1) Information on the Collection of Personal Data and Contact Details of the Controller
1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.
1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is napo-shop.de GmbH, Niederwiesenstrasse 28, 78050 Villingen-Schwenningen, Deutschland, Tel.: +49 - (0)7721 9442 122, Fax: +49 - (0)7721 9442 222, E-Mail: email@example.com. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
1.3 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.
2) Data Collection When You Visit Our Website
When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:
- Our visited website
- Date and time at the moment of access
- Amount of data sent in bytes
- Source/reference from which you came to the page
- Browser used
- Operating system used
- IP address used (if applicable: in anonymized form)
Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.
To make visiting our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your end device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your terminal and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process specific user information such as browser and location data as well as IP address values according to individual requirements. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can check the duration of the respective cookie storage in the overview of the cookie settings of your web browser.
In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the content of a virtual shopping basket for a later visit to the website). If personal data are also processed by individual cookies set by us, the processing is carried out in accordance with Art. 6 (1) point b GDPR either for the execution of the contract or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.
Please note that you can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. Each browser differs in the way it manages the cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You will find these for the respective browsers under the following links:
Please note that the functionality of our website may be limited if cookies are not accepted.
4) Contacting Us
4.1 Evaluation Reminder by Trusted Shops
If you have given us your express consent during or after your order in accordance with Art. 6 (1) point a GDPR, we will send your e-mail address to the evaluation platform "Trusted Shops GmbH" , Subbelrather Str. 15c, 50823 Köln (www.trustedshops.it), so that it can send you an evaluation reminder by e-mail. You can revoke your consent at any time by sending a message to the controller responsible for data processing or to the evaluation platform.
4.2 When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration. The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.
5) Data Processing When Opening a Customer Account and for Contract Processing
Pursuant to Art. 6 (1) point b GDPR, personal data will continue to be collected and processed to the extent required in each case if you provide us with this data when opening a customer account. The data required for opening an account can be found in the input mask of the corresponding form on our website. Deletion of your customer account is possible at any time and can be done by sending a message to the above address of the person responsible. After deletion of your customer account, your data will be deleted, provided that all contracts concluded via it have been fully processed, no legal retention periods are opposed and no legitimate interest on our part in the continued storage exists.
6) Use of Client Data for Direct Advertising
- Newsletter via Seninblue
Our e-mail newsletter is sent by the technical service provider Sendinblue SAS (55 Rue d'Amsterdam, 75008 Paris, France), to whom we pass on the data you provide when registering for the newsletter. This passing on takes place in accordance with Art. 6 (1) point f GDPR and serves our legitimate interest in the use of an effective, secure and user-friendly newsletter system. The data you enter for newsletter subscription (e.g. e-mail address) will be stored on Sendinblue's servers in the EU.
Sendinblue uses this information to send and statistically evaluate newsletters on our behalf. For evaluation purposes, the e-mails sent contain so-called web beacons or tracking pixels, which represent one-pixel image files stored on our website. This enables us to determine whether a newsletter message has been opened and which links have been clicked. Technical information is also recorded (e.g. time of access, IP address, browser type and operating system). The data is exclusively collected in a pseudonymized format and is not linked with your other personal data, a direct personal reference is excluded. This data is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients. If you wish to object to the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter.
Furthermore, in accordance with Art. 6 (1) point f GDPR, Sendinblue itself may use this data for its own legitimate interest in designing and optimising the service in line with market needs and for market research purposes. Data is used, for example, to determine from which countries the recipients come. However, Sendinblue does not use the data of our newsletter recipients to write to them or forward the data to third parties.
We have concluded an order processing agreement with Sendinblue obliging Sendinblue to protect our customers’ data and not to pass it on to third parties.
7) Processing of Data for the Purpose of Order Handling
7.1 Insofar as necessary for the processing of the contract for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 (1) lit. b GDPR.
If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we will process the contact data (name, address, e-mail address) provided by you when placing the order in order to inform you personally by suitable means of communication (e.g. by post or e-mail) about upcoming updates within the legally stipulated period of time within the framework of our statutory duty to inform pursuant to Art. 6 (1) lit. c GDPR. Your contact details will be used strictly for the purpose of informing you about updates owed by us and will only be processed by us for this purpose to the extent necessary for the respective information.
In order to process your order, we also work together with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information.
7.2 Use of Special Service Providers for Order Processing and Handling
7.3 Use of Payment Service Providers
- Amazon Pay
If the payment method "Klarna invoice purchase" or (if offered) the payment method "Klarna Installment Purchase" is selected, payment is processed by Klarna AB (publ )[https://www.klarna.com
The credit report can contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on recognized scientific, mathematical-statistical methods. The calculation of the score values includes, but is not limited to, address data. Klarna uses the information received on the statistical probability of non-payment for a balanced decision on the establishment, implementation or termination of the contractual relationship.
You can revoke your consent at any time by sending a message to the controller responsible for data processing or to Klarna. However, Klarna may still be entitled to process your personal data if this is necessary to process payments in accordance with the contract.
When you pay via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "payment by instalments" via PayPal, we transmit your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). The transfer takes place in accordance with Art. 6 (1) point b GDPR and only insofar as this is necessary for payment processing.
PayPal reserves the right to carry out credit checks for the payment methods credit card via PayPal, direct debit via PayPal or, if offered, "purchase on account" or "payment by installments" via PayPal. For this purpose, your payment data may be passed on to credit agencies on the basis of PayPal's legitimate interest in determining your solvency pursuant to Art. 6 (1) point f GDPR. PayPal uses the result of the credit assessment in relation to the statistical probability of non-payment for the purpose of deciding on the provision of the respective payment method. The credit report can contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on recognized scientific, mathematical-statistical methods. The calculation of the score values includes, but is not limited to, address data. For further information on data protection law, including the credit agencies used, please refer to PayPal's data protection declaration at: https://www.paypal.com
You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary for contractual payment processing.
- Paypal Checkout
This website uses PayPal Checkout, an online payment system from PayPal, which consists of PayPal's own payment methods and local payment methods from third-party providers.
When paying via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "Pay Later" via PayPal, we pass on your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal") as part of the payment processing. The transfer takes place in accordance with Art. 6 Para. 1 lit. b GDPR and only insofar as this is necessary for the payment processing.
For the payment methods credit card via PayPal, direct debit via PayPal or - if offered - "pay later" via PayPal - PayPal reserves the right to conduct a credit check. For this purpose, your payment data may be passed on to credit agencies in accordance with Art. 6 Para. 1 lit. f GDPR on the basis of PayPal's legitimate interest in determining your solvency. PayPal uses the result of the credit check in terms of the statistical probability of non-payment for the purpose of deciding on the provision of the respective payment method. The creditworthiness information may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, they have their basis in a scientifically recognised mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data. You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary for the contractual processing of payments.
If you select the PayPal payment method "purchase on account", your payment data will first be transmitted to PayPal in preparation for payment, whereupon PayPal will forward this data to Ratepay GmbH, Franklinstraße 28-29, 10587 Berlin ("Ratepay") in order to process the payment. The legal basis in each case is Art. 6 para. 1 lit. b GDPR. In this case, RatePay carries out an identity and creditworthiness check on its own behalf to determine solvency in accordance with the principle already mentioned above and passes on your payment data to credit agencies on the basis of the legitimate interest in determining solvency in accordance with Art. 6 Para. 1 lit. f GDPR. A list of the credit agencies that Ratepay may use can be found here: https://www.ratepay.com
If you use the payment method of a local third-party provider, your payment data will first be passed on to PayPal in preparation for the payment in accordance with Art. 6 para. 1 lit. b GDPR. Depending on your selection of an available local payment method, PayPal will then transmit your payment data to the corresponding provider in order to carry out the payment in accordance with Art. 6 Para. 1 lit. b GDPR:
- Sofort (SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany)
- iDeal (Currence Holding BV, Beethovenstraat 300 Amsterdam, Netherlands)
- giropay (Paydirekt GmbH, Stephanstr. 14-16, 60313 Frankfurt am Main, Germany)
- bancontact (Bancontact Payconiq Company, Rue d'Arlon 82, 1040 Brussels, Belgium)
- blik (Polski Standard Płatności sp. z o.o., ul. Czerniakowska 87A, 00-718 Warsaw, Poland)
- eps (STUZZA Studiengesellschaft für Zusammenarbeit im Zahlungsverkehr GmbH, Frankgasse 10/8, 1090 Vienna, Austria)
- MyBank (PRETA S.A.S, 40 Rue de Courcelles, F-75008 Paris, France)
- Przelewy24 (PayPro SA, Kanclerska 15A, 60-326 Poznań, Poland)
8) Online Marketing
Use of Afiliate Programs
- AWIN Performance Advertising Network
We participate in the Performance Advertising Network of AWIN AG, Eichhornstraße 3, 10785 Berlin (hereinafter "AWIN"). Within the scope of its tracking services, AWIN stores cookies to document transactions (e.g. leads and sales) on end devices of users who visit or use websites or other online offers of its customers (e.g. register for a newsletter or place an order in an online shop). These cookies are used solely for the purpose of correctly allocating the success of an advertising medium and the corresponding billing within its network.
A cookie only contains information about the time when a particular advertising medium was clicked on by a terminal device. The AWIN tracking cookies contain an individual sequence of digits which cannot be assigned to the individual user and which documents the affiliate program of an advertiser, the publisher, and the time of the user's action (click or view). AWIN also collects information about the mobile device from which a transaction is executed, e.g. the operating system and the calling browser. If the information also contains personal data, the described processing is carried out on the basis of our legitimate financial interest in the processing of commission payments with AWIN pursuant to Art. 6 (1) point f GDPR.
If you do not wish cookies to be stored in your browser, you can do this by setting your browser accordingly. You can deactivate the storage of cookies in your respective browser under tools/internet options, limit them to certain websites or set your browser so that it notifies you as soon as a cookie is sent. Please note, however, that in this case you must expect a limited display of online offers and limited user guidance. You can also delete cookies at any time. In this case, the information stored in it is removed from your mobile device.
To the extent required by law, we have obtained your consent to the processing of your data as described in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future. If you wish to exercise your right of revocation, please follow the procedure described above.
9) Web Analysis Services
Google (Universal) Analytics
This website uses Google (Universal) Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google (Universal) Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website (including the abbreviated IP address) is usually transferred to a Google server and stored there and may also be transferred to the servers of Google LLC. in the USA.
This website uses Google (Universal) Analytics exclusively with the extension "_anonymizeIp()", which ensures anonymization of the IP address by shortening it and excludes the possibility of direct personal reference. Through the extension, your IP address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area before. Only in exceptional cases will the full IP address be transferred to a server of Google LLC. in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide us with further services related to the use of the website and the Internet. The IP address transmitted by your browser within the framework of Google (Universal) Analytics is not combined with other Google data.
Via a special function called "Demographics", Google Analytics also enables the compilation of statistics with statements about the age, gender and interests of site visitors based on an evaluation of interest-related advertising and with the use of third-party information. This allows the definition and differentiation of user groups of the website for the purpose of target-group-optimized marketing measures. However, data sets collected via "Demographics" cannot be assigned to a specific person.
Details on the processing operations initiated and on Google's handling of data collected from websites can be found here: https://policies.google.com
All the processing described above, in particular the setting of Google Analytics cookies for reading information on the terminal device used, is only carried out if you have given us your express consent in accordance with Art. 6 Para. 1 letter a GDPR. Without this consent, the use of Google Analytics during your visit to our website will not take place.
You can withdraw your consent at any time with effect for the future. To exercise your right of withdrawal of consent, please deactivate this service in the "Cookie-Consent-Tool" provided on the website. We have concluded a data processing agreement with Google for the use of Google Analytics, which obliges Google to protect the data of our site visitors and not to pass it on to third parties.
For the transmission of data from the EU to the USA, Google relies on so-called standard data protection clauses of the European Commission, which are intended to ensure compliance with the European data protection level in the USA.
Further information about Google (Universal) Analytics can be found here: https://policies.google.com
10) Site Functionalities
10.1 Trusted Shops Trustbadge
The Trusted Shops Trustbadge is included on this website to display our Trusted Shops seal of approval and to offer Trusted Shops membership to buyers after placing an order.
In this way, our legitimate interests in an optimal marketing of our offer are protected, within the meaning of Art. 6 (1) point f GDPR. The Trustbadge and the services advertised with it are a service of Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne.
When the trust badge is called up, the web server automatically stores a so-called server log file, which contains e.g. your IP address, date and time of the call, transferred data volume, the requesting provider (access data), and it documents the call. This access data is not evaluated and is automatically overwritten at the latest seven days after the end of your page visit.
Further personal data will only be transferred to Trusted Shops if you decide to use Trusted Shops products after completing an order or if you have already registered for use. In this case, the contractual agreement between you and Trusted Shops applies.
10.2 Google Web Fonts
This site uses web fonts provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google") to uniformly display fonts. When you call up a page, your browser loads the required web fonts into its browser cache to display texts and fonts correctly.
To do this, the browser you are using must have a connection to Google's servers. When using Google Maps, personal data may also be transmitted to the servers of Google LLC. in the USA. In this way, Google will be informed that our website has been accessed via your IP address. Google Web Fonts are used for the purpose of a uniform and attractive presentation of our online offers and its use is in our legitimate interest within the meaning of Art. 6 (1) point f GDPR. If your browser does not support web fonts, a default font is used by your computer.
Further information about Google Web Fonts can be found at https://developers.google.com
11) Rights of the Data Subject
11.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:
- Right of access by the data subject pursuant to Art. 15 GDPR: You shall have the right to receive the following information: The personal data processed by us; the purposes of the processing; the categories of processed personal data; the recipients or categories of recipients to whom the personal data have been or will be disclosed; the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling and at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject; the appropriate safeguards pursuant to Article 46 when personal data is transferred to a third country.
- Right to rectification pursuant to Art. 16 GDPR: You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you and/or the right to have incomplete personal data completed which are stored by us.
- Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR: You have the right to obtain from the controller the erasure of personal data concerning you if the conditions of Art. 17 (2) GDPR are fulfilled. However, this right will not apply for exercising the freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims.
- Right to restriction of processing pursuant to Art. 18 GDPR: You have the right to obtain from the controller restriction of processing your personal data for the following reasons: As long as the accuracy of your personal data contested by you will be verified. If you oppose the erasure of your personal data because of unlawful processing and you request the restriction of their use instead. If you require the personal data for the establishment, exercise or defense of legal claims, once we no longer need those data for the purposes of the processing. If you have objected to processing on grounds relating to your personal situation pending the verification whether our legitimate grounds override your grounds.
- Right to be informed pursuant to Art. 19 GDPR: If you have asserted the right of rectification, erasure or restriction of processing against the controller, he is obliged to communicate to each recipient to whom the personal date has been disclosed any rectification or erasure of personal data or restriction of processing, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients.
- Right to data portability pursuant to Art. 20 GDPR: You shall have 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 require that those data be transmitted to another controller, where technically feasible.
- Right to withdraw a given consent pursuant to Art. 7 (3) GDPR: You have the right to withdraw your consent for the processing of personal data at any time with effect for the future. In the event of withdrawal, we will immediately erase the data concerned, unless further processing can be based on a legal basis for processing without consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- Right to lodge a complaint pursuant to Art. 77 GDPR: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
11.2 RIGHT TO OBJECT
IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.
12) Duration of Storage of Personal Data
The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).
If personal data is processed on the basis of an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.
If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.
When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
If personal data is processed for the purpose of direct marketing on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.
Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.