DATA PROTECTION DECLARATION (PRIVACY POLICY)

INFORMATION ON THE COLLECTION OF PERSONAL DATA AND CONTROLLER CONTACT DETAILS

1.1 We are pleased that you are visiting our website and thank you for your interest. Below we inform you about how we process your personal data when you use our website. Personal data means any information relating to an identified or identifiable natural person.

1.2 The data controller for this website, within the meaning of the General Data Protection Regulation (GDPR), is True Gents. The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data.

1.3 For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the character string “https://” and the lock symbol in your browser bar.

DATA COLLECTION WHEN YOU VISIT OUR WEBSITE

If you use our website for informational purposes only—i.e., you do not register or otherwise transmit information to us—we only collect the data that your browser transmits to our server (server log files). When you visit our website, we collect the following information, which is technically necessary for us to display the website to you:

The page visited on our website
Date and time of access
Amount of data transferred (in bytes)
The source/referrer from which you reached the page
The browser used
The operating system used
The IP address used (possibly in anonymized form)

Processing takes place pursuant to Art. 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data are not disclosed or used in any other way. However, we reserve the right to subsequently check the server log files if there are specific indications of unlawful use.

COOKIES

We use cookies on various pages to make your visit to our website attractive and to enable the use of certain functions. Cookies are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e., after you close your browser (session cookies). Other cookies remain on your device and allow us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). Where cookies are set, certain user information—such as browser and location data as well as IP address values—may be collected and processed to an individual extent.

Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie. In some cases, cookies simplify the ordering process by saving settings (e.g., remembering the contents of a virtual shopping cart for a later visit). If personal data are also processed through cookies that we implement, processing occurs either pursuant to Art. 6(1)(b) GDPR for the performance of a contract, or pursuant to Art. 6(1)(f) GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly, efficient design of our site.

We may cooperate with advertising partners who help us make our website more appealing. For this purpose, cookies from partner companies (third parties) may also be stored on your hard drive when you visit our site. Where we cooperate with such advertising partners, you will be informed individually and separately below about the use of these cookies and the scope of the information collected in each case.

Please note you can set your browser to inform you about the setting of cookies and decide individually whether to accept them, to accept cookies in certain cases, or to generally exclude them. How you manage cookie settings varies by browser. You can find information in each browser’s help menu explaining how to change your cookie settings. For individual browsers:

Please note that if you do not accept cookies, the functionality of our website may be limited.

WHEN YOU CONTACT US

Personal data are collected when you contact us (e.g., via contact form or e-mail). The data collected via the contact form are evident from the respective form. These data are stored and used solely for the purpose of responding to your inquiry or for contacting you, and for the associated technical administration. The legal basis for processing is our legitimate interest in responding to your request pursuant to Art. 6(1)(f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6(1)(b) GDPR. Your data will be deleted once your inquiry has been fully processed—this is the case when the circumstances indicate that the matter has been conclusively resolved and no statutory retention obligations apply.

DATA PROCESSING IN THE CONTEXT OF ACCOUNT CREATION AND CONTRACT PROCESSING

Pursuant to Art. 6(1)(b) GDPR, personal data are also collected and processed if you provide them to us for the purpose of performing a contract or when creating a customer account. The data collected are apparent from the respective input forms. You may delete your customer account at any time by sending a message to the controller named above. We store and use the data you provide for contract performance. After the contract has been fully performed or your customer account has been deleted, your data will be blocked with regard to retention periods under tax and commercial law and deleted after these periods expire, unless you have expressly consented to further use of your data or we have reserved a legally permitted further use of data, about which we inform you below.

USE OF YOUR DATA FOR DIRECT ADVERTISING

6.1 Subscribing to our e-mail newsletter
If you subscribe to our newsletter, we will regularly send you information about our offers. The only mandatory information for sending the newsletter is your e-mail address. Providing additional data is optional and will be used to address you personally. We use the double opt-in procedure: we will only send you the newsletter if you expressly confirm that you consent to receiving it. We will then send you a confirmation e-mail asking you to confirm your subscription by clicking a link.

By clicking the confirmation link, you consent to the use of your personal data pursuant to Art. 6(1)(a) GDPR. When you subscribe, we store your IP address as well as the date and time of registration so we can prove your registration in accordance with legal requirements. The data collected when you register for the newsletter are used exclusively for advertising via the newsletter. You may withdraw your consent at any time and unsubscribe—via the link in every newsletter, by messaging the controller above, or via the contact methods in the legal notice.

6.2 Newsletter delivery for advertising purposes
The newsletter is sent via our service provider, who processes data on our behalf and according to our instructions. We do not disclose your data to third parties without your consent, unless necessary for contract performance or required by law.

DATA PROCESSING FOR ORDER FULFILMENT

7.1 Processing of personal data
The personal data collected by us will be transmitted to the transport company commissioned with the delivery as part of contract performance, insofar as this is necessary to deliver the goods. For payment processing, we transmit your payment data to the authorized credit institution, where necessary for payment processing. If you use payment service providers, we will explicitly inform you below. Legal basis: Art. 6(1)(b) GDPR.

7.2 Use of payment service providers (payment services)

PayPal
If you pay via PayPal, by credit card via PayPal, by direct debit via PayPal or—if offered—“purchase on account” or “installment payment” via PayPal, we transmit your payment data to PayPal (Europe) S.à r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg (“PayPal”) as part of payment processing. Transmission occurs pursuant to Art. 6(1)(b) GDPR and only to the extent necessary for payment processing. PayPal reserves the right to carry out a credit check for the payment methods PayPal, credit card via PayPal, direct debit via PayPal or—if offered—purchase on account/installment payment. PayPal uses the result of the credit check (probability values/scores) to decide on the provision of the respective payment method. The score values are calculated on the basis of recognized mathematical-statistical procedures and may include address data. Further information on data protection (including the credit agencies used) can be found in PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full

You can object to this processing at any time by contacting the controller above. However, PayPal may still be entitled to process your data if this is necessary for contractual payment processing.

RIGHTS OF DATA SUBJECTS

8.1 Applicable law grants you extensive rights (rights of information and intervention) regarding the processing of your personal data. In particular:

Right of access (Art. 15 GDPR): You have the right to obtain information about the personal data we process about you, the purposes of processing, the categories of data, the recipients or categories of recipients to whom your data have been or will be disclosed, the planned storage period or the criteria used to determine that period, the existence of the right to rectification, erasure, restriction of processing, objection, the right to lodge a complaint with a supervisory authority, the source of your data if not collected from you, the existence of automated decision-making including profiling and meaningful information about the logic involved, as well as the significance and envisaged consequences, and your right to be informed of the safeguards under Art. 46 GDPR if your data are transferred to a third country.
Right to rectification (Art. 16 GDPR): You have the right to obtain without undue delay the rectification of inaccurate data and completion of incomplete data.
Right to erasure (Art. 17 GDPR): You have the right to request erasure of your personal data where one of the grounds in Art. 17(1) GDPR applies (e.g., data are no longer necessary; you withdraw consent and there is no other legal basis; you object; data were unlawfully processed; erasure is required by EU or Member State law; data were collected in relation to information society services).
Right to restriction of processing (Art. 18 GDPR): You may request restriction if you contest accuracy; processing is unlawful and you oppose erasure; we no longer need the data but you need them for legal claims; or you have objected under Art. 21(1) pending verification of overriding legitimate grounds.
Right to data portability (Art. 20 GDPR): You have the right to receive the data you provided to us in a structured, commonly used, machine-readable format, or to request transmission to another controller where technically feasible.
Right to withdraw consent (Art. 7(3) GDPR): You may withdraw consent at any time with effect for the future. Upon withdrawal, we will erase the affected data unless further processing is permitted by law. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.
Right to lodge a complaint (Art. 77 GDPR): You may lodge a complaint with a supervisory authority, in particular in your Member State of habitual residence, place of work, or place of the alleged infringement, without prejudice to other administrative or judicial remedies.

8.2 RIGHT TO OBJECT
IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTERESTS (BALANCING OF INTERESTS), YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, WITH EFFECT FOR THE FUTURE.

IF YOU OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO CONTINUE PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS OR IF PROCESSING SERVES THE ESTABLISHMENT, EXERCISE, OR DEFENCE OF LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES (E.G., SENDING NEWSLETTERS), YOU MAY OBJECT AT ANY TIME TO SUCH PROCESSING FOR DIRECT ADVERTISING. YOU MAY EXERCISE YOUR RIGHT TO OBJECT AS DESCRIBED ABOVE.

IF YOU OBJECT, WE WILL STOP PROCESSING THE RELEVANT DATA FOR DIRECT MARKETING PURPOSES.

STORAGE PERIOD FOR PERSONAL DATA

The storage period is determined according to the respective legal basis and statutory retention periods (e.g., commercial and tax law). After expiry of the period, the corresponding data are routinely deleted, provided they are no longer necessary for contract performance or initiation and/or we no longer have a legitimate interest in further storage.

GOOGLE ANALYTICS

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies,” text files stored on your computer, to help analyze how users use the site. The information generated by the cookie about your use of this website is generally transmitted to a Google server in the USA and stored there. If IP anonymization is activated on this website, your IP address will first be shortened by Google within Member States of the European Union or in other Contracting States of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the website operator, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services relating to website activity and Internet usage. The IP address transmitted by your browser within Google Analytics is not merged with other Google data. You can refuse the use of cookies by selecting the appropriate settings in your browser; however, please note that in this case you may not be able to use the full functionality of this website. You can also prevent Google’s collection and processing of data generated by the cookie and related to your use of the website (including your IP address) by downloading and installing the browser plug-in available at: http://tools.google.com/dlpage/gaoptout?hl=de

WITHDRAWAL OF CONSENT

You may withdraw your consent at any time with effect for the future. To exercise your right of withdrawal, please contact the controller indicated above.

DATA SUBJECT RIGHTS (SUMMARY)

Upon request, you have the right to receive free information about the personal data we store about you. You also have the right to rectification of inaccurate data, restriction of processing, and deletion of your personal data where permitted by law, and the right to object to processing where permitted by law. To exercise these rights, contact us by e-mail at [email address] or by postal mail at [name and address]. You also have the right to lodge a complaint with the data protection supervisory authority competent for you or in the Member State of your habitual residence or place of work.

DATA SECURITY

We implement technical and organizational security measures to protect your personal data against manipulation, loss, destruction, or access by unauthorized persons. Our security measures are continually improved in line with technological developments.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend this Privacy Policy if necessary due to new technologies. Please ensure you have the latest version. In the event of material changes, we will inform our users by e-mail.

10.2 USE OF GOOGLE ADWORDS CONVERSION TRACKING

This website uses the online advertising program “Google AdWords” and, within Google AdWords, the conversion tracking tool of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). We use Google AdWords to draw attention to our attractive offers on external websites by means of advertising materials (so-called Google AdWords). With campaign data we can determine the success of individual advertising measures. Our aim is to display ads that are of interest to you, to make our website more interesting for you, and to calculate advertising costs fairly.

The conversion tracking cookie is set when a user clicks on a Google AdWords ad. These cookies expire after 30 days and are not used to identify users personally. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize that the user clicked the ad and was redirected to this page. Each Google AdWords customer receives a different cookie, so cookies cannot be tracked across AdWords customers’ websites. The information collected via the conversion cookie is used to compile conversion statistics for AdWords customers who have opted in to conversion tracking. Customers learn the total number of users who clicked their ad and were redirected to a conversion-tracking page, but receive no information that personally identifies users. If you do not wish to participate in tracking, you can block this by disabling the Google conversion-tracking cookie in your browser settings. You will then not be included in the conversion statistics. We use Google AdWords based on our legitimate interest in targeted advertising pursuant to Art. 6(1)(f) GDPR.

Google LLC in the United States is certified under the EU-U.S. Privacy Shield, which ensures compliance with the data protection level applicable in the EU.

More information on Google’s privacy policy: https://www.google.de/policies/privacy/
You can permanently disable cookies for ad preferences either via your browser settings or by installing the browser plug-in available here: https://www.google.com/settings/ads/plugin?hl=de
Note that if you disable cookies, some features of this website may be unavailable or only partially available.

GOOGLE (UNIVERSAL) ANALYTICS (EXTENDED)

This website also uses Google Analytics (Universal Analytics). The information generated by cookies about your use of this website (including a shortened IP address) is generally transmitted to a Google server in the USA and stored there.

This site uses Google Analytics exclusively with the “_anonymizeIp()” extension, which ensures IP anonymization by shortening the IP and excludes direct personal reference. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. In those exceptional cases, processing occurs pursuant to Art. 6(1)(f) GDPR on the basis of our legitimate interest in statistical analysis of user behavior for optimization and marketing.

Google will use this information to evaluate your use of the site, compile reports on website activity, and provide other services related to website activity and Internet usage. The IP address transmitted by your browser as part of Google Analytics is not combined with other Google data.

You can prevent cookies via your browser settings; however, this may limit website functionality. You can also prevent collection and processing of data (including your IP address) by Google by installing the browser add-on: https://tools.google.com/dlpage/gaoptout?hl=pl

As an alternative to the browser add-on—or on mobile browsers—you can set an opt-out cookie that prevents future collection by Google Analytics on this website (works only in this browser and only for this domain; if you delete cookies, you must click the link again): Disable Google Analytics.
More about Universal Analytics: https://support.google.com/analytics/answer/2838718?hl=pl&ref_topic=6010376

RETARGETING / REMARKETING / AD RECOMMENDATIONS

Facebook Custom Audiences via pixel
This website uses the “Facebook pixel” of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA (“Facebook”). With explicit consent, user behavior can be tracked after viewing or clicking a Facebook ad. This serves statistical and market research purposes to measure ad effectiveness and to optimize future advertising. The data collected are anonymous to us; however, Facebook stores and processes the data so they can be linked to the respective user profile, and Facebook may use the data for its own advertising purposes in accordance with Facebook’s Data Policy (https://www.facebook.com/about/privacy/). This allows Facebook and its partners to display ads on and off Facebook. A cookie may also be stored on your computer for this purpose. Such processing is carried out only with your explicit consent pursuant to Art. 6(1)(a) GDPR.

Consent to use the Facebook pixel may only be given by users who are at least 13 years old; if you are younger, please obtain consent from a legal guardian. Facebook Inc. is certified under the EU-U.S. Privacy Shield, ensuring EU-level data protection.

If you want to disable cookies on your computer, set your browser so that no cookies are stored in the future or so that cookies already stored are deleted. If you disable all cookies, some functions of our site may not be available. You can also opt out of third-party cookies such as Facebook via the Digital Advertising Alliance: https://www.aboutads.info/choices/

Google AdWords Remarketing
Our website uses Google AdWords remarketing to advertise in Google search results and on third-party websites. Provider: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google places a cookie in your browser that automatically enables interest-based advertising via a pseudonymous cookie ID and based on the pages you visit. Processing is based on our legitimate interest in optimal marketing of our website pursuant to Art. 6(1)(f) GDPR. Further processing occurs only if you consent to Google linking your web and app browsing history with your Google account and using information from your account to personalize ads across devices. If you are logged in to your Google account while visiting our site, Google uses your data together with Google Analytics data to create and define cross-device remarketing audiences. For this purpose, Google temporarily links your personal data with Google Analytics data to form target groups.

You can permanently deactivate cookies for ad preferences by installing the browser plug-in: https://www.google.com/settings/ads/onweb/
Alternatively, see cookie settings at www.aboutads.info. Finally, you can set your browser to notify you about cookies and decide individually whether to accept them or exclude acceptance in certain cases or in general. If you do not accept cookies, our website functionality may be limited.

Google LLC is certified under the EU-U.S. Privacy Shield.

More information and Google’s advertising privacy provisions: https://www.google.com/policies/technologies/ads/

DATA SUBJECT RIGHTS (EXTENDED SUMMARY)

13.1 The applicable data protection laws grant you extensive rights with respect to the controller (rights of access and intervention), including:

Right to information (Art. 15 GDPR)
Right to rectification (Art. 16 GDPR)
Right to erasure (Art. 17 GDPR)
Right to restriction of processing (Art. 18 GDPR)
Right to notification (Art. 19 GDPR)
Right to data portability (Art. 20 GDPR)
Right to withdraw consent (Art. 7(3) GDPR)
Right to lodge a complaint (Art. 77 GDPR)

13.2 RIGHT TO OBJECT
IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTERESTS (BALANCING OF INTERESTS), YOU HAVE THE RIGHT TO OBJECT AT ANY TIME ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, WITH EFFECT FOR THE FUTURE.

IF YOU OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED, UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE, OR DEFENCE OF LEGAL CLAIMS. IF WE PROCESS YOUR DATA FOR DIRECT MARKETING PURPOSES, YOU MAY OBJECT AT ANY TIME; IF YOU DO SO, WE WILL CEASE PROCESSING FOR SUCH PURPOSES.

RETENTION PERIOD FOR PERSONAL DATA

The retention period is determined by applicable statutory retention periods (e.g., commercial and tax law). After expiry of these periods, the data are routinely deleted provided they are no longer required for the purpose for which they were collected.