exercise or defence of legal claims and there is no reason to assume that you have

an overriding legitimate interest in the non-disclosure of your data,

● If there is a legal obligation according to Art. 6 (1)(c) GDPR

to transfer the data and

• This is legally permissible and required according to Art. 6 (1)(b) GDPR in order to fulfil

the contractual relationship with you.

 
4. Cookies & Web Beacons:

a) Cookies:

On our website, we use cookies. These are small files that your browser generates automatically and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies cannot damage your device and do not contain viruses, trojans or other malware.

Information is stored in the cookie relating to the specific device you are using. However, this does not mean that we obtain direct knowledge of your identity in this way.

Cookies are used to save basket settings and to make it possible for you to shop using the basket system. Cookies are also used to statistically record the use of our website and evaluate this data for the purposes of optimising our website for you (See Clause 5). When you visit our website again, these cookies allow us to automatically detect that you have visited us before. These cookies will be automatically deleted after a set period of time.

The data processed by cookies is required for the intended purposes in order to preserve our legitimate interests, as well as the interests of third parties, according to Art. 6 (1)(f) GDPR.

Most browsers automatically accept cookies. However, you can configure your browser so that no cookies will be saved to your computer or a warning will always appear before a new cookie is stored. But complete deactivation of cookies may make it impossible for you to use all features of our website.

b) Web Beacons:

Web beacons are invisible graphics used to collect information. Web beacons make it possible to analyse visitor traffic on websites.

 
5. Analysis Tools:

The measures listed below and implemented by us are carried out according to Art. 6 (1)(f) GDPR. The respective purpose of data processing and categories of data can be found from the respective tools.

a) Google Analytics:

To design our website based on user needs and continually optimise the website, we use Google Analytics, a web analysis service of Google Inc. https://www.google.de/intl/de/about/ (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereafter “Google”). In this context, pseudonymised usage profiles are created and cookies (see Clause 4 below) are used. The information generated by the cookie about your use of this website, such as

• Browser type/version,

• Operating system used,

• Referrer URL (previously visited website),

• Host name of the accessing computer (IP address),

• Date and time of service request,

will be transferred to a Google server in the USA and stored there. This information is used to analyse your use of the website, to compile reports about website activity and to perform other services associated with website use and internet use for the purposes of market research and needs-oriented design of these websites. This information may also be transferred to third parties if this is prescribed by law or insofar as third parties process this data on our behalf. Under no circumstances will your IP address be linked with other Google data. IP addresses are anonymised to ensure that personal identification is not possible (IP masking).

You can prevent the installation of cookies by changing the settings of your browser software accordingly; however, we inform you that in this case it may not be possible to use all features of this website to their full extent.

You can also prevent the collection of the data generated by the cookie concerning your use of this website (incl. your IP address) as well as the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/ gaoptout?hl=de).

As an alternative to the browser add-on, particularly for browsers on mobile devices, you can also prevent collection of data by Google Analytics by clicking on this link. An opt-out cookie will be set to prevent the future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website and will be stored on your device. If you delete the cookies in this browser, you will need to set the opt-out cookie again.

If you would like to deactivate tracking through Google Analytics, please click the following link.

You can find more information about data protection in connection with Google Analytics here:

https://www.google.com/analytics/terms/de.html

b) Facebook Pixel:

Our website uses the tracking service Facebook Pixel. This is a product offered by Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland). This service is used to document the transactions on our website such as the length of site visits, placement of products in the basket or purchases. The data used in this context will be stored using cookies (Clause 4) on your computer.

The saved data will be used to analyse the searching and buying habits of visitors on this website (tracking). The aggregated information will be used to improve the website and services.

You have the option to deactivate the collection of data for the abovementioned purposes. A permanent cookie will then be set which prevents the collection of data unless you specifically delete this cookie from your browser. You can object again at any time.

To deactivate Facebook Pixel, please click the following link.

 
6. Retargeting Tools:

a) Google Remarketing:

On this website, data is collected and stored using Google Remarketing, a retargeting service offered by Google, based on which usage profiles are created using pseudonyms. This technology allows users who have already visited our website and online services to see targeted advertising from us when visiting external websites in the Google partner network. To do so, a cookie will be set on your computer that analyses user behaviour when visiting the website and which can subsequently be used for targeted product recommendations and interest-based advertising. No personal data will be stored or processed in connection with the placement of this cookie.

If you would not like to receive interest-based advertising, you can deactivate Google's use of cookies for these purposes by following the instructions at https://www.google.de/settings/ads/onweb#display_optout.

b) Criteo:

On our website, we also use the retargeting tool Criteo (Criteo GmbH, Gewürzmühlstr. 11, 80538 Munich). Criteo collects information about the browsing behaviour of websites in a purely anonymous form for marketing purposes. To do so, cookies are placed on the visitor's device.

This allows Criteo to analyse browsing behaviour and then display targeted product recommendations as a relevant ad banner when other websites are visited. This anonymised data cannot be used to personally identify website visitors under any circumstances. The data collected by Criteo is solely used to improve the web service. On each banner displayed, there is a small "i" (for information) on the lower right which opens when the mouse is hovered over it; clicking on this icon leads to a page explaining the system and offering an opt-out option. Clicking on the opt out will set an "Opt Out" cookie which will prevent this banner from being displayed in the future. Different use or transfer to third parties will not occur.

You can learn more details and object to anonymous analysis of your browsing behaviour by Criteo at http://www.criteo.com/de/datenschutzrichtlinien.

7. Social Media:

On our website, it is possible to share content on the social networks Facebook and Pinterest. We make use of this option to increase awareness of our website on these platforms. The commercial purpose behind this is considered a legitimate interest within the meaning of the GDPR. We embed these plugins using the so-called two-click method to protect visitors to our website optimally. Responsibility for compliant operation under data protection laws must be guaranteed by the respective provider.

8. Other:

a) Google Maps:

Our website uses a Google Maps API to visually represent geographical information. Google Maps is a product of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereafter “Google”). When Google Maps is used, Google also collects, processes and uses data regarding the use of the maps feature by website visitors. You can find more detailed information about data processing by Google in Google's privacy policy.

A more thorough guide to managing personal data in connection with Google products can be found here: https://support.google.com/accounts/answer/3024190.

b) WisePops:

We use the service provided by the company WisePops SAS, 49 rue Jean De La Fontaine, 75016 Paris, in order to address surveys to our users. WisePops uses cookies (Clause 4) to determine whether and how users interact with survey popups. We use the survey results to optimise our website. You can find more information on the WisePops website.

c) Fraend

We use the German platform FRAEND (FRAEND GmbH; Gaudystr. 10; 10437 Berlin; Germany) in order to enable product reviews and visitor discussions. You can only participate in such visitor discussions if you log in to your user account with us, FRAEND or another service such as Facebook or Google (in the latter case, these services may also potentially track your use of FRAEND). FRAEND uses cookies to identify you and may integrate services for use-based marketing, which you can prevent here. Here you can find details about data protection relating to FRAEND.

9. Rights of data subjects:

You have the right:

● according to Art. 15 GDPR, to request information about your personal data that is processed by us. In particular, you can request information about the purposes for which the personal data is processed, the categories of personal data concerned, the categories of recipients to whom your personal data has been or will be disclosed, the envisaged period of storage, the existence of the rights to rectification, erasure, restriction of processing or objection, the right to lodge a complaint, the source of the data if the personal data is not collected from the data subject, as well as the existence of automated decision-making, including profiling, and any meaningful information about the details involved;

● according to Art. 16 GDPR, the right to prompt rectification and/or completion of inaccurate or incomplete personal data we have stored concerning you;

● according to Art. 17 GDPR, the right to request the erasure of your personal data that we have stored, unless processing is necessary in order to exercise the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims;

● according to Art. 18 GDPR, the right to restriction of processing for personal data concerning you, if you contest the accuracy of the data, if processing is unlawful but you oppose the erasure of the personal data and if we no longer require the data, but you require the data for the assertion, exercise or defence of legal claims, or if you have filed an objection according to Art. 21 GDPR against the processing.

● according to Art. 20 GDPR, the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or to request transfer to another controller;

● according to Art. 7 (3) GDPR, to withdraw your consent at any time after granting it to us. As a consequence, we will not be allowed to continue with the data processing related to this consent in the future and

● according to Art. 77 GDPR, the right to lodge a complaint with a supervisory authority. Generally, you can contact the supervisory authority for your typical place of residence or workplace or your company's registered office.

10. Right to object:

If your personal data is processed on the basis of legitimate interests within the meaning of Art. 6 (1)(f) GDPR, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR as long as there are grounds relating to your particular situation, or if the objection concerns direct marketing. In the latter case, you have a general right of objection that we will implement without requiring information about a particular situation. If you would like to exercise your right of cancellation or objection, it is sufficient to send an email to service@unger-fashion.com.

11. Data Security:

During website visits, we use the popular SSL method (Secure Socket Layer) in conjunction with the highest level of encryption currently supported by your browser. Generally, this is 256 bit encryption. If your browser does not support 256 bit encryption, we resort to 128 bit v3 technology instead. You can tell whether individual pages on our website are transmitted in an encrypted form by the closed key or lock symbol displayed in the status bar of your browser. We also implement technical and organisational security measures to protect your personal data against accidental or deliberate manipulation, partial or total loss, destruction or against attacks by unauthorised persons. Our security measures are continually improved according to technological developments.

12. Validity and modifications to this privacy policy

This privacy policy is currently valid as of October 2021.

It may be necessary to make changes to this privacy policy due to continuing development of this website and service, or due to modified statutory or official requirements. The current privacy policy can be accessed and printed on the website at

www.unger-fashion.com/datenschutz at any time.