PRIVACY POLICY
PRIVACY POLICY
§ 1 General Information
Your personal data (e.g., title, name, address, email address, telephone number, bank account details, credit card number) will be processed by us solely in accordance with the provisions of German data protection law and the data protection laws of the European Union (EU). In addition to informing you about the purposes of processing, categories of recipients, legal bases, and retention periods, the following provisions also inform you about your rights and the controller responsible for the processing of your personal data.
This Privacy Policy applies exclusively to our websites. If you are redirected to other websites via links on our pages, please refer to the respective websites for information on how your personal data is handled there.
§ 2 Data Processing for Contract Performance
(1) Purpose of Processing
The personal data you provide during the ordering process is required for the conclusion of a contract with us. You are not obliged to provide your personal data; however, without your address, we are unable to deliver the goods to you. For certain payment methods, we require the necessary payment information in order to forward it to a payment service provider engaged by us. Accordingly, the processing of the data entered during the ordering process is carried out for the purpose of fulfilling the contract.
If you contact us prior to entering into a contract by email, via a contact form, or by other means, we process the data received in this context for the purpose of carrying out pre-contractual measures and, for example, responding to your inquiries regarding our products.
If you create a customer account, your data (in particular your name, address, payment method, email address, and password) will be processed for the purpose of registration and the creation of a customer login account. The stored data enables you to shop more conveniently and to view your orders at any time. You may delete your customer account at any time by contacting us or by using the account deletion function.
(2) Legal Basis
The legal basis for this processing is Article 6(1)(b) of the General Data Protection Regulation (GDPR). (German: Art. 6 Abs. 1 b) DSGVO.)
(3) Categories of Recipients
Payment service providers, Shipping service providers, Hosting providers, Where applicable, enterprise resource planning (ERP) or merchandise management systems, Where applicable, suppliers (drop-shipping providers).
(4) Retention Period
We store the data required for contract performance until the expiry of the applicable statutory warranty periods and, where applicable, contractual guarantee periods.
Data that must be retained under commercial and tax laws will be stored for the legally prescribed retention periods, generally ten years (cf. Section 257 of the German Commercial Code (HGB) and Section 147 of the German Fiscal Code (AO)).
Data processed for the purpose of carrying out pre-contractual measures will be deleted once such measures have been completed and it is evident that no contract will be concluded.
§ 3 Comments / Product Reviews
(1) Purpose of Processing
You have the option to submit comments and product reviews. In this case, your data (e.g., name or pseudonym, email address, and website) will be processed solely for the purpose of publishing your comment or review.
(2) Legal Basis
The legal basis for this processing is Article 6(1)(f) of the General Data Protection Regulation (GDPR). (German: Art. 6 Abs. 1 f) DSGVO.)
(3) Legitimate Interest
Our legitimate interest lies in facilitating the public exchange of user opinions regarding specific topics and products. The publication of comments and reviews serves, among other things, transparency and the formation of informed opinions. Your interest in protecting your personal data is safeguarded, as you may publish your comment or review under a pseudonym.
(4) Retention Period
No specific retention period is envisaged. You may request the deletion of your comment or review at any time.
(5) Right to Object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data where such processing is based on Article 6(1)(f) GDPR and is not carried out for direct marketing purposes.
Where personal data is processed for direct marketing purposes, you have the right to object to such processing at any time without giving reasons.
§ 3.1 Store Reviews by EHI Retail Institute GmbH
(1) Purpose of Processing
If you choose to review our services, we process your email address as well as your order number and order date in order to send you a review verification request and a final review invitation. This information is also used to assign your review correctly and to prevent misuse of the review system.
(2) Legal Basis
This processing is carried out on the basis of our legitimate interests in improving our services and preventing review fraud in accordance with Article 6(1)(f) of the General Data Protection Regulation (GDPR). (German: Art. 6 Abs. 1 f) DSGVO.)
(3) Recipient
EHI Retail Institute GmbH
(4) Retention Period
Your data will be stored for as long as the EHI store review is displayed on our website.
§ 4 PayPal Transactions
Please note that all PayPal transactions are subject to PayPal's Privacy Policy:
https://www.paypal.com/de/webapps/mpp/ua/privacy-full
§ 5 Creditworthiness Check
Where we provide goods or services in advance of payment, for example in the case of payment by invoice or installment purchase, the following companies may obtain a creditworthiness assessment about you: For payments by invoice: PayPal Plus L-2449 Luxembourg, for installment purchases: TeamBank AG Nürnberg, Beuthener Straße 25, 90471 Nürnberg (TeamBank AG).
For this purpose, your personal data (e.g., name and address) will be transmitted to the respective company.
Your creditworthiness is assessed using mathematical and statistical methods to determine the risk of payment default. The conclusion of the purchase agreement may be made dependent upon the outcome of the creditworthiness assessment.
§ 6 Web Analytics with Google Analytics
(1) Purpose of Processing
This website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
Google Analytics 4 uses so-called "cookies", which are text files stored on your device that enable us to analyze your use of the website. According to Google, individual IP addresses are neither logged nor stored in Google Analytics 4. Analytics does not provide precise location data. Instead, the following metadata is derived from IP addresses: „City" (including the derived latitude and longitude of the city), „Continent“, „Country“, „Region“, „Subcontinent“ (Corresponding identifier-based geographic data).
For users accessing the website from within the European Union (EU), IP addresses are used solely to derive location data and are immediately deleted thereafter. They are not logged, are not accessible, and are not used for any other purposes.
When Analytics measurement data is collected, all IP lookups are performed on servers located within the EU before the traffic is forwarded to Analytics servers for processing. These servers may also be located outside the European Union.
On behalf of the operator of this website, Google will use this information to evaluate your use of the website, compile reports on website activity, and provide additional services related to website and internet usage to the website operator.
(2) Legal Basis
The legal basis for this processing is Article 6(1)(f) of the General Data Protection Regulation (GDPR). (German: Art. 6 Abs.1 f) DSGVO.)
(3) Categories of Recipients
Google, Google affiliated companies and partners
(4) Transfer to Third Countries
Google Ireland Limited is an affiliated company of Google LLC. Google LLC is headquartered in the United States at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
The transfer of personal data from the European Union to the United States is based on the EU–U.S. Data Privacy Framework.
(5) Retention Period
2 months.
(6) Right to Withdraw Consent
You may withdraw your consent at any time with future effect via our cookie banner or through the settings available on our website.
You may also prevent the storage of cookies by configuring your browser software accordingly. Please note, however, that if you do so, you may not be able to use all functions of this website to their full extent.
Furthermore, you may prevent Google from collecting and processing the data generated by the cookie and related to your use of the website by downloading and installing the browser plug-in available at the following link: optout
§ 7 Information About Cookies
(1) Purpose of Processing
This website uses technically necessary cookies. Cookies are small text files that are stored by your internet browser on your computer system and are generally not stored permanently. These cookies enable functions such as adding multiple products to a shopping cart.
Other cookies remain stored on your device and allow us to recognize your browser when you visit our website again. These cookies enable features such as saving your login credentials for a customer account.
(2) Legal Basis
The legal basis for the processing of personal data through cookies requiring consent is Article 6(1)(a) of the General Data Protection Regulation (GDPR). (German: Art. 6 Abs.1 a) DSGVO.)
Where applicable, you have provided the following consent:
By selecting "Accept all", you give us permission to use the following services on our website: YouTube, Vimeo, ReCaptcha, Brevo. You can change the settings at any time (fingerprint icon in the bottom left corner). For further details, please see Individual configuration and our Privacy notice
(3) Retention Period
Technically necessary cookies are generally deleted when you close your browser.
Persistent cookies remain stored for varying periods, ranging from a few minutes to several years, depending on their purpose.
(4) Right to Withdraw Consent
If you do not wish cookies to be stored on your device, you may disable the acceptance of cookies in your internet browser settings. Please note that doing so may limit the functionality of this website.
You may withdraw your consent to the storage of persistent cookies at any time by deleting the stored cookies through your browser settings.
§ 8 Social Plugins from Facebook and Twitter (X)
(1) We use social plugins provided by Facebook, operated by Facebook Inc., 1601 S. California Avenue, Palo Alto, CA 94304, USA. These plugins can be identified by the Facebook logo or the designation "Facebook Social Plugin".
If you click the "Like" button or submit a comment, the corresponding information is transmitted directly from your browser to Facebook and stored there. Facebook may also make your preferences publicly available to your Facebook friends.
If you are logged into Facebook, Facebook may directly associate your visit to our website with your Facebook account. Even if you are not logged in or do not have a Facebook account, your browser may transmit information (such as the website you visited and your IP address) to Facebook, where it may be stored.
For further information regarding the processing of your personal data by Facebook and your related rights, please refer to Facebook's Privacy Policy.
If you do not want Facebook to associate data collected through our website with your Facebook account, you must log out of Facebook before visiting our website.
You may also prevent the loading of Facebook plugins by using browser add-ons such as "Facebook Blocker" or similar tools.
(2) We use social plugins and Re-Tweet functions provided by Twitter (now X), formerly operated by Twitter Inc., 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA.
These plugins are identified by the Twitter logo, such as the blue Twitter bird icon.
If you use the Re-Tweet functions, the websites you visit may be disclosed to third parties and linked to your Twitter (X) account.
For further information regarding the processing of your personal data by Twitter (X), as well as your rights and privacy settings, please refer to Twitter's (X's) Privacy Policy.
If you do not wish Twitter (X) to associate data collected through our website directly with your Twitter (X) account, you must log out of Twitter (X) before visiting our website.
You may also prevent the loading of Twitter (X) plugins by using browser add-ons such as script blockers (e.g., NoScript).
§ 9 Newsletter
(1) Purpose of Processing
When you subscribe to our newsletter, your email address will be used for marketing purposes. In particular, we will use the newsletter to inform you about products and offers from our product range.
For statistical purposes, we may analyze which links within the newsletter are clicked. However, we are not able to identify which specific individual clicked on a particular link.
You have provided the following consent separately or, where applicable, during the ordering process: "Subscribe to Newsletter"
(2) Legal Basis
The legal basis for this processing is Article 6(1)(a) of the General Data Protection Regulation (GDPR). (German: Art. 6 Abs. 1 a) DSGVO.)
(3) Categories of Recipients
Where applicable, newsletter service providers
(4) Retention Period
Your email address will be stored for newsletter distribution only for as long as you remain subscribed to the newsletter.
(5) Right to Withdraw Consent
You may withdraw your consent at any time with effect for the future.
If you no longer wish to receive our newsletter, you may unsubscribe at any time by: Clicking the unsubscribe link contained in any newsletter email; or using the "Unsubscribe from Newsletter" function available in our online shop. To unsubscribe via the website, please enter your email address in the designated field and click the "Unsubscribe" button.
§ 10 easyCredit Installment Purchase
I. Privacy Notice for easyCredit Installment Purchase
For your order with the merchant, you may choose to use the easyCredit Installment Purchase service provided by TeamBank AG, Beuthener Straße 25, 90471 Nuremberg, Germany (hereinafter referred to as "TeamBank AG").
The merchant cooperates with TeamBank AG, which assists the merchant in assessing the likelihood of proper payment. To perform these risk assessments, the merchant is required to transmit your customer data to TeamBank AG.
For the purpose of conducting the risk assessment, TeamBank AG also requires your consent to transfer selected data to credit agencies and other cooperation partners. Data will only be transferred to the extent that you have expressly consented to such transfer in separate declarations of consent.
Providing such consent is entirely voluntary. However, please note that without granting this consent, you will not be able to use the easyCredit Installment Purchase service.
(1) Transfer of Data from the Merchant to TeamBank AG
For installment purchases made through the merchant's website, the merchant will transfer data to TeamBank AG, provided that you have given your consent for such transfer. This data may include: Personal identification data, contact information, bank account details, information relating to your current and previous orders.
This data transfer does not apply to installment purchases made directly at the merchant's physical store locations.
(2) Collection of Creditworthiness and Risk Information by TeamBank AG
If you grant your consent to TeamBank AG, creditworthiness data and risk information will be obtained from credit agencies and other cooperation partners.
Creditworthiness data includes information relevant to assessing your financial reliability, such as information regarding legally enforceable outstanding claims against you and other credit-related information, to the extent permitted under applicable data protection laws.
To prevent fraud, risk information may also be obtained from cooperation partners. Such partners may collect and process data through cookies and other tracking technologies in order to identify the device used by visitors to this website and to analyze additional information regarding website usage.
(3) Assignment of Receivables to TeamBank AG
Receivables arising from the use of the installment purchase service are assigned by the merchant to TeamBank AG under an ongoing factoring agreement.
TeamBank AG processes and uses your customer data to the extent necessary for the assertion, management, and enforcement of the assigned receivables.
(4) Your Rights to Withdraw Consent, Access, Rectification, Restriction, and Erasure
You may withdraw your consent at any time with effect for the future.
Furthermore, you are entitled to request, free of charge, access to, rectification of, restriction of processing of, and, where applicable, erasure of your personal data.
Please address such requests to the merchant using the contact details provided in the legal notice (Imprint) of the website.
For information regarding data stored about you by credit agencies, please contact the respective agency directly:
- Creditreform Boniversum GmbH, Hellersbergstraße 11, 41460 Neuss, Germany
- SCHUFA Holding AG, Kormoranweg 5, 65201 Wiesbaden, Germany
- Infoscore Consumer Data GmbH, Rheinstraße 99, 76532 Baden-Baden, Germany
§ 11 Credit Card Transactions via secupay
The controller has integrated the secupay.Credit Card payment service of secupay AG (hereinafter referred to as "secupay"), Goethestraße 6, 01896 Pulsnitz, Germany, into this website.
secupay is a payment institution within the meaning of the German Payment Services Supervision Act (ZAG) and is registered with the German Federal Financial Supervisory Authority (BaFin), Graurheindorfer Straße 108, 53117 Bonn, Germany (Registration No. 126737). secupay enables cashless payment for products and services over the Internet.
secupay operates a process under which the merchant's payment claim is assigned to secupay. This enables the merchant to deliver goods, services, or digital downloads to the customer immediately after the order has been placed.
If you select "Credit Card" as your payment method during the ordering process in our online shop, your personal data will automatically be transmitted to secupay. By selecting this payment option, you consent to the transfer of personal data required for payment processing.
As the purchaser, you provide your payment details directly to secupay for the processing of credit card payments. secupay then performs a technical assessment of the risk of payment default. The result of this assessment is subsequently transmitted automatically to the online merchant.
The personal data exchanged with secupay may include: First name, last name, postal address, email address, IP address, telephone number, payment information, other data required for payment processing.
The data is transmitted for the purposes of payment processing and fraud prevention.
The controller may also transfer additional personal data to secupay where there is a legitimate interest in such transfer. Personal data exchanged between secupay and the controller may, where appropriate, be transmitted by secupay to credit reference agencies for the purposes of identity verification and creditworthiness assessment.
secupay may disclose personal data to affiliated companies, service providers, or subcontractors where such disclosure is necessary for the performance of contractual obligations or where the data is processed on secupay's behalf.
You may withdraw your consent regarding the processing of personal data by secupay at any time. However, such withdrawal shall not affect personal data that must be processed, used, or transferred for the contractual execution of payment transactions.
The current privacy policy of secupay is available at: https://www.secupay.com/en/privacy-policy
§ 12 Content Delivery Network (CDN)
We use the Bunny.net Content Delivery Network (CDN), provided by BUNNYWAY, informacijske storitve d.o.o., Dunajska cesta 165, 1000 Ljubljana, Slovenia, to deliver the content of our website.
A CDN helps to provide websites more quickly and securely by delivering content through geographically distributed servers. In this process, technical information transmitted by your browser may be processed. This information may include, in particular:
- Anonymized IP address
- Website address (URL)
- Country code
- User-Agent (browser and device information)
- Date and time of access
This information may be collected and temporarily stored in order to facilitate the delivery of the website, perform performance and security analyses, carry out technical optimizations, and protect against malicious attacks.
According to its own statements, the provider implements GDPR-compliant safeguards and data protection measures.
Further information can be found in Bunny.net's Privacy Policy: https://bunny.net/gdpr/ and https://bunny.net/privacy/
This processing is carried out on the basis of Article 6(1)(f) of the General Data Protection Regulation (GDPR) (German: Art. 6 Abs. 1 lit. f DSGVO), as we have a legitimate interest in the secure and efficient provision of our website.
§ 13 Sweepstakes and Prize Draws
If you participate in a sweepstakes or prize draw organized by us, we process the personal data you provide in the entry form (e.g., name, email address, country) for the purpose of conducting and administering the prize draw, in particular for selecting and notifying the winners.
The legal basis for this data processing is Article 6(1)(a) GDPR, Article 6(1)(b) GDPR, and Article 6(1)(f) GDPR.
Detailed information can be found in the respective terms and conditions applicable to the relevant sweepstakes or prize draw.
We use Brevo as a data processor for the collection and management of participant data.
If you additionally consent to receiving our newsletter, your email address will be processed on the basis of your consent in accordance with Article 6(1)(a) GDPR. You may withdraw your consent at any time with effect for the future.
§ 14 Your Rights as a Data Subject
If your personal data is processed, you are considered a data subject within the meaning of the General Data Protection Regulation (GDPR) (German DSGVO) and are entitled to the following rights with respect to us as the controller:
1. Right of Access
Pursuant to Article 15 GDPR, you have the right to obtain information about the personal data concerning you that we process. (German: Art. 15 DSGVO)
2. Right to Rectification
If the personal data concerning you is inaccurate or no longer accurate, you have the right to request rectification pursuant to Article 16 GDPR (German: Art. 16 DSGVO) . If your personal data is incomplete, you may request that it be completed. (German: Art. 16 DSGVO)
3. Right to Erasure
Under the conditions set out in Article 17 GDPR (German: Art. 17 DSGVO), you have the right to request the erasure of your personal data.
4. Right to Restriction of Processing
Under the conditions set out in Article 18 GDPR (German: Art. 18 DSGVO), you have the right to request the restriction of the processing of your personal data.
5. Right to Data Portability
Pursuant to Article 20 GDPR (German: Art. 20 DSGVO), you have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, or to request the transmission of such data to another controller.
6. Right to Withdraw Consent
Pursuant to Article 7(3) GDPR (German: Art. 7 Abs. 3 DSGVO), you have the right to withdraw any consent previously given for the processing of your personal data at any time with effect for the future.
The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
7. Right to Lodge a Complaint with a Supervisory Authority
If you believe that the processing of your personal data violates the GDPR, you have the right, pursuant to Article 77 GDPR (German:Art. 77 DSGVO), to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or the place of the alleged infringement.
Right to Object Pursuant to Article 21 GDPR (German: Art. 21 DSGVO):
a) General Right to Object: Where personal data concerning you is processed:
- for the purposes of our overriding legitimate interests (legal basis: Article 6(1)(f) GDPR), or (German: Art. 6 Abs. 1 f) DSGVO) or
- in the public interest (legal basis: Article 6(1)(e) GDPR), (German: Art. 6 Abs. 1 e) DSGVO),
you have the right to object at any time, on grounds relating to your particular situation, to such processing. This also applies to profiling based on these provisions of the GDPR.
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or unless the processing serves the establishment, exercise, or defense of legal claims.
b) Right to Object to Direct Marketing
Where your personal data is processed for direct marketing purposes, you have the right to object at any time to such processing without providing any reasons. This also applies to profiling insofar as it is related to such direct marketing.
If you object to processing for direct marketing purposes, your personal data will no longer be processed for such purposes.
Controller Responsible for Data Processing:
Torro GmbH
Am Roehrig 2
63762 Grossostheim
Data Protection Officer: Helmut Fendt
Telephon: 060269988599
Mo.-Fr. 11-15 Uhr
service@torro.de