Privacy & Cookie Policy

DATA PROTECTION NOTICE

It is important to us that all visitors to our website feel comfortable and secure. For that reason, the we take the protection of your data extremely seriously. This document provides extensive information about how your data is processed when using our website and online shop.

When we refer to “your data” we mean personal data. Personal data refers to information that we can use to establish your identity, be that directly or in combination with other data. This includes for instance: your name, your address, your e-mail address, your telephone number, your customer or order number, your user conduct, your IP address.

Statistical data that we collect e.g. during a visit to our website and cannot link to your identity is not covered by the definition of personal data.

DATA CONTROLLER AND CONTACT DETAILS

The data controller as defined by the EU General Data Protection Regulation (“GDPR”) is

ZOLES  ApS
Hoejvangen 13
3060 Espergaerde
Tel. +45 53552800
E-mail zoles@zoles.eu

(hereinafter referred to as “Zoles”, “we” or “us”)

DATA PROCESSING FOR CONTRACTUAL PERFORMANCE AND CONTACT PURPOSES

Your ordering or purchasing data
If you place an order via our online shop, by phone or using an order card, we collect your order or purchasing data.
Additionally, for each customer we set up a customer account in which the above data is stored.

We process your data to enable us to deal with your order, send you your order and process any returns, complaints and warranty cases. We also process your data in order to comply with statutory retention obligations.

The legal basis of the foregoing data processing is processing for the performance of the contract or precontractual steps pursuant to Art. 6 (1) b) GDPR or on the basis of a legitimate interest pursuant to Art. 6 (1) f) GDPR.

On our website we also have contact and order forms which you can fill in if you wish to be contacted. The collected data from our contact forms is recorded in our Customer Relationship Management (CRM) system HubSpot and is used solely to register your enquiry and to enable our customer service or sales department to contact you and process your order with the necessary information.

MY ACCOUNT

To place an order with us, you shall set up an online customer account.

• We process your data so that you
• Have an overview of previous orders,
• Have a more comfortable and straightforward purchasing experience,
• Can view your personal data and
• Can track the progress of your orders.

The legal basis of the foregoing data processing is processing for the performance of the contract or precontractual steps pursuant to Art. 6 (1) b) GDPR.

YOUR CONTACT DATA AND NOTIFICATIONS

You have the opportunity to contact us. In that context we process your telephone number, your mobile number and/or your e-mail address exclusively for the purpose of communicating with you, e.g. in order for us to contact you if we have any questions relating to your order. Providing this information is voluntary, but it makes communication related to orders much easier. If you do not provide this information, we cannot contact you if we have any questions.

The legal basis of the foregoing data processing is processing for the performance of the contract or precontractual steps pursuant to Art. 6 (1) b) GDPR.

PAYMENT DATA

We offer the payment methods of credit card or debit card. Depending on the payment type you select in the order process, we pass on payment data collected at this point to the financial institution in charge of the payment and any payment service provider instructed by us or to the selected payment service for the handling of payments. Without this payment data and these payment service providers, payments and contracts cannot be dealt with.

The legal basis of the foregoing data processing is processing for the performance of the contract or precontractual steps pursuant to Art. 6 (1) b) GDPR.

DATA PROCESSING FOR THE PURPOSE OF CUSTOMIZING YOUR INSOLES

Your date of birth
You must provide your date of birth in the registration process. We use the age data in the process of modelling your customised insoles. The age is one of several parameters, that determine the hardness/softness of the insoles.

The legal basis for the foregoing data processing is consent pursuant to Art. 6 (1) a) GDPR.

Competitions and surveys
If you participate in one of our surveys, we use your data for market research and opinion polling. We use the data solely for internal purposes on an anonymised basis. If in exceptional cases surveys are not performed on an anonymous basis, the personal data will only be collected with your consent. Data protection laws do not apply to anonymous surveys.

In such exceptional cases where personal data is collected, the legal basis of the above data processing is your consent under Art. 6 (1) sentence 1 a) GDPR.

In the context of competitions, we use your data for the purpose of conducting the competition and notifying winners. For detailed information, refer to the conditions of participation for the respective competition.

The legal basis for the foregoing data processing is Art. 6 Abs. 1 b) GDPR.

NEWSLETTERS AND PROMOTIONAL CORRESPONDENCE

Newsletters
If you register for one of our newsletters, we use the data you provide with your express consent to send the respective newsletter. The newsletter contains current offers and information from Zoles. The personalised newsletter contains interesting offers, trends, promotions, tips and voluntary opinion polls. Your customer data as well as your purchasing and clicking behaviour is analysed.

The legal basis for the foregoing data processing is your consent pursuant to Art. 6 (1) a) GDPR.

DATA ON INTEREST

If you place an order with us, buy something from us or interact with our website, we learn about the products, product types, brands, styles and topics that you are interested in. For example, you may place products on your wishlist, search for products or repeatedly visit a given area of the online shop. This helps us to permanently improve your shopping experience and to make it customer-friendly, bespoke and personal. The information that you provide along with the information that is automatically generated is used to create promotional material that is tailored to you and your interests. We also use your data in connection with data analyses and market research.

The legal basis for the foregoing data processing is a legitimate interest pursuant to Art. 6 (1) f) GDPR.

ADVERTISING PARTNERS

We receive information from selected operators of online advertising networks such as Google or Facebook and data providers that undertake promotional activities on our behalf or in cooperation with us (referred to hereafter as “Advertising Partners”).

The information that we receive from Advertising Partners comprises information and statistics about demographics (such as age, gender, region), device and access data as well as our users’ interests. This information can help us to better understand our users, for instance in the context of customer-structure analyses and user segmentation. We only receive aggregated, encrypted data or data that is anonymous to us. We cannot allocate the data to a specific person, and especially not a specific user.

The legal basis for the foregoing data processing is a legitimate interest pursuant to Art. 6 (1) f) GDPR.

VISITING THIS WEBSITE

If you only use the website for information purposes, i.e. if you do not register or otherwise transfer any information to us, we only collect the personal data that your browser transmits to our server. If you want to view our website, we collect the following data that we require for technical purposes in order to display our website and guarantee stability and security.

The legal basis for the foregoing data processing is a legitimate interest pursuant to Art. 6 (1) sentence 1 f) GDPR.

USE OF COOKIES

We use cookies on various pages in order to make visiting our website an attractive experience and to enable the use of certain functions. Cookies are small text files that are stored on your device and store certain settings and data that are exchanged with our system via your browser.

GOOGLE

Google Analytics
Our website uses Google Analytics, a web analytics service from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies and similar technologies to analyse and improve our website based on your user behaviour. The data produced in this context may be transferred to and stored on a server in the USA by Google for analysis. Should personal data be transferred to the USA, Google has signed up to the EU-US Privacy Shield. However, before the usage statistics are analysed, your IP address will be shortened, meaning that your identity cannot be traced. To that end, Google Analytics has been expanded with the code “anonymizeIP” on our website to guarantee the anonymised collection of IP addresses.

Google uses the information gathered via the cookies to analyse your use of the website, to compile reports relating to website activity for the website operators and to provide further services connected to the use of the website and the Internet.

As set out above, you can configure your browser to reject cookies, or you can prevent the collection of the data generated by cookies relating to your use of this website (incl. your IP address) as well as the processing of this data by Google by downloading and installing the Browser Add-on provided by Google. As an alternative to the Browser Add-on, please use the opt-out link at the end of this notice. This will prevent data collection by Google Analytics within this website in future (the opt-out only works in the browser and only for this domain). If you delete your cookies in this browser, you need to click the link again.

For further information see the Google privacy policy.

Use of Google Adwords Conversion
We implement Google Adwords, which enables us to use advertising media (known as Google Adwords) on external websites to draw attention to our attractive product range. On the basis of the data of the advertising campaigns, we can determine the success of the individual advertising measures. By doing so we are pursuing the interest of showing you advertising that is of interest to you, making our website more interesting for you and achieving a fair calculation of advertising costs.

These advertising media are supplied by Google via what are termed “Ad Servers”. To that end we use Ad Server cookies that enable certain parameters for success measurement, such as displaying the ads or users’ clicks, to be measured. If you land on our page through a Google ad, Google Adwords stores a cookie on your PC. These cookies usually lose their validity after 30 days and are not intended to identify you personally. Analysis values stored for this cookie usually include unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) as well as opt-out information (marker that the user no longer wants to be targeted).

These cookies enable Google to recognise your Internet browser. If a user visits certain pages on the website of an Adwords customer and the cookie on his or her computer has not yet expired, Google and the customer recognise that the user has clicked the ad and was forwarded to this page. Each Adwords customer is allocated a different cookie. Cookies therefore cannot be traced via the websites of Adwords customers. We do not collect and process any personal data ourselves during these advertising measures. Google merely provides us with statistical analyses. These analyses enable us to identify which of the deployed advertising measures are particularly effective. We do not receive any data from the deployment of the advertising methods, in particular we cannot use this information to identify the users.

Based on the marketing tools used, your browser automatically creates a direct connection to Google’s server. We have no influence over the scope and further use of the data collected by Google via these tools and therefore inform you in accordance with our level of knowledge: by integrating AdWords Conversion, Google is given the information that you have accessed the corresponding part of our website or clicked one of our ads. If you are registered with a Google service, Google can allocate the visit to your account. Even if you are not registered with Google or are not logged in, there is a chance that the provider is aware of your IP address and stores it.

You can prevent your participation in this tracking process in a number of ways:

1. by a corresponding setting in your browser software; in particular, the suppression of third-party cookies means that you will receive no adverts from third parties;
2. by deactivating cookies for conversion tracking by setting your browser up for cookies to be blocked by the domain “www.googleadservices.com”, https://www.google.com/settings/ads (albeit these settings are deleted when you delete your cookies);
3. by deactivating the interest-driven ads of the providers who participate in the self-regulation campaign “About Ads”, via the link http://www.aboutads.info/choices, whereby this setting is deleted when you delete your cookies;
4. through permanent deactivation in the browsers Firefox, Internet Explorer or Google Chrome under https://support.google.com/ads/answer/7395996. We refer you to the fact that in this case you may not be able to use the full functionality of this offering.

The legal basis for this processing of your data is a legitimate interest pursuant to Art. 6 (1) sentence 1 f) GDPR. Further information on data protection at Google can be found here: https://policies.google.com/privacy and https://services.google.com/sitestats/en.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org. Google has signed up to the EU-US Privacy Shield.

INTEGRATION OF YOUTUBE VIDEOS

We have integrated videos into our website that are stored with YouTube and can be played directly from our websites. YouTube is a multimedia service by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (“YouTube”), a group company of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Should personal data be transferred to the USA, Google and the group company YouTube have signed up to the EU-US Privacy Shield. The legal basis is Art. 6 (1) sentence 1 f) GDPR, based on our legitimate interest in the integration of video and image content.

By visiting our website, YouTube and Google are notified that you have accessed the corresponding subpage of our website. This happens irrespective of whether you are logged on to YouTube or Google. YouTube and Google use this data for purposes of advertising, market research and needs-driven layout of their websites. If you access YouTube on our website while you are logged on to your YouTube or Google profile, YouTube and Google can further link this event to the respective profiles. If you don’t want such an allocation to be made, you need to log out of Google before accessing our website.

As set out above, you can configure your browser to reject cookies, or you can prevent the collection of the data generated by the cookies relating to your use of this website as well as the processing of this data by Google by accessing the Google Ads Settings and deactivating the “Ads Personalization” slider. In this case Google will only display non-individualised advertising.

Further information can be found in Google’s privacy policy applicable to YouTube.

STORAGE DURATION

We only ever store personal data for such time as is required for the performance of contractual or statutory obligations for which we have collected the data. Thereafter we delete the data immediately unless we still require the data for evidential purposes under civil law up to the expiry of the limitation period or due to statutory retention periods.

For evidential purposes we are required to store contractual data for a further three years after the end of the year in which the business relationship with you comes to an end. Any claims in accordance with the standard statutory limitation period shall become time barred at this point at the earliest.

Thereafter we may still store some of your data for accounting reasons. We are required to do so due to statutory documentary obligations arising under the Danish Commercial Code, Income Tax Code, Banking Act, Money Laundering Act and Securities Trading Act. The periods for the retention of documents set down therein comprise two to ten years.

YOUR RIGHTS

Under the respective statutory preconditions, you have the following statutory data protection rights:

• Right of access (Article 15 GDPR, section 34 BDSG)
• Right to erasure (Article 17 GDPR, section 35 BDSG)
• Right to rectification (Article 16 GDPR, section 34 BDSG)
• Right to restriction of processing (Article 18 GDPR)
• Right to data portability (Article 20 GDPR)
• Right to withdraw consent (Article 7 (3) GDPR)
• Right to object to certain data protection measures (Article 21 GDPR)

In order to assert your rights described here, you use the above contact details at any time.
You also have the right to complain to the competent data protection authority; the competent supervisory authority is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Alternatively, you may contact the data protection authority at your place of residence, which will forward the matter to the competent authority.

DATA SECURITY

We maintain up-to-date technical measures to guarantee data security, in particular to protect your personal data from risks from data transfers and disclosure to third parties. These are adapted to the respective state of the art at any given time. We use the Standard Secure Sockets layer (SSL) to protect the personal data you specify on the website. This encrypts the data you enter.

AMENDMENTS TO THE PRIVACY POLICY

We occasionally update this privacy policy, for example when we amend our website or the legal stipulations change.

Zoles® – last revised: June 2018