Privacy Policy

This privacy policy explains the nature, scope, and purpose of the processing of personal data (hereinafter referred to as "data") within our online offering and the associated websites, functions, and content, as well as external online presences, such as our social media profiles (hereinafter jointly referred to as the "online offering"). With regard to the terms used, such as "processing" or "controller," we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR). Responsible: JAN&INA Traditional Costumes STORE Owner: Janina Maria Albrecht Hiltenspergerstr.36/ corner of Hohenzollernstraße 80796 Munich Phone: + 49 89/ 740 38 297 Email: servus@janinatrachten.de Types of data processed: - Inventory data - Contact details - Content data - Contract data - Payment details - Usage data - Meta/communication data Processing of special categories of data (Article 9 (1) GDPR): No special categories of data are processed. Categories of data subjects: - Customers, interested parties, visitors and users of the online offer, business partners. - Visitors and users of the online offer. In the following, we refer to the data subjects collectively as “users”. Purpose of processing: - Provision of the online offer, its contents and shop functions. - Provision of contractual services, service and customer care. - Answering contact requests and communicating with users. - Marketing, advertising and market research. - Security measures. Status: May 2018

1. Terms used

1.1. “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 1.2. "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually all data handling. 1.3. The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.

2. Relevant legal bases

In accordance with Art. 13 GDPR, we inform you of the legal basis for our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR, the legal basis for processing to fulfill our services and implement contractual measures as well as to answer inquiries is Art. 6 (1) (b) GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 (1) (c) GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 (1) (f) GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.

3. Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.

4. Security measures

4.1. In accordance with Art. 32 GDPR, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, implementation costs, the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons. These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, and transmission, ensuring availability, and segregation. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and response to data threats. Furthermore, we consider the protection of personal data right from the development or selection of hardware, software, and processes, in accordance with the principle of data protection by design and through data protection-friendly default settings (Art. 25 GDPR). 4.2. The security measures include, in particular, the encrypted transmission of data between your browser and our server.

5. Disclosure and transfer of data

5.1. If, as part of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if transmission of the data to third parties, such as payment service providers, is necessary to fulfil the contract in accordance with Art. 6 (1) (b) GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to fulfil our contractual obligations, administrative tasks and obligations efficiently and effectively). 5.2. If we commission third parties to process data on the basis of a so-called “order processing agreement”, this is done on the basis of Art. 28 GDPR.

6. Transfers 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 if this occurs as part of the use of third-party services or the disclosure or transmission of data to third parties, this will only occur if it is necessary to fulfill our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or have data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means that processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level equivalent to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

7. Rights of data subjects

7.1 You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR. 7.2. Pursuant to Article 16 of the GDPR, you have the right to request the completion of your personal data or the rectification of inaccurate data concerning you. 7.3. In accordance with Art. 17 GDPR, you have the right to request that the data in question be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with Art. 18 GDPR. 7.4 You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 GDPR and to request that it be transmitted to other responsible parties. 7.5. You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.

8. Right of withdrawal

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

9. Right of objection

You may object to the future processing of your data at any time in accordance with Art. 21 GDPR. In particular, you may object to processing for direct marketing purposes.

10. Cookies and right to object to direct advertising

10.1 Some of our websites use so-called cookies. Cookies do not harm your computer and do not contain viruses. Cookies serve to make our services more user-friendly, effective, and secure. Cookies are small text files that are stored on your computer and saved by your browser. 10.2 Most of the cookies we use are so-called "session cookies." They are automatically deleted after your visit. Other cookies remain stored on your device until you delete them. These cookies allow us to recognize your browser the next time you visit. 10.3 You can set your browser so that you are informed about the use of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted. A general objection to the use of cookies used for online marketing purposes can be declared for many services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ . Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case, not all functions of this online service can be used. 10.4 Cookies that are necessary to carry out electronic communication or to provide certain functions you have requested (e.g., shopping cart function) are stored on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in storing cookies to ensure the technically error-free and optimized provision of its services. If other cookies (e.g., cookies for analyzing your surfing behavior) are stored, these are treated separately in this privacy policy.

11. Deletion of data

11.1. The data we process will be deleted or restricted in accordance with Articles 17 and 18 of the GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no statutory retention periods that prevent deletion. If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons. 11.2. According to legal requirements, the retention period is in particular 6 years according to Section 257 Para. 1 HGB (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and 10 years according to Section 147 Para. 1 AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.

12. Order processing in the online shop and customer account

12.1. We process our customers' data as part of the ordering process in our online shop in order to enable them to select and order the selected products and services, as well as to pay for and deliver them or execute them. 12.2. The data processed includes inventory data, communication data, contract data, payment data, and the data subjects include our customers, prospective customers, and other business partners. The processing is carried out for the purpose of providing contractual services within the scope of operating an online shop, billing, delivery, and customer services. We use session cookies to store the shopping cart contents and permanent cookies to store the login status. 12.3. Processing is based on Art. 6 (1) (b) (execution of order transactions) and (c) (legally required archiving) GDPR. The information marked as required is necessary to establish and fulfill the contract. We will only disclose this data to third parties in the context of delivery, payment, or within the scope of legal permissions and obligations to legal advisors and authorities. Data will only be processed in third countries if this is necessary to fulfill the contract (e.g., at the customer's request during delivery or payment). 12.4. Users can optionally create a user account, which allows them, in particular, to view their orders. During registration, the required mandatory information is communicated to users. User accounts are private and cannot be indexed by search engines. If users cancel their user account, their data relating to the user account will be deleted, unless retention is necessary for commercial or tax law reasons in accordance with Art. 6 (1) (c) GDPR. Information in the customer account remains until it is deleted and subsequently archived in the event of a legal obligation. It is the user's responsibility to back up their data before the end of the contract if the contract is terminated. 12.5. During registration and subsequent registrations, as well as when using our online services, we store the IP address and the time of the respective user action. This storage is based on our legitimate interests, as well as the user's interest in protecting against misuse and other unauthorized use. This data is generally not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 (1) (c) GDPR. 12.6. Deletion occurs after expiration of statutory warranty and similar obligations; the necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, deletion occurs after their expiration (end of commercial (6 years) and tax (10 years) retention periods); information in the customer account remains until its deletion.

13. Contact and customer service

13.1. When you contact us (via contact form or email), the user's information will be processed to process the contact request and its handling in accordance with Art. 6 (1) (b) GDPR. 13.2. User information may be stored in our Customer Relationship Management System ("CRM System") or similar request organization. 13.3. We delete inquiries if they are no longer required. We review their necessity every two years. We permanently store inquiries from customers who have a customer account and refer to the customer account information for deletion. Furthermore, statutory archiving requirements apply.

14. Collection of access data and log files

14.1. Based on our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, we collect data about every access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, the file, the date and time of access, the amount of data transferred, the notification of successful access, the browser type and version, the user's operating system, the referrer URL (the previously visited page), the IP address, and the requesting provider. 14.2. Log file information is stored for security reasons (e.g., to investigate misuse or fraud) for a maximum of thirty days and then deleted. Data that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been finally resolved.

15. Online presence in social media

15.1. Based on our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, we maintain online presences within social networks and platforms in order to communicate with customers, interested parties, and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply. 15.2 Unless otherwise stated in our privacy policy, we process users’ data if they communicate with us within the social networks and platforms, e.g. by writing posts on our online presence or sending us messages.

16. Google Analytics

16.1. Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR), we use Google Analytics, a web analysis service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offering by users is usually transferred to a Google server in the USA and stored there. 16.2. Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ). 16.3. Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on the activities within this website, and to provide us with other services related to the use of this website and internet usage. In doing so, pseudonymous user profiles may be created from the processed data. 16.4. We only use Google Analytics with activated IP anonymization. This means that the user's IP address will be shortened by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. 16.5. The IP address transmitted by the user's browser will not be merged with other data held by Google. Users can prevent cookies from being saved by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the website, as well as from processing this data, by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de . 16.6 You can prevent Google Analytics from collecting your data by clicking on the following link. This will set an opt-out cookie that prevents the collection of your data on future visits to this website: [google_analytics_optout]Disable Google Analytics[/google_analytics_optout]. 16.7. Further information on data usage by Google, settings and objection options can be found on the Google websites: https://www.google.com/intl/de/policies/privacy/partners (“How Google uses data when you use our partners’ websites or apps”), https://policies.google.com/technologies/ads (“How Google uses data for advertising purposes”), https://adssettings.google.com/authenticated (“Manage information that Google uses to show you ads”).

17. Communication via mail, email, fax or telephone

17.1 We use means of remote communication, such as mail, telephone, or email, for business transactions and marketing purposes. In doing so, we process inventory data, address and contact details, as well as contract data of customers, participants, interested parties, and communication partners. 17.2 Processing is based on Art. 6 (1) (a), Art. 7 GDPR, Art. 6 (1) (f) GDPR in conjunction with statutory requirements for advertising communications. Contact will only be made with the consent of the contact partner or within the scope of legal permissions, and the processed data will be deleted as soon as they are no longer required, or otherwise upon objection/revocation or the expiration of the authorization basis or statutory archiving obligations.

18. Newsletter

18.1. The following information informs you about the content of our newsletter, the registration, dispatch, and statistical evaluation procedures, as well as your right to object. By subscribing to our newsletter, you agree to receive it and to the described procedures. 18.2. Newsletter Content: We send newsletters, emails, and other electronic notifications containing promotional information (hereinafter "newsletters") only with the recipient's consent or legal permission. If the newsletter content is specifically described when registering for the newsletter, it is decisive for the user's consent. Furthermore, our newsletters contain information about our products, offers, promotions, and our company. 18.3. Double opt-in and logging: Registration for our newsletter is carried out using a so-called double opt-in process. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to ensure that no one can register using someone else's email address. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes saving the time of registration and confirmation, as well as the IP address. Changes to your data stored by the shipping service provider are also logged. 18.4. Shipping service provider: The newsletter is sent via "MailChimp," a newsletter distribution platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the shipping service provider's privacy policy here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection standards (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). 18.5. If we use a shipping service provider, the shipping service provider may, according to its own information, use this data in pseudonymous form, i.e., without assignment to a user, to optimize or improve its own services, e.g., for the technical optimization of the delivery and presentation of the newsletter or for statistical purposes to determine which countries the recipients come from. However, the shipping service provider does not use the data of our newsletter recipients to contact them directly or to pass it on to third parties. 18.6. Registration data: To subscribe to the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name for the purpose of addressing you personally in the newsletter. 18.7. Performance Measurement - The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or if we use a shipping service provider, from their server. During this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the 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 individual newsletter recipients. However, it is neither our aim nor, if used, that of the shipping service provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. 18.8. The newsletter is sent and its success is measured on the basis of the recipient’s consent in accordance with Art. 6 (1) (a), Art. 7 GDPR in conjunction with Section 7 (2) No. 3 of the German Unfair Competition Act (UWG) or on the basis of legal permission in accordance with Section 7 (3) of the UWG. 18.9. The registration process is logged on the basis of our legitimate interests pursuant to Art. 6 (1) (f) GDPR and serves as proof of consent to receive the newsletter. 18.10. Newsletter recipients can cancel their subscription to our newsletter at any time, i.e. revoke their consent. You will find a link to cancel the newsletter at the end of each newsletter. This will also revoke their consent to performance measurement. Unfortunately, a separate revocation of performance measurement is not possible; in this case, the entire newsletter subscription must be canceled. When you unsubscribe from the newsletter, your personal data will be deleted unless its retention is legally required or justified, in which case its processing will be limited to these exceptional purposes. In particular, we can store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them for the purposes of sending the newsletter in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time.

19. Integration of third-party services and content

19.1. Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR), we use content or service offerings from third-party providers within our online offering in order to integrate their content and services, such as videos or fonts (hereinafter collectively referred to as “content”). This always requires that the third-party providers of this content perceive the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may 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 such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online service, as well as be linked to such information from other sources. 19.2. The following presentation provides an overview of third-party providers and their content, along with links to their privacy policies, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out). - If our customers use third-party payment services (e.g. PayPal or Sofortüberweisung), the terms and conditions and privacy policy of the respective third-party providers apply, which can be accessed within the respective websites or transaction applications. - External fonts from Google, LLC., https://www.google.com/fonts ("Google Fonts"). Google Fonts are integrated by calling a Google server (usually in the USA). Privacy policy: https://policies.google.com/privacy , Opt-out: https://adssettings.google.com/authenticated . - External "reCaptcha" anti-spam technology from Google, LLC., https://www.google.com/fonts ("Google Fonts"). The Google reCaptcha box is integrated by calling a Google server (usually in the USA). Privacy policy: https://policies.google.com/privacy , Opt-out: https://adssettings.google.com/authenticated . - Maps from the "Google Maps" service provided by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/ , Opt-out: https://www.google.com/settings/ads/ . – Videos from the "YouTube" platform of the third-party provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/ , Opt-out: https://www.google.com/settings/ads/ .