Privacy policy
1) Introduction and contact details of the person responsible
1.1We are pleased that you visit our website and thank you for your interest. In the following we will inform you about dealing with your personal data when using our website. Personal data is all data with which you can be personally identified.
1.2Grahams Natural Germany GmbH, Schauenburgerstr. 32a, 24105 Kiel, Germany, Tel.: +49 151 6778 5937, email: hello@grahamsnatural.de. The person responsible for processing personal data is the natural or legal person who decides alone or together with others about the purposes and means of processing personal data.
2) Data acquisition when visiting our website
2.1When using our website, i.e. if you do not register or otherwise convey information, we only collect data that your browser transmits to the side server (so-called "server log files"). When you call up our website, we will collect the following data that is technically necessary for us to display the website:
- Our visited website
- Date and time at the time of access
- Quantity of the data sent in byte
- Source/reference from which they came to the page
- Browser used
- Operating system used
- Used IP address (possibly: in anonymized form)
The processing takes place in accordance with Art. 6 Para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. There is no transfer or other use of the data. However, we reserve the right to check the server log files retrospectively, should indicate specific indications of illegal use.
2.2This website uses an SSL and TLS encryption. You can see an encrypted connection to the string "https: //" and the castle symbol in your browser line.
3) Hosting & Content Delivery Network
3.1Amazon Web Services
For the hosting of our website and the presentation of the page content, we use the system of the following provider: Amazon Web Services, Inc., 410 Terry Avenue North, Seattle, WA 98109, USA
All data collected on our website is processed on the provider's servers.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our side visitors and prohibits an unauthorized transfer to third parties.
For data transmission to the USA, the provider has joined the EU-US-data protection framework (EU-US-EU Privacy Framework), which ensures compliance with the European data protection level on the basis of an adequacy decision by the European Commission.
3.2Shopify
For the hosting of our website and the presentation of the page content, we use the system of the following provider: Shopify International Limited, Victoria Buildings, 2. Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland ("Shopify")
Data is also transferred to: Shopify Inc., 150 Elgin St, Ottawa, on K2P 1L4, Canada
All data collected on our website is processed on the provider's servers. We have concluded an order processing contract with the provider, which ensures the protection of the data of our side visitors and prohibits an unauthorized transfer to third parties.
In the event of a data transmission to Canada, an appropriate level of data protection is guaranteed by an adequacy decision by the European Commission.
3.3AWS Cloudfront
We use a content delivery of the following provider: Amazon Web Services, Inc., 410 Terry Avenue North, Seattle, WA 98109, USA
This service enables us to deliver large media files such as graphics, page content or scripts more quickly via a network of regionally distributed servers. The processing is to maintain our legitimate interest in improving the stability and functionality of our website in accordance with Art. 6 Para. 1 lit. f GDPR. We have concluded an order processing contract with the provider, which ensures the protection of the data of our side visitors and prohibits an unauthorized transfer to third parties.
For data transmission to the USA, the provider has joined the EU-US-data protection framework (EU-US-EU Privacy Framework), which ensures compliance with the European data protection level on the basis of an adequacy decision by the European Commission.
3.4Cloudflare
We use a content delivery of the following provider: Cloudflare Inc., 101 Townsend St. San Francisco, CA 94107, USA
This service enables us to deliver large media files such as graphics, page content or scripts more quickly via a network of regionally distributed servers. The processing is to maintain our legitimate interest in improving the stability and functionality of our website in accordance with Art. 6 Para. 1 lit. f GDPR. We have concluded an order processing contract with the provider, which ensures the protection of the data of our side visitors and prohibits an unauthorized transfer to third parties.
For data transmission to the USA, the provider has joined the EU-US-data protection framework (EU-US-EU Privacy Framework), which ensures compliance with the European data protection level on the basis of an adequacy decision by the European Commission.
4) Cookies
In order to make the visit of our website attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your device. In some cases, these cookies are automatically deleted after closing the browser (so-called "session cookies"), some of these cookies remain longer on their device and enable the storage of side settings (so-called "persistent cookies"). In the latter case, you can find the memory duration of the overview of the cookie settings of your web browser.
If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 Para. 1 Lit.B GDPR either for the implementation of the contract, in accordance with Art. 6 Para. 1 lit. a GDPR in the event of consent or According to Art. 6 Para. 1 Lit. f GDPR to maintain our legitimate interests in the best possible functionality of the website and a customer -friendly and effective design of the page visit.
You can set your browser so that you are informed about the setting of cookies and decide individually about their acceptance or can rule out the acceptance of cookies for certain cases or in general.
Please note that the functionality of our website may be restricted if you are not accepted.
5) contact
5.1Judge.me
For evaluations, we use the services of the following provider: Judge.me Ltd., C/O Buckworths, 2nd Floor, 1-3 Worship Street, London, England, EC2A 2ab, United Kingdom
Only on the basis of your express consent in accordance with Art. 6 Para. 1 lit. a GDPR, we transmit your email address and, if necessary, other customer data to the provider so that he will contact you by email with an evaluation reminder.
You can revoke your consent at any time with effect for the future towards us or the provider.
We have concluded an order processing contract with the provider, which ensures the protection of the data of our side visitors and prohibits an unauthorized transfer to third parties.
In the case of data transmission to the provider location, an appropriate level of data protection is guaranteed by an adequacy decision of the European Commission.
5.2WhatsApp business
We offer visitors to our website the opportunity to get in touch with us via the WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland. For this we use the so-called "business version" from WhatsApp.
If you contact us on the occasion of a specific business (for example a placed order) via WhatsApp, save and use the mobile phone number you use at WhatsApp and- if provided- your first and last name in accordance with Art. 6 Para. 1 lit. b. GDPR for processing and answering your concern. On the basis of the same legal basis, we may ask you via WhatsApp to provide you with the provision of further data (order number, customer number, address or email address) in order to be able to assign your request to a specific process.
Use our WhatsApp contact for general inquiries (such as the range of services, for availability or for our website) Save and we use the mobile phone number you use at WhatsApp and- if provided- your first and last name in accordance with Art. 6 Para. 1 lit .
Your data will always only be used to answer your request via WhatsApp. There is no transfer to third parties.
Please note that WhatsApp Business receives access to the address book of the mobile device we use for this purpose and automatically transmits telephone numbers stored in the address book to a server of the parent company Meta Platform Inc. in the USA. For the operation of our WhatsApp business account, we use a mobile device, in the address book of which only the WhatsApp contact data of such users who have also come into contact with us via WhatsApp are also stored.
This ensures that every person whose WhatsApp contact details are stored in our address book is already when the app is used for the first time by accepting the WhatsApp terms of use into the transmission of his WhatsApp phone number from the address books of his chat contacts in accordance with Art. 6 para. 1 lit. a GDPR. The transmission of data of such users who do not use WhatsApp and/or have not contacted us via WhatsApp is excluded.
The purpose and scope of the data collection and the further processing and use of the data by WhatsApp as well as your rights and setting options to protect your privacy can be found in the data protection information from WhatsApp: https://www.whatsapp.com/legal/? EEA = 1#privacy policy
We have concluded an order processing contract with the provider that protects our side visitors' data and prohibits a transfer to third parties.
As part of the above -mentioned processing, data transmissions to Server from Meta Platforms Inc. can occur in the USA.
For data transmission to the USA, the provider has joined the EU-US-data protection framework (EU-US-EU Privacy Framework), which ensures compliance with the European data protection level on the basis of an adequacy decision by the European Commission.
5.3As part of contact with us (e.g. via contact form or email)-only for the purpose of processing and answering your request and only to the extent required-personal data are processed.
The legal basis for the processing of this data is our legitimate interest in answering your concern in accordance with Art. 6 Para. 1 lit. f GDPR. If your contact is aimed at a contract, the additional legal basis for the processing is Art. 6 Para. 1 lit. b GDPR. Your data will be deleted when it can be seen from the circumstances that the affected fact is finally clarified and if there are no statutory retention obligations.
6) Data processing when opening a customer account
According to Art. 6 Para. 1 Lit. B GDPR, personal data will continue to be collected and processed to the extent required if you provide us with the opening of a customer account. The input mask of the corresponding form on our website can be found in which data is required for the opening of the account.
Your customer account is deleted at any time and can be made by a message to the above address of the person responsible. After deleting your customer account, your data will be deleted, provided that all contracts concluded over it are completely handled, there are no statutory retention periods and our partly no legitimate interest in the further storage continues.
7) Use of customer data for direct marketing
7.1Registration for our email newsletter
If you register for our email newsletter, we will send you information about our offers regularly. Your email address is solely mandatory for sending the newsletter. The specification of further data is voluntary and is used to be able to address you personally. For the newsletter shipping, we use the so-called Double Opt-in that ensures that you will only receive newsletters if you have expressly confirmed your consent to the newsletter reception by pressing an email address provided to the specified email address.
By activating the confirmation link, you will give us your consent to the use of your personal data in accordance with Art. 6 Para. 1 Lit. a GDPR. Here we save your IP address entered by the Internet Service provider (ISP) as well as the date and time of registration in order to be able to understand a possible misuse of your email address at a later date. The data collected by us when registering for the newsletter are used strictly.
You can unsubscribe to the newsletter at any time via the link provided in the newsletter or by the corresponding message to the responsible person mentioned at the beginning. After deregistration, your e-mail address will be deleted immediately in our newsletter distributor, unless you have expressly consented to further use of your data or we are reserved for any further data usage that is legally permitted and about which we inform you in this declaration.
7.2Shipping of the email newsletter to existing customers
If you have made your email address available to us when buying goods or services, we reserve the right to send you offers for goods or services, such as those already purchased, from our range by email. To do this, we do not have to obtain separate consent from you in accordance with Section 7 (3) UWG. In this respect, data processing takes place solely on the basis of our legitimate interest in personalized direct marketing in accordance with Art. 6 Para. 1 lit. f GDPR. If you initially contradict the use of your email address for this purpose, a mail order from our part does not take place.
You are entitled to contradict the use of your email address for the predetermined advertising purpose at any time with effect for the future by notification to the responsible person at the beginning. For this, only transmission costs according to the basic tariffs are incurred. After receipt of your objection, the use of your email address for advertising purposes will be set immediately.
7.3Omnic
Our email newsletter is sent by this provider: Soundest Ltd., Unit A3, Gateway Tower, 32 Western Gateway, London E16 1L, England
Based on our legitimate interest in an effective and user-friendly newsletter marketing, we pass on your data provided for the newsletter registration according to Art. 6 Para. 1 lit. f GDPR to this provider so that the newsletter shipping on our behalf.
Subject to your express consent in accordance with Art. 6 Para. 1 lit. a GDPR, the provider also carries out a statistical evaluation of success of newsletter campaigns using web beacons or tracking pixels in the emails sent, the opening rates and specific interactions with the content can measure the newsletter. The end device information (e.g. time of the call, IP address, browser type and operating system) is also charged and evaluated, but not merged with other databases.
You can revoke your consent to newsletter tracking at any time with effect for the future.
We have concluded an order processing contract with the provider that protects our side visitors' data and prohibits a transfer to third parties.
In the case of data transmission to the provider location, an appropriate level of data protection is guaranteed by an adequacy decision of the European Commission.
7.4Property availability by e-mail
For temporarily non-available items, you can register for the receipt of email goods availability notifications. We will send you a message by email about the availability of the item you selected. Your email address is mandatory for sending this notification. The specification of further data is voluntary and is used if necessary to be able to address it personally. For the mail order shipping, we use the so-called double opt-in procedure, which ensures that you will only receive a notification if you have expressly confirmed your consent to us by pressing an email address provided to the specified email address.
By activating the confirmation link, you will give us your consent to the use of your personal data in accordance with Art. 6 Para. 1 Lit. a GDPR. Here we save your IP address entered by the Internet Service provider (ISP) as well as the date and time of registration in order to be able to understand a possible misuse of your email address at a later date. The data collected by us when registering for our email notification service for goods availability are used strictly.
You can unsubscribe from the availability notifications at any time by the appropriate message to the responsible responsible person. After deregistration, your e-mail address will be deleted immediately from our distributor set up for this purpose, provided that you have not expressly consented to further use of your data or we are reserved for an additional data usage that is permitted by law and which we will inform you in this explanation .
7.5Cart's memories by email
In the event of the termination of your purchase from us, you have the option of being reminded of the content of your virtual shopping cart once before completing the order.
Your email address is mandatory for sending this memory. The specification of further data is voluntary and is used if necessary to be able to address it personally. For the mail order shipping, we use the so-called double opt-in procedure, which ensures that you will only receive a notification if you have expressly confirmed your consent to us by pressing an email address provided to the specified email address.
By activating the confirmation link, you will grant us your consent to the use of your personal data in accordance with Art. 6 Para. 1 Lit. a GDPR for sending a shopping cart reminder. Here we save your IP address entered by the Internet Service provider (ISP) as well as the date and time of registration in order to be able to understand a possible misuse of your email address at a later date. The data collected by us when registering for our email notification service are used strictly.
You can unsubscribe from the shopping basket memories at any time by the appropriate message to the responsible responsible person. After deregistration, your e-mail address will be deleted immediately from our distributor set up for this purpose, provided that you have not expressly consented to further use of your data or we are reserved for an additional data usage that is permitted by law and which we will inform you in this explanation .
8) Data processing for order processing
8.1Insofar as the contractual processing is required for delivery and payment purposes, the personal data we collect will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 Para. 1 Lit.B GDPR.
If we are on the basis of a corresponding contract updates for goods with digital elements or for digital products, we will process the contact details you transmit when you order (name, address, email address) in order to be within the framework of our statutory information obligations in accordance with Art. 6 ABS . 1 lit. c GDPR on a suitable communication path (such as postal or email) about upcoming updates in the legally provided period. Your contact details will be used strictly for communications about updates owed by us and for this purpose by us only processed to the extent that this is necessary for the respective information.
To handle your order, we also work with the subsequent service provider (s), who support us in whole or in part in the implementation. Certain personal data is transmitted to these service providers in accordance with the following information.
8.2Delivering of personal data to shipping service providers
- German postal service
As a transport service provider, we use the following provider: Deutsche Post AG, Charles-de-Gaulle-Straße 20, 53113 Bonn, Germany
We pass on your email address and/or telephone number in accordance with Art. 6 Para. 1 lit. a GDPR before delivery of the goods for the purpose of the coordination of a delivery date or for the delivery notice to the provider, provided that you are expressed in the order process Have given consent. Otherwise, we only pass on the name of the recipient and the delivery address to the provider for the purpose of delivery in accordance with Art. 6 Para. 1 Lit. B GDPR. The transfer is only carried out if this is required for the delivery of goods. In this case, a prior coordination of the delivery date with the provider or the delivery notice is not possible.
The consent can be revoked at any time with effect for the future towards the person responsible for the above or to the provider.
- DHL
We use the following provider as a transport service provider: DHL Paket GmbH, Sträßchensweg 10, 53113 Bonn, Germany
We will pass on your e-mail address and/or telephone number to the provider in accordance with Art. 6 Para. 1 lit have given consent. Otherwise, for the purpose of delivery in accordance with Article 6 Paragraph 1 Letter b GDPR, we will only pass on the name of the recipient and the delivery address to the provider. The data will only be passed on to the extent that this is necessary for the delivery of the goods. In this case, prior coordination of the delivery date with the provider or delivery notification is not possible.
Consent can be revoked at any time with future effect from the person responsible above or from the provider.
8.3Use of payment service providers (payment services)
-Apple Pay
If you choose the “Apple Pay” payment method from Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, the payment will be processed via the “Apple Pay” function of your device running iOS, watchOS or macOS by debiting a payment card stored with “Apple Pay”. Apple Pay uses security features built into your device's hardware and software to protect your transactions. In order to approve a payment, you must enter a code previously specified by you and verify it using the “Face ID” or “Touch ID” function of your device.
For the purpose of payment processing, the information you provided during the ordering process, along with the information about your order, will be passed on to Apple in encrypted form. Apple then encrypts this data again with a developer-specific key before the data is transmitted to the payment service provider of the payment card stored in Apple Pay to carry out the payment. Encryption ensures that only the website through which the purchase was made can access the payment details. After the payment is made, Apple sends your device account number and a transaction-specific, dynamic security code to the originating website to confirm the payment success.
If personal data is processed during the transfers described, the processing takes place exclusively for the purpose of payment processing in accordance with Article 6 (1) (b) GDPR.
Apple retains anonymized transaction information, including the approximate purchase amount, the approximate date and time, and whether the transaction was successfully completed. Anonymization completely excludes any personal reference. Apple uses the anonymized data to improve Apple Pay and other Apple products and services.
When you use Apple Pay on iPhone or Apple Watch to complete a purchase made through Safari on Mac, the Mac and the authorization device communicate over an encrypted channel on Apple's servers. Apple does not process or store any of this information in a format that can be used to identify you. You can turn off the ability to use Apple Pay on your Mac in your iPhone's settings. Go to Wallet & Apple Pay and turn off Allow Payments on Mac.
Further information on data protection with Apple Pay can be found at the following internet address: https://support.apple.com/de-de/HT203027
- Google Pay
If you choose Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), the payment processing is carried out via the "Google Pay" application of your with at least Android 4.4 (“Kitkat”) operated mobile devices that have been operated by an NFC function by loading a payment card stored on Google Pay or a payment system verified there (e.g. PayPal). For the release of a payment via Google Pay of more than € 25,- € previously unlocking your mobile device is required by the verification measure (such as face recognition, password, fingerprint or pattern).
For the purpose of the payment processing, your information given as part of the ordering process and the information about your order will be passed on to Google. Google then transmits its payment information stored in Google Pay in the form of a one -off transaction number to the starting website with which a payment is verified. This transaction number contains no information about the real payment data of your payment method stored in Google Pay, but is created and transmitted as a one -off numerical token. In all transactions via Google Pay, Google only appears as an intermediary for processing the payment process. The transaction is carried out exclusively in the ratio between the user and the output website by loading the payment stored on Google Pay.
If personal data is processed in the transmission described, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 Para. 1 lit. b GDPR.
Google reserves the right to collect, save and evaluate certain process -specific information on every transaction made via Google Pay. This includes the date, time and amount of the transaction, dealer location and description, a description of the goods or services provided by the dealer, photos that you have attached to the transaction, the name and email address of the seller and buyer or buyer or of the sender and recipient, the payment method used, its description for the reason of the transaction and, if necessary, the offer associated with the transaction.
According to Google, this processing takes place exclusively in accordance with Art. 6 Para. 1 lit. f GDPR on the basis of the legitimate interest in the proper accounting, the verification of process data and the optimization and function maintenance of the Google Pay service.
Google also reserves the right to bring the processed process data together with further information that is collected and saved by Google when using further Google services.
Google Pay's terms of use can be found here:
https://payments.google.com/Payments/APIS-Secure/u/0/get_legal_document? Ldo = 0& ldt = Google Paytos& ldl = de
Further information on data protection on Google Pay can be found at the following Internet address:
https://payments.google.com/Payments/APIS-Secure/get_legal_document? Ldo = 0& ldt = privacynotice& ldl = de
- Klarna
One or more types of online payment from the following provider are available on this website: Klarna Bank, Sveafen 46, 111 34 Stockholm, Sweden
If you choose a payment method of the provider, in which you are in advance (such as credit card payment), your payment data communicated as part of the order process (including name, address, banking and number card information, currency and transaction number) as well as information about the content of your order will passed on in accordance with Art. 6 Para. 1 lit. b GDPR. In this case, your data is passed on exclusively for the purpose of payment processing with the provider and only insofar as it is necessary.
If you choose a payment method in which the provider is in advance (such as accounting or installment purchase or direct debit), you will also be asked in the order process, certain personal data (first and last name, street, house number, postal code, place, date of birth, E -Mail address, telephone number, possibly data on an alternative means of payment).
In order to protect our legitimate interest in determining the solvency of our customers, we are forwarded to the provider for the purpose of a credit check to the provider in accordance with Art. 6 Para. 1 lit. f GDPR. The provider checks on the basis of the personal data you specified and other data (such as shopping cart, invoice amount, order history, payment experience) whether the payment option you have selected with regard to payment and/or claim loss risks can be granted.
In addition to the provider-internal criteria in accordance with Art. 6 Para. 1 Lit. f GDPR, identity and credit information from the following information can also be included in the decision as part of the application test:
https://cdn.klarna.com/1.0/shared/content/legal/term/0/de_de/Credit_rting_agencies
The credit information can contain probability values (so-called score values). Insofar as score values flow into the result of the credit information, you have your basis in a scientifically recognized mathematical-statistical process. The calculation of the score values flow, among other things, but not exclusively, address data.
You can object to this processing of your data at any time by a message to us or to the provider. However, the provider may remain entitled to process your personal data, provided that this is necessary for contractual payment processing.
- PayPal
One or more types of online payment from the following provider are available on this website: PayPal (Europe) S.A.R.L. et cie, s.c.a., 22-24 Boulevard Royal, L-2449 Luxembourg
If you choose a payment method of the provider, in which you are in advance, your payment data communicated as part of the order process (including name, address, banking and number card information, currency and transaction number) as well as information about the content of your order in accordance with Art. 6 Paragraph 1 lit. b GDPR passed on. In this case, your data is passed on exclusively for the purpose of payment processing with the provider and only insofar as it is necessary.
When selecting a payment method in which we are in advance, you will also be asked in the order sequence, certain personal data (first and last name, street, house number, postcode, location, date of birth, email address, telephone number, an alternative means of payment).
In order to protect our legitimate interest in determining your solvency in such cases, this data is forwarded by us in accordance with Art. 6 Para. 1 Lit. f GDPR for the purpose of a credit check to the provider. The provider checks on the basis of the personal data you specified and other data (such as shopping cart, invoice amount, order history, payment experience) whether the payment option you have selected with regard to payment and/or claim loss risks can be granted.
The credit report can contain probability values (so-called score values). To the extent that score values are included in the results of the credit report, they are based on a scientifically recognized mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data.
You can object to this processing of your data at any time by sending a message to us or the provider. However, the provider may still be entitled to process your personal data if this is necessary for contractual payment processing.
- Shopify Payments
One or more online payment methods from the following provider are available on this website: Shopify International Limited, Victoria Buildings, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland
If you choose a payment method from the provider with which you pay in advance (e.g. credit card payment), the payment details you provided during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be sent to them passed on in accordance with Article 6 Paragraph 1 Letter b GDPR. In this case, your data will be passed on exclusively for the purpose of processing payments with the provider and only to the extent that it is necessary for this purpose.
9) Web analytics services
9.1Google Analytics 4
This website uses Google Analytics 4, a web analysis service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), which enables an analysis of your use of our website.
By default, when you visit the website, Google Analytics sets 4 cookies, which are stored as small text modules on your device and collect certain information. The scope of this information also includes your IP address, which, however, is shortened by Google by the last digits in order to exclude any direct personal reference.
The information is transferred to Google servers and further processed there. Transfers to Google LLC based in the USA are also possible.
Google uses the information collected on our behalf to evaluate your use of the website, to compile reports on website activity for us and to provide other services related to website activity and internet usage. The shortened IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. The data collected as part of the use of Google Analytics 4 is stored for a period of two months and then deleted.
All processing described above, in particular the setting of cookies on the device used, will only take place if you have given us your express consent in accordance with Article 6 (1) (a) GDPR.
Without your consent, Google Analytics 4 will not be used during your visit to the site. You can revoke your consent at any time with future effect. To exercise your right of withdrawal, please deactivate this service using the “cookie consent tool” provided on the website.
We have concluded an order processing agreement with Google that ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
Further legal information about Google Analytics 4 can be found at https://business.safety.google/intl/en/privacy/, https://policies.google.com/privacy?hl=de&gl=de and under https://policies.google.com/technologies/partner sites
Demographic characteristics
Google Analytics 4 uses the special “demographic characteristics” function and can use it to create statistics that make statements about the age, gender and interests of site visitors. This is done by analyzing advertising and information from third parties. This allows target groups for marketing activities to be identified. However, the data collected cannot be assigned to a specific person and will be deleted after being stored for a period of two months.
Google Signals
As an extension of Google Analytics 4, Google Signals can be used on this website to create cross-device reports. If you have activated personalized ads and have linked your devices to your Google account, Google can, subject to your consent to the use of Google Analytics in accordance with Article 6 (1) (a) GDPR, analyze your usage behavior across devices and use database models, including cross-device data Conversions, create. We do not receive any personal data from Google, only statistics. If you want to stop cross-device analysis, you can deactivate the "Personalized Advertising" function in your Google Account settings. To do this, follow the instructions on this page: https://support.google.com/ads/answer/2662922?hl=de You can find more information about Google Signals at the following link: https://support.google.com/analytics/answer/7532985?hl=de
UserIDs
As an extension to Google Analytics 4, the “UserIDs” function can be used on this website. If you have consented to the use of Google Analytics 4 in accordance with Article 6 Para. 1 lit. a GDPR, have set up an account on this website and log in with this account on different devices, your activities, including conversions, can be analyzed across devices become.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with European data protection levels based on an adequacy decision by the European Commission.
9.2Google Tag Manager
This website uses “Google Tag Manager”, a service provided by the following provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: “Google”).
Google Tag Manager provides a technical basis for bundling various web applications, including tracking and analysis services, and calibrating, controlling and attaching conditions to them via a uniform user interface. The Google Tag Manager itself does not store or read any information on user devices. The service also does not carry out any independent data analysis. However, when you access the page, Google Tag Manager will transfer your IP address to Google and, if necessary, store it there. Also a transmission to Google LLC servers. In the USA it is possible.
This processing will only be carried out if you have given us your express consent in accordance with Article 6 (1) (a) GDPR. Without this consent, Google Tag Manager will not be used during your visit to the site. You can revoke your consent at any time with future effect. To exercise your revocation, please deactivate this service in the “cookie consent tool” provided on the website.
We have concluded an order processing agreement with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with European data protection levels based on an adequacy decision by the European Commission.
Further legal information about Google Tag Manager can be found at https://business.safety.google/intl/en/privacy/ and https://policies.google.com/privacy?hl=de&gl=de
9.3Hotjar
This website uses the web analysis service of the following provider: Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta
Using cookies and/or comparable technologies (tracking pixels, web beacons, algorithms for reading device and browser information), the service collects and stores pseudonymized visitor data, including information about the device used such as the IP address and browser information, in order to use it for to evaluate statistical analyzes of usage behavior on our website and to create pseudonymized usage profiles. Among other things, this makes it possible to evaluate movement patterns (so-called heatmaps), which show the duration of page visits as well as interactions with page content (e.g. text input, scrolling, clicks and mouse-overs). Pseudonymization fundamentally excludes any direct personal reference. It will not be merged with clear personal data collected about you in any other way.
All processing described above, in particular the reading or storage of information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 Paragraph 1 Letter a of the GDPR. You can revoke your consent at any time with future effect by deactivating this service in the “cookie consent tool” provided on the website.
We have concluded an order processing agreement with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
9.4Matomo
This website uses a web analysis service from the following provider: InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand, (“Matomo”)
To protect site visitors, Matomo uses a so-called “config_id” to enable various analyzes of site usage within a short time window of up to 24 hours. The site's "config_id" is a randomly set, time-limited hash of a limited set of the visitor's settings and attributes. The config_id or config hash is a string calculated for a visitor based on their operating system, browser, browser plugins, IP address and browser language. Matomo does not use device fingerprinting and uses an anonymized IP address of the site visitor to create the “config_id”.
If the information processed in this way includes personal user data, the processing takes place in accordance with Article 6 Paragraph 1 Letter f of the GDPR on the basis of our legitimate interest in the statistical analysis of user behavior for optimization and marketing purposes. In order to object to data processing of your visitor data in the future, we provide you with a separate option to object on our website.
If data collected using Matomo technology (including your pseudonymized IP address) is transferred to Matomo servers in New Zealand and processed for usage analysis purposes, we would like to inform you that the European Commission has issued a so-called adequacy decision for New Zealand, which ensures compliance with European regulations Data protection standards for international data transfers attested.
If data is also transferred to the provider's server and the web analysis service has not been installed locally on our server, we have concluded an order processing agreement with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
10) Retargeting/remarketing and conversion tracking
10.1Meta pixels
Within our online offering we use the “Meta Pixel” service from the following provider: Meta Platforms Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland (“Meta”)
If a user clicks on an advertisement we place on Facebook and/or Instagram, the URL of our linked page is expanded by a parameter using “Meta Pixel”. After redirection, this URL parameter is then entered into the user's browser via a cookie that our linked page sets itself.
On the one hand, this makes it possible for Meta to determine the visitors to our online offering as a target group for the display of advertisements (so-called “ads”). Accordingly, we use the service to only show the Facebook and/or Instagram ads we place to users who have shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products, which can be determined based on the websites visited) which we transmit to Meta (so-called “Custom Audiences”).
On the other hand, the “meta pixel” can be used to track whether users were redirected to our website after clicking on an advertisement and what actions they took there (so-called “conversion tracking”).
The data collected is anonymous to us, so it does not allow us to draw any conclusions about the identity of the user. However, the data is stored and processed by Meta so that a connection to the respective user profile is possible and Meta can use the data for its own advertising purposes.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 (1) (a) GDPR. You can revoke your consent at any time with future effect by deactivating this service in the “cookie consent tool” provided on the website.
We have concluded an order processing agreement with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
The information generated by Meta is usually transferred to a Meta server and stored there; In this context, there may also be a transfer to Meta Platforms Inc. servers in the USA.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with European data protection levels on the basis of an adequacy decision by the European Commission.
10.2Google Ads Remarketing
This website uses retargeting technology from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
For this purpose, Google sets a cookie in the browser of your device, which automatically enables interest-based advertising using a pseudonymous cookie ID and based on the pages you visit. Any further data processing will only take place if you have agreed to Google that your internet and app browser history will be linked by Google to your Google account and that information from your Google account will be used to personalize ads that you display on the web regard. In this case, if you are logged in to Google while visiting our website, Google will use your data together with Google Analytics data to create and define target group lists for cross-device remarketing. To do this, Google temporarily links your personal data with Google Analytics data to form target groups. As part of the use of Google Ads Remarketing, personal data may also be transmitted to the servers of Google LLC. come to the USA.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 (1) (a) GDPR. Without this consent, retargeting technology will not be used during your visit to the site.
You can revoke your consent at any time with future effect. To exercise your revocation, please deactivate this service in the “cookie consent tool” provided on the website.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with European data protection levels on the basis of an adequacy decision by the European Commission.
Details about the processing initiated by Google and how Google handles data from websites can be found here: https://policies.google.com/technologies/partner sites
Further information about Google's data protection regulations can be found here: https://business.safety.google/intl/en/privacy/ and https://www.google.de/policies/privacy/
10.3Microsoft Advertising
This website uses retargeting technology from the following provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA
This makes it possible to specifically target visitors to our website who have already shown an interest in our shop and our products with personalized, interest-based advertising. The display of advertising is based on a cookie-based analysis of previous and current usage behavior, but no personal data is stored. In cases of retargeting technology, a cookie is stored on your computer or mobile device to collect pseudonymized data about your interests and thus tailor advertising to the information stored. These cookies are small text files that are stored on your computer or mobile device. You will be shown advertising that most likely corresponds to your product and information interests.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 (1) (a) GDPR. Without this consent, retargeting technology will not be used during your visit to the site.
You can revoke your consent at any time with future effect. To exercise your revocation, please deactivate this service in the “cookie consent tool” provided on the website.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with European data protection levels on the basis of an adequacy decision by the European Commission.
10.4relevance
This website uses retargeting technology from the following provider: releva GmbH, Feilnerstr. 10, 10969 Berlin, Germany
This makes it possible to specifically target visitors to our website who have already shown an interest in our shop and our products with personalized, interest-based advertising. The display of advertising is based on a cookie-based analysis of previous and current usage behavior, but no personal data is stored. In cases of retargeting technology, a cookie is stored on your computer or mobile device to collect pseudonymized data about your interests and thus tailor advertising to the information stored. These cookies are small text files that are stored on your computer or mobile device. You will be shown advertising that most likely corresponds to your product and information interests.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 (1) (a) GDPR. Without this consent, retargeting technology will not be used during your visit to the site.
You can revoke your consent at any time with future effect. To exercise your revocation, please deactivate this service in the “cookie consent tool” provided on the website.
10.5Google Ads conversion tracking
This website uses the online advertising program “Google Ads” and, as part of Google Ads, conversion tracking from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).
We use Google Ads to draw attention to our attractive offers on external websites using advertising materials (so-called Google Adwords). We can use the data from the advertising campaigns to determine how successful the individual advertising measures are. Our aim is to show you advertising that is of interest to you, to make our website more interesting for you and to achieve a fair calculation of the advertising costs incurred.
The conversion tracking cookie is set when a user clicks on an Ads ad placed by Google. Cookies are small text files that are stored on your device. These cookies usually expire after 30 days and are not used for personal identification. If the user visits certain pages on this website and the cookie has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Cookies cannot therefore be tracked via the websites of Google Ads customers. The information collected using the conversion cookie is used to create conversion statistics for Google Ads customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, you will not receive any information that can be used to personally identify users.
When using Google Ads, personal data may also be transmitted to the servers of Google LLC. come to the USA.
Details about the processing initiated by Google Ads Conversion Tracking and how Google handles data from websites can be found here: https://policies.google.com/technologies/partner sites
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 (1) (a) GDPR. You can revoke your consent at any time with future effect by deactivating this service in the “cookie consent tool” provided on the website.
You can also permanently object to the setting of cookies by Google Ads Conversion Tracking by downloading and installing the Google browser plug-in available at the following link:
https://www.google.com/settings/ads/plugin?hl=de
In order to address users whose data we have received as part of business or business-like relationships in an even more appropriate way, we use a customer matching function as part of Google Ads. For this purpose, we transmit one or more files with aggregated customer data (especially email addresses and telephone numbers) to Google electronically. Google does not receive access to clear data, but instead automatically encrypts the information in the customer files using a special algorithm during the transmission process. The encrypted information can then only be used by Google to assign it to existing Google accounts that those affected have set up. This enables personalized advertising to be displayed across all Google services linked to the respective Google account.
Customer data will only be transmitted to Google if you have given us your express consent to do so in accordance with Article 6 (1) (a) GDPR. You can revoke this consent from us at any time with effect for the future. Further information about Google's data protection measures in relation to the Customer Match function can be found here: https://support.google.com/google ads/answer/6334160?hl=de&ref_topic=10550182
Google's privacy policy can be viewed here: https://business.safety.google/intl/en/privacy/ and https://www.google.de/policies/privacy/
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with European data protection levels based on an adequacy decision by the European Commission.
10.6Google Ads conversion tracking
This website uses the online advertising program “Google Ads” and, as part of Google Ads, conversion tracking from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). We use Google Ads to draw attention to our attractive offers on external websites using advertising materials (so-called Google Adwords). We can use the data from the advertising campaigns to determine how successful the individual advertising measures are. Our aim is to show you advertising that is of interest to you, to make our website more interesting for you and to achieve a fair calculation of the advertising costs incurred.
The conversion tracking cookie is set when a user clicks on an Ads ad placed by Google. Cookies are small text files that are stored on your device. These cookies usually expire after 30 days and are not used for personal identification. If the user visits certain pages on this website and the cookie has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Cookies cannot therefore be tracked via the websites of Google Ads customers. The information collected using the conversion cookie is used to create conversion statistics for Google Ads customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, you will not receive any information that can be used to personally identify users. When using Google Ads, personal data may also be transmitted to the servers of Google LLC. come to the USA.
Details about the processing initiated by Google Ads Conversion Tracking and how Google handles data from websites can be found here: https://policies.google.com/technologies/partner sites
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 (1) (a) GDPR. You can revoke your consent at any time with future effect by deactivating this service in the “cookie consent tool” provided on the website.
You can also permanently object to the setting of cookies by Google Ads Conversion Tracking by downloading and installing the Google browser plug-in available at the following link:
https://www.google.com/settings/ads/plugin?hl=de
Please note that certain functions of this website may not be possible or may only be used to a limited extent if you have deactivated the use of cookies.
Google's privacy policy can be viewed here: https://business.safety.google/intl/en/privacy/ and https://www.google.de/policies/privacy/
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with European data protection levels based on an adequacy decision by the European Commission.
10.7Google Marketing Platform
This website uses the online marketing tool Google Marketing Platform from the operator Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("GMP").
GMP uses cookies to deliver ads that are relevant to users, to improve campaign performance reporting, or to prevent a user from seeing the same ads multiple times. Google uses a cookie ID to record which advertisements are shown in which browser and can thus prevent them from being displayed multiple times. In addition, GMP can use cookie IDs to record so-called conversions that are related to ad requests. This is the case, for example, if a user sees a GMP ad and later, using the same browser, visits the advertiser's website and purchases something via this website. According to Google, GMP cookies do not contain any personal information.
Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server.
We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you as follows based on our knowledge: By integrating GMP, Google receives the information that you have accessed the corresponding part of our website accessed our website or clicked on an advert from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, there is a possibility that the provider will find out and store your IP address. As part of the use of GMP, personal data may also be transmitted to the servers of Google LLC. come to the USA.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 (1) (a) GDPR. You can revoke your consent at any time with future effect by deactivating this service in the “cookie consent tool” provided on the website.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with European data protection levels based on an adequacy decision by the European Commission.
The data protection regulations of GMP by Google can be found here: https://business.safety.google/intl/en/privacy/ and https://www.google.de/policies/privacy/
10.8Microsoft Advertising Universal Event Tracking
This website uses conversion tracking technology from the following provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA
To use Universal Event Tracking, a tag is stored on every page of our website that interacts with the conversion cookie set by Microsoft. This interaction makes user behavior on our website traceable and sends the information collected to Microsoft. The purpose of this is that certain predefined goals such as purchases or leads can be statistically recorded and evaluated in order to make the orientation and content of our offers more relevant to your interests. The tags are never used to personally identify users.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 (1) (a) GDPR. Without this consent, retargeting technology will not be used during your visit to the site.
You can revoke your consent at any time with future effect. To exercise your revocation, please deactivate this service in the “cookie consent tool” provided on the website.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with European data protection levels on the basis of an adequacy decision by the European Commission.
10.9TikTok pixels
This website uses conversion tracking technology from the following provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland
If you came to our website from an advertisement on the provider's domain, the success of the advertisement can be tracked using cookies and/or comparable technologies (tracking pixels, web beacons, pings or HTTP requests).
For this purpose, certain device and browser information, including your IP address, is read using tracking technology in order to record and evaluate user actions predefined by us (e.g. completed transactions, leads, search queries on the website, views of product pages). This makes it possible to create statistics about usage behavior on our website after being redirected from an advertisement, which we use to optimize our offering.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your express consent to this in accordance with Article 6 (1) (a) GDPR. You can revoke your consent at any time with future effect by deactivating this service in the “cookie consent tool” provided on the website.
We have concluded an order processing agreement with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
11) Tools and miscellaneous
11.1- DATEV
To carry out the accounting, we use the cloud-based accounting software service from the following provider: DATEV eG, Paumgartnerstr. 6-14, 90429 Nuremberg, Germany
The provider processes incoming and outgoing invoices as well as our company's bank transactions in order to automatically record invoices, match them to the transactions and create financial accounting from them in a semi-automated process.
If personal data is also processed, the processing is carried out in accordance with Article 6 Paragraph 1 Letter f of the GDPR on the basis of our legitimate interest in the efficient organization and documentation of our business processes.
11.2Cookie consent tool
This website uses a so-called “cookie consent tool” to obtain effective user consent for cookies and cookie-based applications that require consent. The “cookie consent tool” is displayed to users when they access the page in the form of an interactive user interface on which consent can be given for certain cookies and/or cookie-based applications by checking a box. By using the tool, all cookies/services requiring consent are only loaded if the respective user gives their consent by checking the box. This ensures that such cookies are only set on the user's device if consent has been given.
The tool sets technically necessary cookies to store your cookie preferences. Personal user data is generally not processed here.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is carried out in accordance with Art. 6 Para. 1 lit. f GDPR on the basis of our legitimate interest in doing so legally compliant, user-specific and user-friendly consent management for cookies and therefore a legally compliant design of our website.
Another legal basis for the processing is Article 6 Paragraph 1 Letter c GDPR. As those responsible, we are subject to the legal obligation to make the use of cookies that are not technically necessary dependent on the respective user consent.
If necessary, we have concluded an order processing agreement with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.
Further information about the operator and the setting options for the cookie consent tool can be found directly in the corresponding user interface on our website.
12) Rights of the person concerned
12.1The applicable data protection law grants you the following data subject rights (rights of information and rights of intervention) vis-à-vis the person responsible for the processing of your personal data, whereby reference is made to the legal basis listed for the respective exercise requirements:
- Right to information in accordance with Art. 15 GDPR;
- Right to rectification in accordance with Art. 16 GDPR;
- Right to deletion in accordance with Art. 17 GDPR;
- Right to restriction of processing in accordance with Art. 18 GDPR;
- Right to information in accordance with Art. 19 GDPR;
- Right to data portability in accordance with Art. 20 GDPR;
- Right to revoke consent given in accordance with Art. 7 Para. 3 GDPR;
- Right to complain in accordance with Art. 77 GDPR.
12.2RIGHT TO OBJECT
IF WE PROCESS YOUR PERSONAL DATA AS PART OF A BALANCE OF INTERESTS BASED ON OUR OVERWHELMING LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION.
IF YOU USE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE AFFECTED DATA. HOWEVER, FURTHER PROCESSING IS RESERVED IF WE CAN PROVE COMPLEX REASONS FOR PROCESSING THAT ARE worthy of protection, which OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FUNDAMENTAL FREEDOMS, OR IF THE PROCESSING SERVES THE ASSERTMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS.
IF YOUR PERSONAL DATA IS PROCESSED BY US FOR DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING. YOU MAY EXERCISE YOUR OPT-OUT AS DESCRIBED ABOVE.
IF YOU USE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE AFFECTED DATA FOR DIRECT ADVERTISING PURPOSES.
13) Duration of storage of personal data
The duration of storage of personal data is determined based on the respective legal basis, the purpose of processing and - if relevant - additionally based on the respective legal retention period (e.g. commercial and tax retention periods).
When processing personal data on the basis of express consent in accordance with Article 6 (1) (a) GDPR, the data concerned will be stored until you revoke your consent.
If there are statutory retention periods for data that are processed within the framework of legal or transaction-like obligations on the basis of Art. 6 Para. 1 lit and/or we have no legitimate interest in further storage.
When processing personal data on the basis of Article 6 Paragraph 1 Letter f of the GDPR, this data will be stored until you exercise your right to object in accordance with Article 21 Paragraph 1 of the GDPR, unless we can provide compelling legitimate reasons for this demonstrate that the processing outweighs your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
When processing personal data for the purpose of direct advertising on the basis of Article 6 Paragraph 1 Letter f of the GDPR, this data will be stored until you exercise your right to object in accordance with Article 21 Paragraph 2 of the GDPR.
Unless otherwise stated in the other information in this declaration about specific processing situations, stored personal data will be deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.