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Privacy Policy

100 mins read

A. Summary

We take your privacy very seriously and are committed to being transparent with how we use your information. This website (www.pamusoroi.com), mobile application and any of our services and sites directing you to this Privacy Policy are controlled by Full Of Pixels LTD, 34 Kingswood Close, Camberley, GU15 4BH, United Kingdom (collectively “we” or “us”).

This Privacy Policy also incorporates the terms contained in the Terms of Use, the Copyright Policy and the PAMUSOROI! Imprint.

Data controller & responsible body

Full Of Pixels LTD, 34 Kingswood Close, Camberley, GU15 4BH, United Kingdom

Duly represented by Muranganwa Mukundu

Data process manager, [email protected]

Our Privacy Policy Explains
  • What information we collect and why we collect it (section I – XI)
  • How we use that information (section I – XI)
  • A notice to users from California (section XII)
  • Your rights with regard to the processing of personal data by PAMUSOROI! (section XIII)

If you have any questions about this Privacy Policy or would like to know more about what information we collect and store, please contact us at [email protected].

Purpose of data collection, data processing and data use

PAMUSOROI! is engaged in operating online publications covering forthcoming trends and news in fashion, art, music, and culture. PAMUSOROI! collects and processes personal data for the following purposes:

  • Operation of the website, including statistical analysis of the use
  • Provision of content
  • Advertising
  • Execution of contracts
Groups of people concerned and the associated data and category of data

Customer and user data, data from partner companies that are needed to fulfill the purpose.

Children under 16

Our website is not directed toward children under 16 and we will not knowingly collect information for any child under the age of 16.

If you are the parent of a child under the age of 16 and have a concern regarding your child’s information on our website, please contact us at [email protected].

Recipients or groups of recipients to whom data may be disclosed

Public authorities in connection with an overriding legal regulation, contractors in connection with a partnership in accordance with Article 28 of the General Data Protection Regulation (GDPR), external partners and internal departments of PAMUSOROI! to fulfill the purpose.

Time limits for the deletion of data

Under statutory provisions, a variety of obligations and periods apply with regard to the keeping of data. Once these retention periods have expired, the corresponding data must be erased as a matter of routine. Any data not affected by this is deleted if the purposes mentioned above ceases to apply.

Transfer of data to third countries

By using social plugins, such as facebook like button, data may be transferred to a third country.

Legal basis for the collection and processing of personal data

Legal basis for the processing of personal data on the basis of the user’s consent is Art. 6 (1) lit. a GDPR.

Legal basis for the processing of personal data which is necessary for the conclusion or performance of a contract entered in the interest of the user is Art. 6 (1) lit. b GDPR. This also applies to pre-contractual processes.

Legal basis for the processing of personal data which is required to fulfil a legal obligation concerning PAMUSOROI! is Art. 6 (1) lit. c GDPR.

Legal basis for the processing of personal data which is necessary in order to realise a legitimate interest held by either PAMUSOROI! or a third party, except where such considerations are overridden by the need to protect the user’s interests or fundamental rights, is Article 6 (1) lit. f GDPR.

 

B. Information We Collect

We collect information to provide better services to our users and improve our business. We collect information in two ways:

Information you give us or information provided through a social network

For example, some of our services require you to sign up for an account, provide information for a contest or award, or link an account through a social network. The information we collect may include email, name, phone number, address, or credit card information. Such information is necessary to render the services requested and/or to provide contractual services. Legal basis for such data processing is Article 6 (1) lit. a, b or f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose ceases to apply, e.g. if the services are performed in full or if you unsubscribe from our services.

When you contact us, either by email or by using our contact form, we collect the data you have submitted with your request (e.g. name. email) and may keep a record of your communication to help solve any issues you might be facing. Legal basis for such data processing is Article 6 (1) lit. b and lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose ceases to apply, e.g. if we have processed your request.

We work with social networks including, but not limited to Facebook, Twitter, Snapchat, Instagram, and YouTube. We have access to information you directly provide and information through those social networking services based on your privacy settings on those networks. Please see section V. below for further details. Such information serves to enhance the usability of our services. Legal basis for such data processing is Article 6 (1) lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose ceases to apply.

Information we gather from surveys

If you take part in one of our surveys, we store your contact data and the information you provide as part of the survey. We use this data in anonymous form only. It is not possible to draw any conclusions about your person. We publish the results of the survey on our website or share them with partner companies, e.g. advertising partners or connected websites. For example, we may share information to show trends about the general use of our services.

For conducting the surveys we use Typeform, a service of TYPEFORM S. L. , Carrer Doctor Trueta, 113-119, Planta 1, 08005 Barcelona, Spain. The data collected in the survey will be stored on a Typeform server, possibly in the USA. The data is only transmitted and stored in encrypted form. Further information can be found in Typeform’s privacy policy.

The legal basis for such data processing is Art. 6 (1) lit. f) GDPR. The data will be deleted as soon as the purpose of the storage has ceased to exist, e.g. when the survey has been completely evaluated.

Information we get from your use of our services

We may collect usage information when you visit different parts of our site or use our applications. We may also automatically collect certain technical information such as device-specific information (such as your hardware model, operating system version, device type, unique device identifiers, and mobile information if you use a mobile device to access the site). Please see section I. below for details. Such information is necessary to provide our services and is used in anonymized or pseudonymised form only. Legal basis for such data processing is Article 6 (1) lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose ceases to apply.



C. Information We Share

We do not share personal information with companies, outside organizations and individuals unless one of the following circumstances apply:

With your consent

We will share personal information with companies, outside organizations or individuals if we have your consent to do so. We may also seek your additional consent for purposes subsequently notified to you.

For external processing

We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These companies are authorized to use your personal information only as necessary to provide these services to us. If personal data is transferred to or processed in countries outside the European Union, we make sure that our contractors guarantee an adequate level of data protection.

For legal reasons

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We will share personal information with companies, outside organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, detect, prevent, or otherwise address fraud, security or technical issues or protect against harm to the rights, property or safety of our users or the public as required or permitted by law. 


In case of a sale or asset transfer

If we become involved in a merger, acquisition or other transaction involving the sale of some or all of our assets, user information, including personal information collected from you through your use of our services, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you and ask for your consent where applicable.

In anonymous form for business purposes

We may share anonymous, non-personally identifiable information publicly and with our partners such as businesses which we have a relationship with, advertisers or connected sites. For example, we may share information to show trends about the general use of our services.

D. Information Security

We work hard to protect our users from unauthorised access to or unauthorised alteration, disclosure or destruction of information we hold however no website is entirely secure. You should protect the account information in your possession as well. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at [email protected]

I. Your Privacy Consent Management

When visiting our website, we will ask you for your consent to use certain cookies. You can at any time revoke your consent for either all services or for individual services by clicking the button below. If you have any questions or concerns on this process send an email to [email protected]. Edit your consent preferences online [ultimate_gdpr_cookie_popup]here [/ultimate_gdpr_cookie_popup].

Cookies

Technologies such as: cookies, beacons, tags and scripts are used by us and our advertising and marketing partners, affiliates, or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. We use cookies to remember users’ settings (e.g. geographic location) and for authentication. You can decide whether to accept cookies.

In addition, users can control the use of cookies at the individual browser level by changing your browser settings (mostly found under “Options” or “Settings” in the browser menu). You have the choice of accepting all cookies, being informed about each cookie or refusing all. To manage Flash cookies, please click here.

If you choose not to accept cookies on our website, it is possible that the functionality of our website may be limited and some services may not be usable.

We and our service providers, marketing partners, and affiliates may use advertising cookies to deliver ads that we believe are more relevant to you and your interests. For example, we may use targeting or advertising cookies to customize the advertising and content you receive on our site, to limit the number of times you see the same ad on our site and to help measure the effectiveness of our advertising campaigns. These cookies remember what you have looked at on the site and other sites, and may be combined with other information acquired from third parties.

You may visit the links below to opt-out of cookies from over 50+ major third party behavioral advertising providers:

Please see below for a full list of cookies and detailed information on the associated processing of personal data and how to opt-out of the use:

II. Cookies we use with your consent only

We will only use such cookies with your prior consent. Legal basis for such data processing is Article 6 (1) lit. a GDPR. Unless statutory provisions provide otherwise, the data will be deleted if you revoke your consent or if the purpose ceases to apply. In any cases, personal data will be deleted after 24 months at the latest.

Usercentrics Consent Management Platform

We use Usercentrics, a Consent Management Platform provided by Usercentrics GmbH, Rosental 4, 80331 Munich, Germany (“Usercentrics”). The Consent Management Platform allows us to comply with the statutory provision pursuant to Art 7 (1) lit. a GDPR. This allows Usercentrics to inform the users about specific tags and web technologies on our website and to obtain, manage and document the users’ consent. This represents the legal basis which is required for all processing purposes by the GDPR. Common legal grounds are Art. 1 (6) (a) GDPR, if a user has given their consent and Art. 1 (6) (f), if the processing of personal data is essential for providing the services, Art. 6 (1) (c) GDPR. Our aim is to know and act according to our users’ preferences as well as to document these in a legally allowed and secure manner. The data is deleted as soon as it is no longer required.

Technologies Used
  • Cookies
  • Local storage
  • JavaScript

You can permanently disable the execution of JavaScript at any time by selecting the relevant settings in your browser, which would also prevent Usercentrics from executing JavaScript. For further details see Usercentrics’ privacy policy

Data Attributes
  • Consent “Yes” or “No”
  • Log file data (IP (anonymised)
Data Collected

This list represents all (personal) data that is collected by or through the use of this service.

  • Date and time of visit
  • Device information
  • Browser Information
  • Anonymized IP address
  • Opt-in and opt-out data
Location of Processing

European Union

Duration to store the data

The revocation certificate of a previously given consent will be kept for a period of three years. On the one hand, storage is based on our accountability according to Art. 5 para. 2 GDPR. This obliges the compliance with the processing of personal data according to the General Data Protection Regulation. On the other hand, storage in the regular limitation period according to § 195 BGB of three years. This limitation period begins with the end of the year in which the claim arose (§ 199 BGB). Consequently, the three-year limitation starts at the end of 31. 12. and ends three years later on 31. 12. , 24. 00.

Contact

You can contact the data protection officer of the processing company at [email protected].
Further Information and Opt-out

See the Usercentrics privacy policy.
Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc. , 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (“Google”), on our website. Google Analytics uses so-called “cookies”, text files that are saved on your computer and that enable your use of the website to be analyzed. The cookie-generated information about your use of our website is usually transmitted to and stored on a Google server in the United States. However, if you are in a country that is a member state of the European Union or a contracting party to the Agreement on the European Economic Area, and if IP address anonymization has been activated on our website, Google will first truncate your IP address. Only by way of exception will the full IP address be transmitted to a Google server in the United States and truncated there. Google will use this information on our behalf for the purposes of analyzing how you use our website, compiling reports on website activity and providing further services related to website and internet use to the website operator. The IP address transmitted through Google Analytics from your browser will not be associated with any other data held by Google. You can disable cookies by setting your browser accordingly; however, if you do this you may not be able to use the full functionality of our website. You can also prevent the data generated by the cookie and related to your use of this website (including your IP address) being transmitted to and processed by Google by downloading and installing the browser plug-in available here: http://tools. google.com/dlpage/gaoptout?hl=en

More detailed information about the function of Google Analytics and the terms of use and privacy policy relevant to this service can be found under http://www.google.com/analytics/terms/gb.html and http://www.google. de/intl/en/policies/privacy/. We would also like to point out that our website uses Google Analytics with the anonymizeIP extension so that IP addresses are only processed further in an abbreviated form to prevent them being directly linked to a particular individual.
Google Universal Analytics

We use Google Universal Analytics, a service provided by Google LLC, to collect information about and to analyse the use of our website. During registration, a cookie containing a unique user ID is set. This allows Google to associate user behavior on different devices with a single user. The information collected, directly and indirectly, by the cookie (technical specifications like device type, browser version, operating system, screen resolution and user behaviour like pages visited, interactions with our content, duration of your visit, products viewed and purchased in our own shop or linked to at other shops) is stored on a Google server in the US. Google has a Privacy Shield certification, which ensures an appropriate level of data protection. Google uses this data to create user profiles on our behalf. No further data will be submitted to Google that would enable identification of the user. We combine the user profiles created by Google with other data, including personal data about the user, which we collect via MailChimp (Newsletters), CommerceTools ( Highsnobiety Store), Google Ad Server (Advertising) and social networks like Facebook, Instagram in order to evaluate user behavior. We use this information to improve our service and to display interest-based recommendations for content and shopping products. The user profiles will not be shared with third parties (we may share anonymous summaries and reports with our partners). The cookie expires after 24 months. The user profiles in Google Analytics are stored for 24 months. The profiles created by us are stored for 24 months. You can revoke your consent at any time at You can revoke your consent at any time at I. Cookies and by sending an email to [email protected].
Google AdSense

Our website also utilizes Google AdSense, a Google Inc. service that allows Google to place automatically generated, content-related advertisements on our website. For further information on Google AdSense, please see https://www.google.com/adsense/start/. Similarly to Google Analytics, Google AdSense uses cookies that are saved on your computer and that enable analysis of your use of our website. Additionally, Google AdSense utilizes “web beacons” (invisible graphics), which also enable an evaluation of your use of our website. The information regarding the use of this website (including your IP address) generated by cookies and web beacons, and the delivery of advertising formats, are transferred to a Google server, where they are saved. Google uses such information to evaluate your use of the website, to compile reports on the website activities and to provide other services to us in relation to website and internet use. Furthermore, Google may pass on this data to its advertising partners. We would like to point out that, in contrast to Google Analytics, Google has as yet not taken measures to anonymize your IP address for its Google AdSense service. Therefore, in addition to the previously mentioned data relating to your use of our website, your IP address will also be transferred to, and saved on, a Google server. You can disable cookies by setting your browser accordingly; however, if you do this you may not be able to use the full functionality of our website.
Google DoubleClick Ad Exchange and Google Tag Manager

Our website uses Google Double Click Ad Exchange and Google Tag Manager software provided by Google. These services allow website providers to address their visitors in a targeted fashion by displaying personalized, interest-based advertisements when they visit other websites that are part of the Google Display Network. Google utilizes cookies to analyze how users use a website. The information collected with these cookies form the basis for interest-based advertising. To do so, Google stores a small sequence of numbers in the browser of the visitor calling on the website. This number is used to record the visits to the website and collect anonymized data on how the website is being used. No personal data are collected in the process. If you subsequently visit another website that is part of the Google Display Network, you will be served advertisements that are very likely to be related to the products or information that you have previously viewed. You can permanently deactivate the cookies used by Google if you click on the following link and download and install the plug-in contained therein: https://www.google.com/settings/ads/plugin. Alternatively, you can deactivate the use of cookies through third parties by visiting the deactivation page of the Network Advertising Initiative at http://www.networkadvertising. org/choices/ and following the opt-out instructions contained therein. Further information on Google remarketing and the privacy policy of Google can be found at: http://www.google.com/privacy/ads/.
Google DoubleClick for Publisher

Our website uses DoubleClick for Publishers (“DFP”), a service of Google. DFP is a platform for the placement, management and optimization of ads on websites. DFP allows us to present personalized ads to website visitors who have shown interest in certain content areas. This is made possible through an analysis of their use of our website, including other site pages, and on other websites within the Google display network (Google itself, Google Ads, and other websites). For this purpose, Google uses cookies, which are stored on your computer. DoubleClick cookies do not contain or store any personal data of users. You can deactivate personalized Google ads in your browser by clicking the “Turn off” button under “Ads Personalization Across the Web” at http://www.google.com/settings/ads, or, if you use the Google Chrome, Firefox or Microsoft Internet Explorer browser, by installing the DoubleClick opt out extension offered for your browser at https://support. google.com/ads/answer/7395996?hl=en
Quantcast

Our website uses Quantcast Measurement, a service provided by Quantcast Corp. , 201 3rd Street, San Francisco, CA 94103, USA („Quantcast“). Quantcast provides us with a service for audience measurement and for advertising purposes. Using Quantcast allows us to address the users of our website in a targeted manner. Quantcast collects information on how you use our services, including your IP address (not your name, email address or other personally identifiable information). Such information is stored on Quantcast’s servers in the US and is provided to us in aggregated form only. Further information on the processing and use of data by Quantcast can be found in Quantcast’s privacy policy.

You may opt-out of data collection by Quantcast at any time by following this link: https://www.quantcast.com/opt-out/
Scorecard Research

Our website uses Scorecard Research, a service provided by Full Circle Studies, Inc. , 11950 Democracy Drive, Reston, VA 20190, USA („Scorecard“). Scorecard collects information on how you use our services, including information about your operating system, browser type and website preferences and your activities on our website. Such information is used to create reports on the use of our website that helps us to understand our user’s behaviour and to provide with you content and advertising based on your interests and preferences. Further information on the processing and use of data by Scorecard can be found in Scorecard‘s privacy policy

You may opt-out of data collection by Scorecard at any time by following this link: www.scorecardresearch.com/privacy.aspx
comScore

Our website uses audience measurement services provided by comScore Inc. („comScore“).comScore uses cookies to collect information about our audience (e.g. demographic data such as region, language, age group, gender), their behavior (e.g. devices they use, how they use our content or websites they visit) and the efficiency of our advertising campaigns. In most cases, this information is pseudonymised or anonymized. Further information on the processing and use of data by comScore can be found in comScore‘s privacy policy and comScore’s GDPR Supplemental Privacy Policy

III. Other cookies we use

Our services are mainly financed by advertising revenues. The use of cookies helps to improve the quality of our website and services and serves to finance our services and is used in anonymized or pseudonymized form only. Legal basis for such data processing is Article 6 (1) lit. f) GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose ceases to apply. In any cases, personal data will be deleted after 24 months at the latest.

Facebook Custom Audiences

Our website uses the “Custom Audiences” remarketing service provided by Facebook Inc. , 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). This service allows us to advertise products and services to the visitors of our website in a targeted fashion by displaying personalized, interest-based Facebook ads to the website’s visitors, when they use the Facebook social network. Articles marked as ‘sponsored post’ may contain a Facebook Custom Audiences tag of our respective partner. In this case, the respective partner is responsible for the data processing.

This tag establishes a direct connection to the Facebook servers when you visit our website. It allows the Facebook server to record which of our webpages you have visited. Facebook allocates this information to your personal Facebook user account. Additional information regarding the collection and utilization of your data by Facebook, your rights in relation to these data and the possibilities to protect your privacy can be found in the privacy policy of Facebook.

If you do not want Facebook to assign this information directly to your Facebook user account, you can deactivate the “Custom Audiences” remarketing service by using the following link: https://www.facebook.com/settings/?tab=ads. You must be logged in on Facebook to do so.

Chartbeat

Our website uses Chartbeat, a service provided by Chartbeat, Inc. , 826 Broadway, 6th Floor, New York, NY 10003, USA („Chartbeat“). Chartbeat is an internet technology company that provides real-time website analytics to monitor content performance. It collects anonymous user data to provide information about how our website is being used and gives us an indication of the content that is of most interest to our website visitors. This includes what pages users are clicking on, how long users spend on each page, whether users are commenting on a page, and whether users are scrolling down pages they click on. This information allows us to provide content that is more useful and relevant for the users of our websites. For details of Chartbeat’s privacy policy, please visit http://www.chartbeat.com.

New Relic APM

Our website uses New Relic Application Performance Monitoring, a service provided by New Relic Inc. , 101 Second Street, 15th Floor, San Francisco, CA 94105 („New Relic“). New Relic APM allows us to monitor and analyse the technical performance of our services and to detect possible faults. New Relic APM collects application data, such as information on the user’s browser and browser add-ons or the hard- and software used. Further information on the processing and use of data by New Relic can be found in New Relic’s privacy policy.

Google Optimize

We use Google Optimize on our website, a service of Google Inc. We use Google Optimize to analyze the use of our website in order to improve the usability of our website and the attractiveness of our content. For this purpose, we provide new functions and content to individual user groups and evaluate user behavior statistically.

Google Optimize uses cookies for this analysis and optimization. The cookie-generated information about your use of our website is usually transmitted to and stored on a Google server in the United States. We are using IP address anonymization on our website. This means that, if you are in a country that is a member state of the European Union or a contracting party to the Agreement on the European Economic Area, Google will first truncate your IP address. Only by way of exception will the full IP address be transmitted to a Google server in the United States and truncated there. Google will use this information on our behalf for the purposes of analyzing how you use our website, compiling reports on website activity and providing further services related to website and internet use to the website operator. The IP address transmitted through Google Optimize from your browser will not be associated with any other data held by Google. You can disable cookies by setting your browser accordingly; however, if you do this you may not be able to use the full functionality of our website. You can also prevent the data generated by the cookie and related to your use of this website (including your IP address) being transmitted to and processed by Google by downloading and installing the browser plug-in available here: http://tools. google.com/dlpage/gaoptout

More detailed information about the processing of data by Google Optimize can be found under http://www.google. de/intl/en/policies/privacy

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc. ) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular the IP address of the device, captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

DISQUS comment function

With your prior explicit consent, you can use the comment function to comment on articles, tips, news and other content on our website. The comment function is an external service that we have integrated into our website, and is provided by Disqus, Inc. , 301 Howard St. , Suite 300, San Francisco, CA 94105 (hereinafter referred to as “DISQUS”). You can use the comment function either as a guest or as a registered user. If you wish to comment on articles on our website as a guest, you must first provide a name under which you wish to comment and a valid email address. This information will be transmitted to DISQUS and saved on their servers. You can also log in and comment using your access data from a pre-existing DISQUS user account or your Facebook or Twitter account.

If you log in using your DISQUS access data, a connection will be made with the DISQUS server and DISQUS will be informed that you are visiting our website and using the comment function. This information will be associated with your DISQUS account. We have no influence on the scope of further data that is provided to DISQUS using the comment function and saved there. DISQUS is solely responsible for this data processing. You can prevent DISQUS collecting data and information, in particular usage data, by opting out on Disqus’ Data Sharing Settings page (click the “opt out” button).

When using the comment function via your Facebook or Twitter account, DISQUS connects to the relevant social network’s server via our website and informs it that you are visiting our website and using the DISQUS comment function. This information will be associated with your Facebook or Twitter account. When registering for DISQUS, Facebook or Twitter will send your user ID to DISQUS if the login information provided and sent by our website (normally an email address) corresponds to the information saved on Facebook or Twitter. At the same time, by logging in using Facebook or Twitter you are authorizing DISQUS to use your data and also the functions of Facebook or Twitter. You can find more information about this by logging in using your Facebook or Twitter account. We have no influence on the volume of further data that is provided to Facebook or Twitter using the comment function and saved there. Facebook or Twitter is solely responsible for this data processing.

For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by DISQUS, Facebook or Twitter, see the privacy rules of the relevant service. These can be found here:

There you will find, amongst other things, information regarding settings for the protection of your privacy and regarding your further rights regarding the collecting, processing and use of your data by DISQUS, Facebook or Twitter.

Legal basis for such data processing is Article 6 (1) lit. a GDPR. You may at any time revoke your consent by using the opt-out link above or by sending an email to [email protected]. Unless statutory provisions provide otherwise, the data will be deleted if the purpose ceases to apply, e.g. if you disable your account.

IV. Store

To place an order, you must create an account using your email address and a personal password.

When placing an order via our store, we collect personal data required to process your order (name, billing address, shipping address, phone number, payment method, email address). These data may be transferred to payment and shipping service providers.

Legal basis for such data processing is Article 6 (1) lit. b GDPR. Due to legal regulations, we are obliged to store data for orders, including addresses and payment details, for 10 years.

Payments via PayPal are handled by PayPal Europe S. à r. l. et Cie, S. C. A. , 22-24 Boulevard Royal, L-2449 Luxembourg („PayPal“). If you choose to pay by using PayPal, the information required to process the order (such as purchase price and quantity, time of purchase, shipping address, billing address, phone number and email address) will be transferred to PayPal. For further information, please see PayPal’s privacy policy.

If you choose to pay by credit card, the information required to process the order (such as credit card number, purchase price and quantity, time of purchase, shipping address, phone number and email address) will be transferred to Stripe (Stripe Payments Europe Ltd. ). Stripe can forward this data to Stripe Inc. based in the USA. In this case, the data is transferred to a server in the USA. Stripe Inc. has a Privacy Shield certification, which ensures an adequate level of data protection.

For payments by credit card, a fraud check is also carried out. For this purpose, data such as credit card number, purchase price and quantity, time of purchase, shipping address, phone number and email address are forwarded to Stripe so that Stripe can verify the identity and carry out the fraud check. As part of the fraud check, an automated decision is made which may lead to the exclusion of the credit card payment method. Legal basis for such data processing is Article 6 (1) lit. f GDPR. For further information, please see Stripe’s Privacy Policy.

V. Links to external social networks and social media widgets

Our website includes links to social networks and social media features. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policies of the companies providing them. Please note that Titel Media is not liable for the privacy policies of these companies. We recommend you to read the privacy policies of those companies after you get to one of their websites.

Facebook Plugins

Our website uses social plugins provided by the social network facebook.com. The responsibility for the processing of data via such plugins lies with Facebook Inc.

The plugins are identifiable by a Facebook logo (white letter f on blue background or a thumb up icon) or the notice “Facebook Social Plugin”. For a full list of all social Plugins please see https://developers. facebook.com/docs/plugins?locale=en_US.

When you visit a page of our website that contains a social plugin of Facebook, your browser establishes a direct connection to Facebook servers. Facebook directly transfers the plugin content to your browser which embeds the latter into the website, enabling Facebook to receive information about your having accessed the respective page of our website. Thus we have no influence on the data gathered by the plugin and inform you according to our state of knowledge:

The embedded plugins provide Facebook with the information that you have accessed the corresponding page of our website. If you are logged into Facebook, your visit can be assigned to your Facebook account. If you interact with the plugins, for example by clicking “Like”, or entering a comment, the corresponding information is transmitted from your browser directly to Facebook and stored by it. Even if you are not logged into Facebook, there is possibility that the plugins transmits your IP-address to Facebook.

For the information on the purpose and scope of data collection and procession by Facebook, as well as your rights in this respect and settings options for protecting your privacy please visit Facebook’s privacy policy.

If you are a Facebook member and do not want Facebook to connect the data concerning your visit to our website with your member data already stored by Facebook, please log off Facebook before entering our website. Further you can block Facebook social Plugins by using add-ons for your browser.

Facebook Page

When you visit our Facebook page, Facebook collects personal data, even if you are not a member of Facebook. Please note that we have no control over the type and scope of such data processing. Facebook provides us with aggregated, anonymous demographic data only that helps us to better understand our audience.

For the information on the purpose and scope of data collection and procession by Facebook, as well as your rights against Facebook in this respect and settings options for protecting your privacy please visit : Facebook’s privacy policy.

Login with Facebook

Our website also allows you to register or sign-up to our services using your Facebook account. If you connect to pamusoroi.com through Facebook, we collect and use in accordance with this Privacy Policy any information you agreed that Facebook could provide to us through its API. Such information may include your name, profile picture, email address, gender, birthday, location and other information you make publicly available via Facebook.

Such information serves to enhance the usability of our services. Legal basis for such data processing is Article 6 (1) lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose ceases to apply.

For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by Facebook, see Facebook’s own privacy rules. There you will find, amongst other things, information regarding settings for the protection of your privacy and regarding your further rights regarding the collecting, processing and use of your data by Facebook.

Twitter

Our website also has links to our Twitter pages and uses social plugins provided by Twitter. When you use Twitter and the “Re-Tweet” feature the pages you visited will be linked to your Twitter-account and published to other users. This also involves transferring data to Twitter. Please note that we as providers of the pages have no knowledge as to the contents of the submitted data or its use by Twitter.

For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by Twitter, see the privacy rules of Twitter. There you will find, amongst other things, information regarding settings for the protection of your privacy and regarding your further rights regarding the collecting, processing and use of your data by Twitter.

Instagram

Our website has links to our Instagram page and uses social plugins provided by the social network of instagram.com. The sole responsibility for Instagram and its website lies with Instagram LLC, 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”).

When you visit a page of our website that contains a social plugin of Instagram, your browser establishes a direct connection to the Instagram servers. Instagram directly transfers the plugin content to your browser which embeds the latter into the website, enabling Instagram to receive information about your having accessed the respective page of our website. Thus we have no influence on the data gathered by the plugin and inform you according to our state of knowledge:

The embedded plugins provide Instagram with the information that you have accessed the corresponding page of our website. If you are logged into Instagram, your visit can be assigned to your Instagram account. If you interact with the plugins, the corresponding information is transmitted from your browser directly to Instagram and stored by it. Even if you are not logged into Instagram, there is possibility that the plugins transmits your IP-address to Instagram.

If you are an Instagram member and do not want Instagram to connect the data concerning your visit to our website with your member data already stored by Instagram, please log off Instagram before entering our website.

For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by Instagram, see Instagram’s own privacy rules. There you will find, amongst other things, information regarding settings for the protection of your privacy and regarding your further rights regarding the collecting, processing and use of your data by Instagram.

Snapchat

Our website has links to our Snapchat page and uses social plugins provided by the social network of Snapchat. The sole responsibility for Snapchat and its website lies with Snapchat, Inc. , Attn: copyright Agent, 63 Market Street, Venice, CA 90291, USA (“Snapchat”).

When you visit a page of our website that contains a social plugin of Snapchat, your browser establishes a direct connection to the Snapchat servers. Snapchat directly transfers the plugin content to your browser which embeds the latter into the website, enabling Snapchat to receive information about your having accessed the respective page of our website. Thus we have no influence on the data gathered by the plugin and inform you according to our state of knowledge:

The embedded plugins provide Snapchat with the information that you have accessed the corresponding page of our website. If you are logged into Snapchat, your visit can be assigned to your Snapchat account. If you interact with the plugins, the corresponding information is transmitted from your browser directly to Snapchat and stored by it. Even if you are not logged into Snapchat, there is possibility that the plugins transmits your IP-address to Snapchat.

If you are a Snapchat member and do not want Snapchat to connect the data concerning your visit to our website with your member data already stored by Snapchat, please log off Snapchat before entering our website.

For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by Snapchat, see Snapchat’s own privacy rules. There you will find, amongst other things, information regarding settings for the protection of your privacy and regarding your further rights regarding the collecting, processing and use of your data by Snapchat.

YouTube

Our website has links to our YouTube page and uses social plugins provided by the social network of YouTube. The sole responsibility for YouTube and its website lies with YouTube LLC with its main office at 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google Inc. with its main office at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

When you visit a page of our website that contains a social plugin of YouTube, your browser establishes a direct connection to the YouTube servers. YouTube directly transfers the plugin content to your browser which embeds the latter into the website, enabling YouTube to receive information about your having accessed the respective page of our website. Thus we have no influence on the data gathered by the plugin and inform you according to our state of knowledge:

The embedded plugins provide YouTube with the information that you have accessed the corresponding page of our website. If you are logged into YouTube, your visit can be assigned to your YouTube account. If you interact with the plugins, the corresponding information is transmitted from your browser directly to YouTube and stored by it. Even if you are not logged into YouTube, there is possibility that the plugins transmits your IP-address to YouTube.

If you are a YouTube member and do not want YouTube to connect the data concerning your visit to our website with your member data already stored by YouTube, please log off YouTube before entering our website.

For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by YouTube, see YouTube’s own privacy rules. There you will find, amongst other things, information regarding settings for the protection of your privacy and regarding your further rights regarding the collecting, processing and use of your data by YouTube.

Spotify

Our website includes functions of the Spotify music service, provided by Spotify AB, Birger Jarlsgatan 61, 113 56 Stockholm, Sweden (“Spotify”). When you visit a page of our website that contains a Spotify plugin, your browser establishes a direct connection to the Spotify servers, enabling Spotify to receive information that you have visited our website. If you click the Spotify button while being logged in to your Spotify account, you can link the content of our pages to your Spotify profile. Thus, Spotify can associate visits to our pages with your user account.

More information on the purpose and scope of data collection, and regarding the further processing and use of your data by Spotify can be found in the Spotify privacy policy.

If you do not want Spotify to connect the data concerning your visit to our website with your member data already stored by Spotify, please log off Spotify before entering our website.

VI. Newsletter

You have the opportunity to receive a newsletter containing targeted information via our web service or new products. In this case we must collect and save your email address, which we will only use to send the newsletter. You can unsubscribe via our website at anytime. At the end of the newsletter you will find a link intended for this purpose and provides a simple way to cancel the newsletter. In this case your data will be deleted.

For sending the newsletter we use MailChimp, a service provided by The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA. The email addresses are processed on our behalf on a MailChimp server in the USA. MailChimp has a Privacy Shield certification that ensures an adequate level of data protection. The email address will be used to send the newsletter.

The newsletters contain a so-called “web-beacon”, i. e. a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. These beacons are used to collect the IP address and the time the newsletter was opened as well as the information as to whether the subscriber has clicked on a link contained in the newsletter. MailChimp uses this data to create reports for us about how an email campaign performed and what actions subscribers took.

If you have expressly consented to receiving our newsletter, the legal basis for such processing of personal data is Art. 6 (1) lit. a GDPR. In case we are entitled to send a newsletter based on your previous purchase of goods or services, legal basis for such processing of personal data is § 7 (3) of the German Act Against Unfair Competition (UWG). In this case, the legal basis for the processing of personal data for the purpose of analysing the campaign performance is our legitimate interest (Art. 6 (1) lit. f) GDPR) in improving the quality of our newsletter.

Unless statutory provisions provide otherwise, the data will be deleted if the purpose ceases to apply, e.g. if you unsubscribe from the newsletter.

VII. Facebook Subscription Messaging

We offer the possibility to subscribe to notifications about upcoming sneaker and product releases (‘Sneaker Bot’) and/or current topics in fashion, lifestyle or music (‘Breaking News Bot’). To do this, we use Facebook Subscription Messaging, a service provided by Facebook Inc. To subscribe to notifications, users must start a communication with Highsnobiety through Facebook Messenger. By clicking the ‘Get Started’ button, the first and last name given in the user’s Facebook profile, gender and location are transmitted to us and stored. This data is required for sending the messages.

We use technologies from Spectrm Publishing UG, Bredower Str. 31, 14612 Falkensee (“Spectrm”) to send notifications and manage subscriptions. Spectrm stores user preferences on our behalf (e.g. the frequency of notifications or product preferences). This information will only be used to manage the subscription.

Legal basis for such data processing is Art. 6 (1) lit. a) GDPR.

Users can unsubscribe at any time. In this case the personal data will be deleted.

  • To unsubscribe from the Breaking News Bot, please use the menu item ‘Manage Subscriptions’ in Facebook Messenger.
  • To unsubscribe from the Sneaker Bot, please send ‘unsubscribe’ via Facebook Messenger.

Please note that communication via Facebook Messenger is stored and processed by Facebook on servers in Europe and the USA. We have no influence on the data processing by Facebook. Additional information regarding the collection and utilization of your data by Facebook, your rights in relation to these data and the possibilities to protect your privacy can be found in the privacy policy of Facebook.

VIII. Affiliate Marketing

We use affiliate links on our website. In order to evaluate the use and success of these affiliate offers, we store and analyse information about the use of these links. This includes the IP address and interactions with the affiliate links (like clicks). This information is combined by one of our partners with information from the connected shops. On the basis of this information, anonymous statistics about the success of affiliate offers are compiled (e.g. the number of users who clicked on an affiliate link and the type and number of products purchased in our partner’s shop).

The legal basis for this data processing is Art. 6 (1) lit. f) GDPR. The data will be deleted as soon as the purpose of the processing has ceased to exist, at the latest after 24 months.

IX. Local Storage – HTML5

We may use Local Storage, such as HTML5 to store user preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your web browsing activity may also use HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. Legal basis for such data processing is Article 6 (1) lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose ceases to apply.

X. Log information

When you use our services or view content provided by us, we may automatically collect and store certain information in server logs. This information may include:

  • Details of how you used our service, such as your navigation paths and search queries.
  • Mobile related information if you access our website using your mobile device.
  • Internet protocol address.
  • Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
  • Cookies that may uniquely identify your browser, mobile device, or your account.
  • Browser type, operating system, and other technical information.

We may combine this automatically collected log information with other information we collect about you. We do this to improve marketing, analytics, and the products and services we offer you. Such information is used in anonymized or pseudonymized form only. Legal basis for such data processing is Article 6 (1) lit. f GDPR. Unless statutory provisions provide otherwise, the data will be deleted if the purpose ceases to apply.

XI. Cloudflare

To improve the security, stability and latency of our website and services, we use Cloudflare services, provided by Cloudflare Inc. , 101 Townsend St. , San Francisco, CA 94107, USA (“Cloudflare”). Cloudflare operates a worldwide content delivery network. This means that the communication between your browser and our website is routed through Cloudflare servers, including those located in the USA. Cloudflare stores and analyzes the traffic between our users and our websites in order to prevent attacks and improve the performance of our websites. These log data include the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider. These data are statistically evaluated for the above mentioned purposes. Cloudflare deletes the data according to its own statements usually after one week at the latest. For more information, see Cloudflare’s privacy policy.

Cloudflare has a Privacy Shield certification, which guarantees an adequate level of data protection. Legal basis for such data processing is Art. 6 (1) lit. f) GDPR.

XII. Notice to California Users

The California Consumer Privacy Act

Effective January 1, 2020, the California Consumer Privacy Act (“CCPA”), grants residents of California certain rights with respect to their Personal Information, described below. This Notice to California Customers supplements the information contained in Highsnobiety’s Privacy Policy. Any terms defined in the CCPA have the same meaning when used in this Notice to California Customers.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information“). During the past twelve (12) months, below are categories of personal information we have either collected or not:

Under the CCPA, personal information does not include information that is publicly available, aggregated consumer information or those not covered by under the CCPA.

We only collect personal information in accordance with the Highsnobiety Privacy Policy (See Section B., Information we Collect)

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our or our affiliates’ assets in which personal information held by us or our affiliates about our website users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We discuss in detail how we share information in the Highsnobiety Privacy Policy (See Section C. , Information we Share).

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we’ve collected about you.
    The categories of sources for the personal information we’ve collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we’ve collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq. ).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at [email protected].

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we’ve collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales

The CCPA broadly defines “sale” in a way that may include the delivery of targeted advertising on the Services or other sites, including allowing third parties to receive certain information, such as cookies, IP address and/or browsing behavior. We may share the following categories of information for such advertising which may be considered a sale (as defined by California law):

  • device information and identifiers, such as IP address, and unique advertising identifiers and cookies; usage information, such as browsing history or app usage; location information, such as city; and inference data.

Do Not Sell My Personal Information

If you are a California resident and would like to opt out of our use of your information for such purposes (to the extent this is considered a sale), beginning January 1, 2020, you may do so using by sending an email to [email protected] or using the following link:

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide you a different level or quality of goods or services
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798. 83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]

XIII. Your right to information and other rights of the persons affected

Right to information

You have the right to obtain confirmation as to whether or not your personal data is being processed by us. Where that is the case, you have the right to access to the personal data and the following information:

  1. the purposes of the processing;
  2. the categories of personal data concerned;
  3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  5. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  6. the right to lodge a complaint with a supervisory authority;
  7. where the personal data are not collected from the data subject, any available information as to their source;
  8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where personal data is transferred to a third country, you have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

Right to rectification

You have the right to obtain the rectification of inaccurate or incomplete personal data.

Right to erasure

You have the right to obtain the erasure of personal data where one of the following grounds applies:

  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. you withdraw the consent on which the processing is based according to Article 6 (1) lit a or Article 9 (2) lit. a GDPR, if there is no other legal ground for the processing;
  3. you object to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21 (2) GDPR;
  4. the personal data have been unlawfully processed;
  5. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which Titel Media is subject;
  6. the personal data have been collected in relation to the offer of information society services referred to in Article 8 (1) GDPR.

If Titel Media has made personal data public and is obliged to erase the personal data, Titel Media, taking account of available technology and the cost of implementation, takes reasonable steps, including technical measures, to inform controllers which are processing the personal data you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

The right to erasure shall not apply to the extent that processing is necessary:

  1. for exercising the right of freedom of expression and information;
  2. for compliance with a legal obligation which requires processing by Union or Member State law to which Titel Media is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  3. for the establishment, exercise or defence of legal claims.

Right to restriction of processing

You have the right to obtain restriction of processing where one of the following applies:

  1. you have contested the accuracy of the personal data, for a period enabling Titel Media to verify the accuracy of the personal data;
  2. the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  3. Titel Media no longer needs the personal data for the purposes of the processing, but is required by you for the establishment, exercise or defence of legal claims;
  4. you have objected to processing pursuant to Article 21 (1) GDPR pending the verification whether the legitimate grounds of Titel Media override yours
  5. Where processing has been restricted under the above, such personal data shall, with the exception of storage, is only processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

I you have obtained restriction of processing you will be informed before the restriction of processing is lifted.

Notification regarding rectification or erasure of personal data or restriction of processing

Titel Media will communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with the above to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves a disproportionate effort. On your request, Titel Media informs you about those recipients.

Right to data portability

You have the right to receive the personal data you have provided to Titel Media in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, where:

  1. the processing is based on consent pursuant to Article 6 (1) lit. a of Article 9 (2) or on a contract pursuant to Article 6 (1) lit. b GDPR; and
  2. the processing is carried out by automated means.

In exercising your right to data portability, you have the right to have the personal data transmitted directly from one Titel Media to another controller, where technically feasible.

The right to data portability shall not apply to processing necessary for the performance of a task carried out in the public interest.

Right to object

  1. You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point Article 6 (1) lit. a or lit. f GDPR, including profiling based on those provisions. Titel Media no longer processes the personal data unless Titel Media demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
  2. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  3. If you object to processing for direct marketing purposes, the personal data is no longer being processed for such purposes.

Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

This shall not apply if the decision:

  1. is necessary for entering into, or performance of, a contract between the data subject and a data controller;
  2. is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
  3. is based on the data subject’s explicit consent.

Right to revocation

You may at all times revoke consent to the processing of personal data. You can use the function on this page at I. Cookies.

Right to lodge a complaint with a supervisory authority

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 by Titel Media relating to you infringes the provisions of the GDPR.

In all such cases, please refer to us by written letter to Titel Media GmbH, Genthiner Strasse 32–34, 10785 Berlin, Germany, or by email to [email protected].

If you have any questions about data protection, please feel free to contact us at any time using the details given above.

XIV. Changes

We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.