- The nature of the personal information processed;
- The purposes and means of the processing of personal information;
- The identity and contact details of the data controller(s);
- The contact details of the Data Protection Officer (DPO);
- Any third parties involved in the processing activities;
- The retention period of personal information;
- The security measures adopted to protect personal information;
- The privacy rights of users.
Users with fewer than 16 (sixteen) years old are not allowed to consent to the processing of Personal information without parental authorization.
The joint controllers for the data processing related to the activities of the Site are:
- Onest GmbH whereas ETIQL is a brand of the Onest GmbH, Am Sandtorkai 23, 201457 Hamburg; contact: firstname.lastname@example.org
- Fully accredited lawyer Joerg Offeney; Hans Boeckler Allee 9, 30173 Hannover; email@example.com (the "Controllers")
There is a designated Data Protection Officer to ensure that the Site processes personal information in compliance with the GDPR. The DPO can be contacted for any enquiries at the following email address: firstname.lastname@example.org
Personal information is collected automatically by the Site or received via multiple sources: forms, chat, e-mail, apps, devices, social media and other means.
The Site processes personal information in various shapes for the following purposes:
• Browsing data
The Site collects non-sensitive browsing data by automatic means in order to enable and improve user navigation (e.g., IP address, date/time of the visit and its length, any referring URL, the pages visited on the Site, the device used and other information). The processing of such information allows users to access the Site and fully enjoy its features and services. Furthermore, browsing data may be used to verify that the Site is functioning properly. From time to time, browsing data are processed anonymously for statistical purposes. Browsing data are unlikely to allow identification of the relevant data subject. However, by their very nature, browsing data may allow identification of the users if associated with other information. The browsing data described above are stored only temporarily in compliance with the applicable law.
At checkout, the Site asks users to provide personal information for the essential purpose of fulfilling their purchase orders and comply with contractual obligations (e.g., name and surname, e-mail address, delivery address, etc.).
Such personal information is also essential for the Customer Service to assist customers on enquiries and for any related necessity, before or after the sale (for instance, with respect to the order delivery status or on product returns).
Personal information related to orders will be stored as long as required to comply with contractual obligations and with the applicable tax and financial reporting obligations.
The Site may also verify the payment instruments used by customers to purchase on the Site (e.g. credit or debit card, etc.) for the main purpose of preventing fraudulent activities or pursuant to the applicable anti-money-laundering laws. As full reliance for payment verification is given to third party payment processors, the Controllers do not process or store any financial information belonging to customers.
Failure to provide the personal information required at checkout will prevent users from completing an order on the Site.
Based on its legitimate interest to improve its relationship with customers, the Site will send to the latter email communications with product suggestions, discounts, feedback requests or other updates. Customers are always free to unsubscribe from such email communications (for instance, by clicking on the “unsubscribe link” at the bottom of each email).
• Site Registration
When users opt to register a personal Site account, they are asked to submit personal information (e.g., date of birth, gender, etc.). The Site clearly indicates which personal information is mandatory (or not) to set up a Site account.
Users must submit personal information that is true and accurate at the moment of registration and are invited to maintain their personal information up-to-date (if any modification occurs) by logging into the personal account to make all relevant changes.
Users who choose to enable or log in to their Site account via a social media, should be aware that when they connect their Site account to a social media account, the Site collects certain personal information the User has already provided to that social media (for example, the email address and public profile on Facebook).
The Controllers do not oversee or control such social media services or the user’s profiles on these services, and do not establish privacy settings or rules for how personal information on those services will be used. Users are highly encouraged to read all policies and information regarding the applicable social media services to learn more about how they process personal information.
• Newsletter and marketing communications
On the Site, users can opt to receive newsletters and commercial communications.
The Site always collects the explicit, free and unambiguous consent of users prior to submitting newsletters and marketing communications to these users or, more in general, before undertaking electronic marketing initiatives dedicated to them.
In such cases, users may be invited to submit personal information in addition to their e-mail address and phone number (e.g., gender, country of residence, etc.) for the purpose of having newsletter and marketing communications tailored to the user profile.
Users can always easily withdraw their consent from receiving newsletters and commercial communications in the following ways:
- Through their account settings;
- By clicking on the ‘unsubscribe’ link in any of such email;
- By contacting our Customer service.
Under the explicit user’s consent, newsletter and marketing communications may be tailored to the user “profile”, based on the personal information the Site collects or receives about the concerned user.
With respect to the customers of the Site, it is in the Site’s legitimate interest to process personal information to offer more interesting products, to improve the Site and to personalize the products offered on the Site.
The main purpose of profiling is to propose products, services and initiatives more responsive to the tastes, shopping habits and interests of users and customers.
Personal information may be also used for remarketing, retargeting or profiling purposes, including via third parties (e.g., social networks, etc.).
Neither the Site nor the Controllers will ever carry out any profiling activities relating to children.
What are cookies
Cookies are small text strings that the Site sends to the user's device, where information is memorized for various purposes. In particular, cookies allow the Site to recognize users on subsequent visits or enable other websites to recognize such users for particular purposes.
What kind of cookies the Site uses
The Site uses various types of cookies for different purposes:
• Technical cookies
Technical cookies are cookies enabling users to browse on the Site or to enjoy its basic features. These cookies are installed automatically on the user device by the Site as a result of the user’s access to the Site and do not require any specific consent by the user.
Indeed, consent is not required by the law if and when a cookie is:
- Used for the sole purpose of carrying out the transmission of a communication; and
- Strictly necessary in order for the provider of a digital service explicitly required by the user to provide that service.
Technical cookies used by the Site include:
- Navigation cookies: to ensure the normal browsing and use of the Site, through different options or services;
- Functional cookies: to save user preferences and facilitate the browsing experience based on a set of selected criteria (for example, language, browser type, etc.).
The Site also collects the IP address or any other identifying information on the user device that is necessary in order to manage the Site, diagnose server problems and meet other lawful purposes. Disabling technical cookies may limit the ability of users to browse the Site and to enjoy its features or the services offered.
• Other cookies
All cookies other than technical cookies are installed or activated only if previous consent by “opt-in” is given by users.
On their first visit to the Site, users are shown a cookie banner on the screen or interface. This banner will disappear once the user has accepted or refused the cookies used on the Site.
Opt-in may be expressed in a general way, for instance by closing the banner, or by clicking the OK button, or by scrolling the page or clicking on any of its elements; opt-in can be also provided in a selective way.
Opt-in given by users is tracked and recorded in order to make their next visits to the Site more effective. However, users can always revoke all or part of the consents previously given.
The non-technical cookies used by the Site are third-party cookies: cookies set up on the user’s device by a domain or website distinct from the Site. Third party cookies are implemented by marketing vendors and partners of the Site by the means of third party tags. The Site does not control such cookies.
The Site does not have any access or control over cookies or other tracking technology used by third parties accessible by the Site and cannot ensure compliance of third parties with the applicable privacy law.
• Advertising cookies
These cookies allow the Site to create an anonymous profile of users based on their browsing experience on this Site and on others. In such a way, it is possible to provide users with advertisements targeted to their interests rather than generic advertising. This is a list of advertising cookies (it includes a link to more information on such cookies and the instructions to manage user consent):
• Retargeting cookies
These cookies allow third-parties to send advertising to users who have previously visited the Site. This is a list of retargeting cookies (it includes a link to more information on such cookies and the instructions on how to manage user consent):
• Social media cookies
These cookies are needed to share content on social networks. This is a list of social media cookies (it includes a link to more information on such cookies and the instructions on how to manage user consent):
• Analytical cookies
These cookies are collected by third parties, in individual or aggregated form, in order to collect information on the number of users and on how they visit the website, such as information on which pages or sections are most viewed. This is a list of analytical cookies (it includes a link to pages with more information on such cookies and the instructions on how to manage user consent):
Users can manage cookie preferences through their web browser settings:
For more information, Users can visit:
www.allaboutcookies.org or www.youronlinechoices.com
Users wishing to contact the Site concerning any matter relating cookies are encouraged to write to: privacy.ETIQL@thelevelgroup.com
For instance, the Controllers may share personal information with the following categories of Processors:
- Through their account settings;
- By clicking on the ‘unsubscribe’ link in any of such email;
- By contacting our Customer service.
In such cases, sharing personal information with the Processors is necessary for the Controllers to fulfill their contractual obligations and, also, to improve the Site’s products and services. Users can request an updated list of the Processors involved in the processing of personal information relevant to the Site’s activities by writing an email to: email@example.com The Controllers must always reserve the right to disclose personal information about users as required by law (for instance, in response to law enforcement requests), and where needed to protect the rights of the Controllers or their affiliates or third parties. Moreover, personal information may be disclosed to other companies within the same corporate group of each of the Controllers, or to third parties in the event of a corporate restructuring process, in full compliance with the applicable law. In any other cases, the sharing of personal information will be conditional upon the preliminary and explicit consent of the user, unless processing is allowed under an alternative legal basis. The Controllers will not transfer any personal information outside the European Economic Area (EEA), unless the user has explicitly authorized such transfer or the transfer of personal information outside the EEA is allowed by the GDPR on another legal basis.
Only authorized employees of the Controllers, and authorized employees of the third-party suppliers, acting as Processors on behalf of the Controllers, have access to personal information related to the Site activities. Data processing agreements are in place with the Processors to ensure that they always meet the level of security required by the GDPR while processing personal information related to the Site activities.
While the Site adopts primary security measures to prevent loss, destruction or dissemination of personal information, at the same time it cannot exclude the safety risks that are naturally involved by online transmission of data. The user accepts the inherent risks of providing personal information over the internet and will not hold the Site responsible for any breach of security, unless this breach is due to the Site’s negligence or willful default.
In order to determine the appropriate retention period for personal information stored by the Site under user consent, the Controllers will take into account multiple factors to ensure that personal information is not stored for longer than the necessary or appropriate period. Such criteria will also include:
- The purpose for which the Site holds personal information;
- Legal, tax and regulatory obligations in relation to that personal information;
- The type of ongoing relationship with the concerned user or customer (how often the user logs into their Site account, whether users continue to receive marketing communications, how regularly they browse or buy on the Site, etc.);
- Any specific user request in relation to the deletion of personal information;
- Legitimate business interests.
- The Site will promptly delete or anonymize personal information that is no longer needed or retained according to the law.
If this is the case, under the GDPR, users also hold the rights to:
- Be informed about the collection and use of their personal information;
- Access their personal information at no cost;
- Have inaccurate personal information rectified, or completed (when it is incomplete);
- Have personal information erased (“the right to be forgotten”);
- Under specific conditions, obtain the restriction or suppression of their personal information;
- Obtain and reuse their personal information for their own purpose across different services when processing is based on a contract or on consent, and the processing is carried out by automatic means (“the right to data portability”);
- Under specific conditions, to object to the processing of their personal information;
- Object at any time to the use of personal information for “profiling” or “automated decision-making” purposes;
- The right to submit complaints related to the collection and processing of personal information to the competent supervisory authority;
- The right to withdraw consent to the processing of personal information at any time.
- Users can contact the Site for any enquiry and to exercise their privacy rights at the following email address: firstname.lastname@example.org