1) Information about the collection of personal data and contact details of the responsible person.
1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, we inform you about the handling of your personal data when using our website. Personal data in this context is all data with which you can be personally identified.
1.2 The person responsible for data processing on this website within the meaning of the General Data Protection Regulation (DSGVO) is KUMPL GmbH, Rupert-Meyer-Straße 44, 81541 Munich, Germany, Tel.: 01734121791, e-mail: email@example.com. The controller of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
1.3 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or requests to the controller). You can recognize an encrypted connection by the character string "https://" and the lock symbol in your browser line.
2) Data collection when visiting our website
During the mere informational use of our website, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data, which is technically necessary for us to display the website to you:
Our visited website
Date and time at the time of access
Amount of data sent in bytes
Source/reference from which you reached the page
Operating system used
IP address used (if applicable: in anonymized form)
The processing is carried out in accordance with Art. 6 para. 1 lit. f DSGVO on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not passed on or used in any other way. However, we reserve the right to check the server log files retrospectively should concrete indications point to illegal use.
In order to make visiting our website more attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your terminal device. Some of the cookies we use are deleted after the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your end device and allow your browser to be recognized on your next visit (so-called persistent cookies). If cookies are set, they collect and process certain user information such as browser and location data as well as IP address values to an individual extent. Persistent cookies are automatically deleted after a specified period of time, which may differ depending on the cookie. The duration of the respective cookie storage can be found in the overview of the cookie settings of your web browser.
In some cases, the cookies are used to simplify the ordering process by storing settings (e.g. remembering the contents of a virtual shopping cart for a later visit to the website). 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 DSGVO either for the performance of the contract, in accordance with Art. 6 para. 1 lit. a DSGVO in the case of consent given, or in accordance with Art. 6 para. 1 lit. f DSGVO to protect our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the site visit.
Please note that you can set your browser in such a way that you are informed about the setting of cookies and can decide individually about their acceptance or can exclude the acceptance of cookies for certain cases or in general. Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find this for each browser at the following links:
Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies
Please note that if you do not accept cookies, the functionality of our website may be limited.
4) Contacting us
In the context of contacting us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of using a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. The legal basis for the processing of this data is our legitimate interest in responding to your request in accordance with Art. 6 (1) lit. f DSGVO. If your contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b DSGVO. Your data will be deleted after final processing of your request. This is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.
5) Data processing when opening a customer account and for contract processing
Pursuant to Art. 6 (1) lit. b DSGVO, personal data will continue to be collected and processed if you provide it to us for the purpose of executing a contract or opening a customer account. Which data is collected can be seen from the respective input forms. Deletion of your customer account is possible at any time and can be done by sending a message to the above address of the person responsible. We store and use the data provided by you for the purpose of processing the contract. After complete execution of the contract or deletion of your customer account, your data will be blocked with regard to tax and commercial law retention periods and deleted after expiration of these periods, unless you have expressly consented to a further use of your data or a legally permitted further use of data was reserved by our side.
6) Use of customer data for direct marketing purposes
6.1 Registration for our e-mail newsletter
If you register for our e-mail newsletter, we will send you regular information about our offers. The only mandatory data for sending the newsletter is your e-mail address. The provision of further data is voluntary and will be used to address you personally. For the dispatch of the newsletter we use the so called "newsletter". We will only send you an e-mail newsletter if you have explicitly confirmed that you agree to receive newsletters. This consent is given by clicking on the 'Subscribe' button on the website or in the pop-up.
By activating the button, you give us your consent for the use of your personal data in accordance with Art. 6 para. 1 lit. a DSGVO. When you register for the newsletter, we store your IP address entered by your Internet service provider (ISP) as well as the date and time of registration in order to be able to trace any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter will be used exclusively for the purpose of addressing you in an advertising manner by way of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the person responsible mentioned at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data or we reserve the right to use your data in a manner that goes beyond this, which is permitted by law and about which we inform you in this declaration.
6.2 Newsletter dispatch via Klaviyo
Our e-mail newsletters are sent via the technical service provider "Klaviyo", 225 Franklin St, Boston, MA 02110, USA (http://www.klaviyo.com/), to whom we pass on the data you provided when registering for the newsletter. This transfer takes place in accordance with Art. 6 (1) lit. f DSGVO and serves our legitimate interest in using a newsletter system that is effective in advertising, secure and user-friendly. Please note that your data is usually transferred to a Klaviyo server in the USA and stored there.
Klaviyo uses this information to send the newsletter on our behalf. Klaviyo does not use the data of our newsletter recipients to write to them itself or to pass it on to third parties.
To protect your data in the USA, we have a data processing agreement with Klaviyo ("Data Processing Agreement"), in which Klaviyo undertakes to protect the data of our users, to process it on our behalf in accordance with its data protection provisions and, in particular, not to pass it on to third parties.
7) Data processing for order handling
7.1 In order to process your order, we work together with the service provider(s) listed below, who support us in whole or in part in the execution of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information.
The personal data collected by us will be passed on to the transport company commissioned with the delivery as part of the contract processing, insofar as this is necessary for the delivery of the goods. We pass on your payment data to the commissioned credit institution within the scope of payment processing, insofar as this is necessary for payment processing. If payment service providers are used, we will inform you explicitly about this below. The legal basis for the transfer of data is Art. 6 (1) lit. b DSGVO.
7.2 Use of payment service providers (payment services)
- Apple Pay
If you choose the payment method "Apple Pay" of Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, the payment processing is carried out via the "Apple Pay" function of your end device running iOS, watchOS or macOS by charging a payment card deposited with "Apple Pay". Apple Pay uses security functions integrated into the hardware and software of your device to protect your transactions. For the release of a payment, the entry of a code previously defined by you as well as the verification by means of the "Face ID" or "Touch ID" function of your terminal device is therefore required.
For the purpose of payment processing, the information you provide during the ordering process, together with information about your order, is 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. The encryption ensures that only the website through which the purchase was made can access the payment data. After the payment has been made, Apple sends your device account number and a transaction-specific, dynamic security code to the source website to confirm the success of the payment.
If personal data is processed during the described transmissions, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 (1) lit. b DSGVO.
Apple retains anonymized transaction data, including the approximate purchase amount, the approximate date and time, and whether the transaction was completed successfully. The anonymization completely eliminates any reference to individuals. 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 identify you personally. You can disable the ability to use Apple Pay on your Mac in your iPhone settings. Go to "Wallet & Apple Pay," and uncheck "Allow payments on Mac."
For more information about Apple Pay privacy, please visit the following web address: https://support.apple.com/de-de/HT203027
- Google Pay
If you choose the payment method "Google Pay" of 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 mobile device running at least Android 4.4 ("KitKat") and having an NFC function by charging a payment card deposited with Google Pay or a payment system verified there (e.g. PayPal). For the release of a payment via Google Pay in the amount of more than €25, the prior unlocking of your mobile end device by the respective verification measure set up (such as facial recognition, password, fingerprint or pattern) is required.
For the purpose of payment processing, the information you provide during the ordering process, together with information about your order, will be passed on to Google. Google then transmits your payment information stored in Google Pay in the form of a uniquely assigned transaction number to the source website, with which a payment made is verified. This transaction number does not contain any information about the real payment data of your payment means deposited in Google Pay, but is created and transmitted as a one-time valid numeric token. For all transactions via Google Pay, Google only acts as an intermediary to process the payment transaction. The transaction is carried out exclusively in the relationship between the user and the source website by debiting the means of payment deposited with Google Pay.
Insofar as personal data is processed during the described transfers, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 (1) lit. b DSGVO.
Google reserves the right to collect, store and evaluate certain transaction-specific information for each transaction made via Google Pay. This includes the date, time and amount of the transaction, merchant location and description, a description of the purchased goods or services provided by the merchant, photos that you have attached to the transaction, the name and email address of the seller and buyer or the sender and recipient, the payment method used, your description for the reason for the transaction and, if applicable, the offer associated with the transaction.
According to Google, this processing is carried out exclusively in accordance with Art. 6 para.1 lit. f DSGVO on the basis of the legitimate interest in proper billing, verification of transaction data and optimization and functional maintenance of the Google Pay service.
Google also reserves the right to merge the processed transaction data with further information collected and stored by Google when using other Google services.
Further information on data protection at Google Pay can be found at the following Internet address:
When paying via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "installment payment" via PayPal, we pass on your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal") as part of the payment processing. The transfer takes place in accordance with Art. 6 para. 1 lit. b DSGVO and only insofar as this is necessary for the payment processing.
PayPal reserves the right to conduct a credit check for the payment methods credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "installment payment" via PayPal. For this purpose, your payment data may be passed on to credit agencies in accordance with Art. 6 para. 1 lit. f DSGVO on the basis of PayPal's legitimate interest in determining your solvency. PayPal uses the result of the credit check in terms of the statistical probability of non-payment for the purpose of deciding on the provision of the respective payment method. The credit report may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, they have their basis in a scientifically recognized mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data. For further information on data protection law, including information on the credit agencies used, please refer to PayPal's data protection declaration:
You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary for the contractual processing of payments.
- Shopify Payments
We use the payment service provider "Shopify Payments", 3rd Floor, Europa House, Harcourt Building, Harcourt Street, Dublin 2. If you choose a payment method offered via the payment service provider Shopify Payments, payment processing is carried out via the technical service provider Stripe Payments Europe Ltd, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, to whom we pass on your information provided during the ordering process together with information about your order (name, address, account number, bank code, credit card number if applicable, invoice amount, currency and transaction number) in accordance with Art. 6 (1) lit. b DSGVO. Your data will only be passed on for the purpose of payment processing with Stripe Payments Europe Ltd. and only insofar as it is necessary for this purpose. You can find more information on the data protection of Shopify Payments at the following Internet address: https://www.shopify.com/legal/privacy.
Data protection information on Stripe Payments Europe Ltd. can be found here: https://stripe.com/de/privacy
8) Online marketing
Facebook Pixel for the creation of Custom Audiences (with Cookie Consent Tool).
Within our online offer, the so-called "Facebook Pixel" of the social network Facebook is used, which is operated by Facebook Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland ("Facebook").
If a user clicks on an advertisement placed by us and played on Facebook, an addition is added to the URL of our linked page by Facebook Pixel. If our site allows data sharing with Facebook via Pixel, this URL parameter is inscribed in the user's browser via a cookie that our linked site sets itself. This cookie is then read by Facebook Pixel and enables the data to be forwarded to Facebook.
With the help of the Facebook Pixel, it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called "Facebook Ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not have a harassing effect. Thus, we can further evaluate the effectiveness of the Facebook ads for statistical and market research purposes by tracking whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion").
The data collected is anonymous for us, so it does not allow us to draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook data usage policy (https://www.facebook.com/about/privacy/). The data can enable Facebook as well as its partners to place advertisements on and outside of Facebook.
The data processing associated with the use of the Facebook Pixel is only carried out with your express consent in accordance with Art. 6 Para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future. To exercise your revocation, remove the check mark next to the setting for the "Facebook Pixel" in the "Cookie Consent Tool" embedded on the website.
9) Rights of the data subject
9.1 The applicable data protection law grants you comprehensive data subject rights (rights of information and intervention) vis-à-vis the controller with regard to the processing of your personal data, which we inform you about below:
- Right to information pursuant to Art. 15 DSGVO: You have in particular the right to information about your personal data processed by us, the processing purposes, the categories of personal data processed, the recipients or categories of recipients to whom your data have been or will be disclosed, the planned storage period or criteria for determining the storage period. the criteria for determining the storage period, the existence of a right to rectification, erasure, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if it has not been collected from you by us, the existence of automated decision-making, including profiling, and, if applicable, meaningful information about the logic involved and the scope and intended effects of such processing that concern you, as well as your right to be informed about what guarantees exist in accordance with Art. 46 of the GDPR if your data is transferred to third countries;
- Right to rectification pursuant to Art. 16 DSGVO: You have the right to have any inaccurate data relating to you corrected without delay and/or to have any incomplete data stored by us completed;
- Right to deletion pursuant to Art. 17 DSGVO: You have the right to demand the deletion of your personal data if the requirements of Art. 17 (1) DSGVO are met. However, this right does not exist in particular if the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims;
- Right to restriction of processing pursuant to Art. 18 GDPR: You have the right to request the restriction of the processing of your personal data as long as the accuracy of your data, which you dispute, is being verified; if you refuse the erasure of your data due to unlawful data processing and instead request the restriction of the processing of your data; if you require your data for the assertion, exercise or defense of legal claims after we no longer need this data after the purpose has been achieved; or if you have lodged an objection for reasons relating to your particular situation as long as it has not yet been determined whether our legitimate grounds prevail;
- Right to information pursuant to Art. 19 DSGVO: If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.
- Right to data portability pursuant to Art. 20 DSGVO: You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another controller, insofar as this is technically feasible;
- Right to revoke consent given in accordance with Art. 7 (3) DSGVO: You have the right to revoke consent to the processing of data once given at any time with effect for the future. In the event of revocation, we will delete the data concerned without delay, unless further processing can be based on a legal basis for processing without consent. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation;
- Right to lodge a complaint pursuant to Art. 77 GDPR: If you consider that the processing of personal data concerning you infringes the GDPR, you have - without prejudice to any other administrative or judicial remedy - the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement.
9.2 RIGHT OF OBJECTION
IF WE PROCESS YOUR PERSONAL DATA IN THE CONTEXT OF A BALANCING OF INTERESTS ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO CONTINUE PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING IS FOR THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR THE PURPOSES OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSES OF SUCH MARKETING. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.
10) Duration of storage of personal data
The duration of the storage of personal data is measured on the basis of the respective legal basis, the purpose of processing and - if relevant - additionally on the basis of the respective statutory retention period (e.g. retention periods under commercial and tax law).
When processing personal data on the basis of explicit consent pursuant to Art. 6 (1) a DSGVO, this data is stored until the data subject revokes his or her consent.
If there are statutory retention periods for data that is processed within the scope of legal or quasi-legal obligations on the basis of Art. 6 (1) (b) DSGVO, this data will be routinely deleted after the retention periods have expired, provided that it is no longer required for the fulfillment or initiation of a contract and/or there is no legitimate interest on our part to continue storing it.
When processing personal data on the basis of Art. 6(1)(f) DSGVO, this data is stored until the data subject exercises his or her right to object pursuant to Art. 21(1) DSGVO, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
When processing personal data for the purpose of direct marketing on the basis of Article 6 (1) (f) DSGVO, this data is stored until the data subject exercises his or her right to object pursuant to Article 21 (2) DSGVO.
Unless otherwise stated in the other information in this statement about specific processing situations, stored personal data will otherwise be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.