Personal data means all data that can be personally related to you, e.g. name, address, telephone number, email address or user behaviour.
1. Who is responsible for data processing?
The service provider and party responsible for processing personal data (‘controller’) is NORDROW INVESTMENTS, LLC you can reach us using the following contact details:
Email: [email protected]
Phone number: +1 (631) 660-8369
You can reach our external data protection officer at 9003 Quioccasin Rd, Richmond, VA 23229, USA.; e-mail: [email protected].
2. To what extent is personal data processed?
2.1 Collection of personal data when you visit our website
a) Log files
When using the Calebhwebsite for information purposes only, so when you do not log in to use the website, register or otherwise provide information, we collect the data that your browser transmits to our server. This includes in particular:
IP address,
date and time of the request,
time zone difference to Greenwich Mean Time (GMT),
name of the requested file,
access status/HTTP status code,
volume of data transferred,
the page from which you came to visit us,
your operating system and its interface,
your browser type and the language and version of the browser software,
a report of successful retrieval
The data is technically necessary for us to display our website to you. It is also evaluated to make the website user-friendly and to ensure stability and security. For this purpose, we partly use the external web hosting service providers Upcloud. In the event that data is also transferred to the USA, both service providers have subjected themselves to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework/). The legal basis for the processing is Art. 6(1) Sentence 1(f) GDPR.
b) Cookies and similar technologies
In addition, we also use cookies on our website. Cookies are small text files that are assigned to your browser and stored on your device. Through them, certain information flows to the place that sets the cookie, such as settings or data for exchange with the system. This helps us to make our website more user-friendly and effective overall. The legal bases for this are Art. 6(1) Sentences 1(a) and (f) GDPR. Cookies cannot execute programs or transmit viruses to your device.
Our website uses the following types of cookies:
session (transient) cookies,
long-term (persistent) cookies,
third-party cookies.
Session cookies store what’s called a session ID, which can be used to assign different requests of your browser to a common session. This allows your device to be recognised when you return to our website. For example, this lets you store certain information you have entered (such as log-in information, language settings) in such a way that you do not have to repeat it constantly. Session cookies are automatically deleted when you log out or close your browser.
Long-term cookies remain on your device for the time being, so that we can recognise your browser on your next visit and we can, for example, assign your preferred information and settings. Long-term cookies are automatically deleted after a specified period, which may vary depending on the cookie.
When you visit our website, our partner companies also store third-party cookies on your device. The cookies contain information about how our website is used, e.g. which pages and products were visited. The data is collected in a pseudonymised form by assigning an identification number, which is not combined with any other personal data you may have provided to us.
You can delete cookies in your browser settings at any time or prevent them from being stored, although the latter may result in a restriction of the functionality of our website for you. In the relevant sections of this Privacy Policy, we explain which technologies that are comparable to cookies are used on our website and how you can object to the use of cookies and other technologies with the individual third-party providers.
2.2 Ordering from Calebh / User Account
a) If you want to order something in our online shop, it is necessary for the conclusion of the contract that you give us the personal data we need to process the order. The mandatory data required to process the contract is marked as such; all other data you provide is voluntary. You can either enter your data only once for the order or use your email address to set up a password-protected user account with us, in which your data can be stored for later purchases until you revoke your consent. You can deactivate or delete the data and the user account at any time via the account.
To prevent unauthorised access to your personal data by third parties, the order process is encrypted using TLS technology.
When we process the data provided by you to process your order, this includes, for example, individual customer service. In the course of order processing, we pass on personal data to one of our third-party Fulfillers within the group, to a shipping company commissioned by the Fulfillers.
Payment via PayPal is processed by PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (“PayPal”). For information about data protection at PayPal, please refer to PayPal’s privacy policy: https://www.paypal.com/myaccount/privacy/privacyhub?locale.x=en.
Payment via Stripe is processed by Stripe, 354 Oyster Point Blvd South San Francisco, CA 94080 United States (“Stripe”). For information about data protection at Stripe, please refer to Stripe’s privacy policy: https://stripe.com/fr-us/privacy.
In the case of trackable parcels, we also pass on your order and address data to Printify Inc, 108 West 13th Street, Wilmington, Delaware, 19801, to make it possible to track your parcel and to inform you about delivery deviations or delays, for example.
The legal bases for the processing of personal data as part of order processing are Art. 6(1) Sentences 1(b) and (f) GDPR. Due to commercial and tax regulations, we are obliged to store your order, address and payment data for a period of ten years.
b) During the order process we also conduct a fraud prevention check via our payment gateway Stripe, which involves using your IP address to carry out a geolocalisation and compare your data with previous experience. This may mean that an order cannot be placed with the selected payment method. Our aim in this regard is to prevent any abuse of your chosen payment method by third parties and to protect ourselves from payment defaults. The legal basis for the processing is Art. 6(1) Sentence 1(f) GDPR.
Since this involves automated decision-making, you have the right to challenge the decision (in this case the refusal of a certain payment method) and have the decision reviewed by a person. In such cases we ask that you contact us using the contact details mentioned in Section 1. Please note that the payment method may have been rejected due to a typing error and you should, therefore, check what you have entered again during the order process if necessary.
c) During the ordering process we use Google Maps Autocomplete, a service of Google LLC (“Google”). This allows an address you start typing to be completed automatically, avoiding delivery errors. Google sometimes conducts a geolocalisation using your IP address and receives the information that you have retrieved the corresponding subpage of our website. In addition, the data referred to in Section 2.1 is transmitted. This is regardless of whether you have a Google account and are logged in. Once you are logged in to your Google Account, the information will be directly associated with your account. If you do not want this assignment to occur, you must log out before entering your address. Google stores your data as user profiles and uses it (even in the case of users who are not logged in) for the purposes of advertising, market research and/or the needs-oriented design of its own website. Google also processes your personal data in the USA and has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework). You can object to Google creating such user profiles. For more information about the purpose and scope of data processing by Google and about protecting your privacy, please refer to Google’s Privacy Policy: https://policies.google.com/privacy?hl=en. The binding terms of use for Google Maps/Google Earth can be found here: https://www.google.com/intl/en_US/help/terms_maps.html. Third-party provider information: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
The legal basis for the processing is Art. 6(1) Sentence 1(f) GDPR.
d) After you place an order, we will process your order and address data to send you a personalised email asking you to rate our products. By obtaining ratings, our aim is to improve our services and adapt them to our customers’ wishes. We use the feedback software of Trustpilot Ltd, 5th Floor, The Minster Building, 21 Mincing Ln., London EC3R 7AG, United Kingdom (“Trustpilot”). For the purpose of sending the feedback email (and in the event that a moderation or conciliation procedure is conducted via Trustpilot following negative feedback), we pass on your email address, name, order number, product types and a unique ID to Trustpilot for identification purposes and in order to generate a feedback link.
The legal basis for the processing is Art. 6(1) Sentence 1(f) GDPR. If you no longer want your data to be used for this purpose, you can object to this at any time. Just click on the unsubscribe link included with each email or send a message using the contact details provided under Section 1.
e) We also use Google Customer Reviews, a service of Google Ireland Ltd. (“Google”), through which we receive feedback about us as a seller and about our products. This allows us to improve our services and adapt them to our customers’ wishes. The legal basis is Art. 6(1) Sentence 1(f) GDPR. After placing an order, you can give Google permission to use your email address to request a review. In the event that data is also transferred to a Google server in the USA, Google LLC has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework/). You can revoke your consent to the use of your data at any time by clicking on the unsubscribe link contained in the emails from Google. For more detailed information about the purpose and scope of data processing by Google and about protecting your privacy, please refer to Google’s Privacy Policy: https://policies.google.com/privacy?hl=en. Third-party provider information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, fax: + 353 (1) 436 1001.
2.3 Calebh Partners: Shop Partners and Marketplace Designers
a) If you want to offer designs on our marketplace or operate a shop, it is necessary for the conclusion of a contract with us that you use your email address to open a password-protected user account and store your name and address there. For the payout of earnings, it is necessary that you additionally provide your bank details or your PayPal information as well as information about your tax status. Any other information you may provide to us when using the account is voluntary. You do not have to enter a real name when choosing your username. You can manage and change this information in your account. You can also deactivate or erase it – or the entire user account. If this affects data necessary for the performance of the contract, we may retain that data for a longer period in accordance with commercial and tax regulations (standard period of ten years). We process this data to conduct the contractual relationship that exists with you; the legal bases are Art. 6(1) Sentences 1(b) and (f) GDPR.
b) Within the scope of the contractual relationship, we also process the email address provided by you in order to send you emails at irregular intervals containing information and tips about the Marketplace and your shops (“Partner Newsletter”). We use your name to allow us to personalise these emails. To this end, the data is passed on to the software company Klaviyo eMarketing Systems AG, Hans-Fischer-Straße 10, 80339 Munich, Germany (“Klaviyo”), which handles the technical side of the mailing on our behalf. You can unsubscribe from the Partner Newsletter at any time by clicking on the unsubscribe link provided in each email, informing us via the contact details specified in Section 1, or changing your newsletter settings in your user account (“Account Settings” – “Newsletter subscriptions”).
When sending the Partner Newsletter, we use Klaviyo to statistically evaluate your user behaviour in order to optimise the design. To enable this evaluation, the emails contain what are called web beacons or tracking pixels. These are single-pixel image files that establish a connection to our website und thus permit a log file analysis. The web beacons are linked with the data mentioned in Section 2.1a and an individual ID. The links contained in the email also contain this ID. For example, we can see if and when an email has been opened and which links have been clicked on. The data is stored on the Klaviyo servers for 13 months and collected pseudonymously, meaning the IDs are not linked to other personal data at this point, thus ruling out any possibility of direct personal reference. You can object to the recording of your usage behaviour at any time by clicking on the unsubscribe link provided in each email, informing us via the contact options listed in Section 1, or changing the newsletter settings in your user account (“Account settings” – “Newsletter subscriptions”). Recording is not possible if you have disabled the display of images in your email settings. In this case, the newsletter will not be displayed to you in full and you may not be able to use all functions. If you choose to display the images manually, recording will take place as described above.
The legal bases for the processing are Art. 6(1) Sentences 1(a), (b) and (f) GDPR.
c) If you store your address in your user account, we use Google Maps Autocomplete, a service of Google LLC (“Google”). This allows an address you start typing to be completed automatically. This helps us verify your address, which we do for tax reasons. Google sometimes conducts a geolocalisation using your IP address. We also use Google Fonts to enhance the user experience in the Partner section of your account as well as Google Calendar to inform you about Partner-related promotions for customers. Via these services and applications, Google receives the information that you have retrieved the corresponding subpage of our website. In addition, the data referred to in Section 2.1 is transmitted. This is regardless of whether you have a Google account and are logged in. Once you are logged in to your Google Account, the information will be directly associated with your account. If you do not want this assignment to occur, you must log out before entering your address. Google stores your data as user profiles and uses it (even in the case of users who are not logged in) for the purposes of advertising, market research and/or the needs-oriented design of its own website. Google also processes your personal data in the USA and has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework). You can object to Google creating such user profiles. For more information about the purpose and scope of data processing by Google and about protecting your privacy, please refer to Google’s Privacy Policy: https://policies.google.com/privacy?hl=en. The binding terms of use for Google Maps/Google Earth can be found here: https://www.google.com/intl/en_US/help/terms_maps.html. Third-party provider information: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
The legal basis for the processing is Art. 6(1) Sentence 1(f) GDPR.
2.4 Communication with Calebh
a) Establishing contact
If you contact us via a contact form, letter, email, social media or telephone, we process the data provided by you for the purpose of processing your enquiry and – only in the legally permissible cases when communicating with entrepreneurs – for advertising purposes. We use the software of Sematell GmbH, Neugrabenweg 1, 66123 Saarbrücken, Germany, to coordinate and process emails, which means that Sematell GmbH gains access to the data. We use the management software of Hootsuite Media, Inc, 5 East 8th Avenue, Vancouver, BC, Canada to coordinate and process enquiries via our social media channels Twitter, Facebook and Instagram. The EU Commission has established the adequacy of the level of data protection in Canada. The legal basis for the processing is Art. 6(1) Sentence 1(f) GDPR. If the aim of establishing contact is to conclude a contract, then an additional legal basis is Art. 6(1) Sentence 1(b) GDPR.
b) Blog
In our blog, where we publish various articles on topics related to our activities, you can post public comments. Your comment will be published along with your chosen username. We recommend using a pseudonym instead of your real name. It is necessary to provide a username and email address, while all other information is voluntary. The necessary information is processed to run the Forum. We need your email address to contact you if a third party should complain that your comment is unlawful. We reserve the right to delete comments if third parties complain that they are unlawful. The legal basis for the processing is Art. 6(1) Sentence 1(f) GDPR.
c) Forum
With the exception of a few sections, our Forum can be read without the need to register. If you wish to actively participate in the Forum under your chosen username, you must log in using your calebh user account access data. To open a calebh user account, only your email address and a password are required. We process your activities (public posts, private messages, likes, profile information, activity logs) and your IP address in order to operate the Forum. The legal basis is Art. 6(1) Sentence 1(f) GDPR. If you deactivate or delete your user account, your public posts will continue to be visible. If you would like your public posts to be deleted, please contact us using the contact details provided in Section 1. When writing a comment and in the Forum settings (under “Preferences” – “Emails” and “Notifications”), you can specify in which cases and to what extent you would like to be notified by email about new activities in the Forum. You can unsubscribe again at any time, either in the Forum settings or by clicking on the unsubscribe link contained in the respective notification email.
2.5 Processing of data for web analytics
a) Google Analytics
Our website uses Google Analytics, a web analytics service provided by Google Ireland Ltd. (“Google”). Google uses cookies (see Section 2.1 b), which enable an analysis of your use of our website. The information generated by the cookie about usage is usually transferred to a Google server in the USA and stored there. However, due to the activation of IP anonymisation on our website, your IP address will first be shortened by Google within the Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide us with other services relating to website and internet use.
The IP address transmitted by your browser in the context of Google Analytics will not be combined with other data held by Google.
You can prevent the storage of cookies by selecting the appropriate settings in your browser software; however, please note that if you do this you may not be able to use the full functionality of our website. You can also prevent the data generated by the cookie and relating to your use of the website (including your IP address) from being recorded and processed by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout/. Specifically in the case of mobile devices, you can prevent Google Analytics from recording data by clicking here: Disable Google Analytics. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website.
This website uses Google Analytics with the “_anonymizeIp()” extension. Consequently, IP addresses are further processed in shortened form, so that any personal association with the data subject can be ruled out. As far as the data collected about you relates to you personally, that association is therefore ruled out immediately and the personal data thus erased without delay.
We use Google Analytics to analyse and regularly improve the use of our website. The statistics this yields allow us to improve our website and make it more interesting for you as a user. We also use Google Analytics to share limited aggregated & anonymised data with Shop Owners, including for example the number of visits to their Shop over time, and the referral sources for those visits (e.g., Facebook vs Google search). For the exceptional cases in which personal data is transferred to the USA, Google LLC has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework). The legal bases for our use of Google Analytics are Art. 6(1) Sentences 1(a) and (f) GDPR.
Third-party provider information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, fax: + 353 (1) 436 1001. See also the terms of use (https://www.google.de/analytics/terms/gb.html) and privacy overview (https://support.google.com/analytics/answer/6004245?hl=en) for Google Analytics as well as Google’s privacy policy: https://policies.google.com/privacy?hl=en.
b) Adobe Analytics
To allow us to analyse and regularly improve the use of our website, our website also uses the Adobe Analytics web analytics service. The statistics this yields allow us to improve our website and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Adobe has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework). The legal bases for our use of Adobe Analytics are Art. 6(1) Sentences 1(a) and (f) GDPR.
The analysis involves storing cookies (see Section 2.1 b) on your device. The information collected in this way is stored on servers, including in the USA. We would like to point out that if you prevent the storage of cookies, you may not be able to use this website in its entirety. You can adjust your browser settings to prevent the storage of cookies. You can also prevent Adobe Analytics from recording your data on this website by clicking here: Disable Adobe Analytics. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website. How to prevent the recording of your data on other websites is explained on the respective sites and at https://www.adobe.com/privacy/opt-out.html.
Our website uses Adobe Analytics with the settings “Before Geo-Lookup: Replace visitor’s last IP octet with 0” and “Obfuscate IP-Removed”, which removes the last octet from your IP address and replaces it with a generic IP address, i.e. one that can no longer be assigned. Any personal connection can therefore be ruled out.
Third-party provider information: Adobe Systems Software Ireland Limited, 4–6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; [email protected]; Adobe’s privacy policy: https://www.adobe.com/privacy/policy.html.
c) Web analytics by Calebh’s Shop Partners
Our partners can also use the Google Analytics web analytics service (see Section 2.5 a) in their Calebh shops themselves, as a rule to analyse use of the shop and improve their offer in the shop. In this case, they determine the purposes and means of processing personal data. The name and contact details of our partners are stored in the legal information section of the respective shop.
2.6 Advertising activities by Calebh
a) Newsletter
If you register separately for our newsletter via our website and give us your consent, we will use your email address to send you regular emails about product offers, discounts and contests. To this end, we pass the data on to the software company Klaviyo Ltd, 49 Southwark Bridge Rd London SE1 9HH, UK (“Klaviyo”), which handles the technical side of the mailing on our behalf.
When you register for our newsletter, we use the so-called double opt-in procedure. This means that after you register we will send you an email to the email address you provided, in which we ask you to confirm that you would like to receive the newsletter. If you do not confirm your registration, your information will be automatically deleted after one month. On the other hand, if you confirm the newsletter subscription, we will save your email address for the purpose of sending you the newsletter until you unsubscribe from the newsletter.
You can revoke your consent to the sending of the newsletter at any time (without this affecting the lawfulness of the processing up to the point of revocation). You can declare your revocation by clicking on the link provided in every newsletter email, by emailing [email protected] or by sending a message to the contact details provided in Section 1.
When sending the newsletter, we use Klaviyo to statistically evaluate your user behaviour in order to measure how successful the newsletter is and to optimise its design. To enable this evaluation, the emails contain what are called web beacons or tracking pixels. These are single-pixel image files that establish a connection to our website und thus permit a log file analysis. The web beacons are linked with the data mentioned in Section 2.1 a and an individual ID. The links contained in the newsletter also contain this ID. For example, we can see if and when an email has been opened and which links have been clicked on. The data is stored on the Klaviyo servers for 13 months and collected pseudonymously, meaning the IDs are not linked to other personal data at this point, thus ruling out any possibility of direct personal reference. You can object to the recording of your usage behaviour at any time by clicking on the unsubscribe link provided in each email or by informing us using the contact details provided in Section 1. Recording is not possible if you have disabled the display of images in your email settings. In this case, the newsletter will not be displayed to you in full and you may not be able to use all functions. If you choose to display the images manually, recording will take place as described above.
The legal bases for the processing are Art. 6(1) Sentences 1(a) and (f) GDPR.
b) Product recommendations
As a Calebh customer, so if you order something in our online shop (see Section 2.2 a), we process the email address you provide in order to send you regular email recommendations for products that might be of interest to you based on your previous orders from us. We also use your name to allow us to personalise these emails. The data is passed on to the software company Klaviyo (see Section 2.6 a), which handles the technical side of the mailing on our behalf. The legal bases are Section 7(3) of the German Act against Unfair Competition (UWG) and Art. 6(1) Sentence 1(f) GDPR.
You receive these product recommendations because you did not object to the use of your email address for this purpose by removing the corresponding check mark during the order process. If you subsequently no longer wish to receive product recommendations or any advertising messages, you can object at any time without incurring any costs other than the transmission costs at the basic rates. Just click on the unsubscribe link included with each email, send a message using the contact details provided under Section 1 or – if you have a user account with us – adjust your newsletter settings accordingly (“Account settings” – “Newsletter subscriptions”).
When sending the product recommendations, we use Klaviyo to statistically evaluate your user behaviour in order to measure their success and to optimise their design. The legal bases for the processing are Art. 6(1) Sentences 1(a) and (f) GDPR. To enable this evaluation, the emails contain what are called web beacons or tracking pixels. These are single-pixel image files that establish a connection to our website und thus permit a log file analysis. The web beacons are linked with the data mentioned in Section 2.1 a and an individual ID. The links contained in the email also contain this ID. For example, we can see if and when an email has been opened and which links have been clicked on. The data is stored on the Klaviyo servers for 13 months and collected pseudonymously, meaning the IDs are not linked to other personal data at this point, thus ruling out any possibility of direct personal reference. You can object to the recording of your usage behaviour at any time by clicking on the unsubscribe link provided in each email, informing us via the contact options listed in Section 1, or – if you have a user account with us – changing the newsletter settings in your user account (“Account settings” – “Newsletter subscriptions”). Recording is not possible if you have disabled the display of images in your email settings. In this case, the newsletter will not be displayed to you in full and you may not be able to use all functions. If you choose to display the images manually, recording will take place as described above.
c) Newsletters and product recommendations from Calebh Shop Partners
In exceptional cases where you register separately in a Calebh shop for a Shop Partner’s newsletter and thus give your consent, we transmit your email address to the Shop Partner so that it can send you emails on product offers, discounts and contests.
You can revoke your consent to the sending of the newsletter at any time (without this affecting the lawfulness of the processing up to the point of revocation). This revocation must be declared vis-à-vis the Shop Partner. The contact details of the respective Shop Partner can be found in the legal information section of their Calebh shop.
The legal basis for the processing is Art. 6(1) Sentence 1(a) GDPR.
2.7 Usage-based online advertising
Our website uses various conversion tracking and retargeting technologies made available by other service providers. We use these technologies to make our website interesting for you. The information also helps us to address users who have already shown an interest in our products with individually tailored advertising on the websites of our partner companies. We assume that the display of personalised, interest-based advertising is generally more interesting for the internet user than advertising that has no such personal relevance. At the same time, we want to avoid inappropriate and intrusive advertising.
General information about third-party advertising-based technologies and how to disable them can be found on the following websites, among others:
Your Online Choices: http://www.youronlinechoices.eu/
YourAdChoices: http://optout.aboutads.info/?c=2#!/
Network Advertising Initiative: http://optout.networkadvertising.org/?c=1#!/
a) Use of Google AdWords conversion tracking and Google AdWords remarketing
– Google AdWords conversion tracking
We use Google AdWords, a service of Google LLC (“Google”), to use ads (so-called Google AdWords) to draw attention to our offers on external websites. In relation to the data of advertising campaigns, we can identify how successful the individual advertising activities are. In this way we want to show you advertising that is of interest to you, make our website more attractive to you and achieve a fair calculation of advertising costs.
These ads are deployed by Google via so-called ‘ad servers’. For this purpose, we use ad server cookies, which enable the tracking of certain parameters for measuring success, such as the display of ads or clicks by users. If you arrive at our website via a Google ad, Google AdWords will store a cookie on your device. These cookies usually expire after 30 days and are not intended to identify you personally. Analysis values usually stored for this cookie are the unique cookie ID, the number of ad impressions per placement (frequency), the last impression (relevant for post-view conversions) and opt-out information (marker showing that the user no longer wishes to be targeted).
These cookies allow Google to recognise your internet browser. If a user visits certain pages of an AdWords customer’s website (in this case ours) and the cookie stored on their device has not yet expired, Google and the customer can recognise that the user has clicked on the ad and has been redirected to this site. Each AdWords customer is assigned a different cookie. Cookies cannot therefore be tracked via the websites of AdWords customers. We do not collect and process any personal data in the aforementioned advertising activities. Google merely provides us with statistical evaluations. On the basis of these evaluations we can identify which of the advertising activities used are particularly effective. We do not receive any further data from the use of ads; in particular we cannot identify users on the basis of this information.
Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence on the extent and further processing of the data collected by Google through the use of this tool and therefore inform you according to what we know: By integrating AdWords Conversion, Google receives the information that you have retrieved the corresponding part of our website, or that you have clicked on one of our ads. If you are registered with a Google service, Google can associate the visit with your account. Even if you are not registered with Google or have not logged in, it is possible that Google will obtain and store your IP address.
– Google AdWords remarketing
Besides AdWords Conversion, we also use Google’s remarketing feature. This is a process we use in an attempt to contact you again. After visiting our website, this feature makes it possible to show you our ads when you continue to use the internet. This is done by means of cookies stored in your browser, which Google uses to record and evaluate your usage behaviour when visiting various websites. This is how Google can determine that you have previously visited our website. According to its own information, Google does not combine the data collected in the context of remarketing with your personal data, which may be processed by Google. Specifically, according to Google, pseudonymisation is used during remarketing.
There are various ways in which you can prevent your participation in this tracking procedure:
By setting your browser software accordingly; in particular, disabling cookies from third party providers means that you will not receive any ads from third-party providers;
By permanent deactivation in your browser Firefox, Internet Explorer or Google Chrome via the link: http://www.google.com/settings/ads/plugin. Please note that by doing this you may not be able to properly use the full functionality of our website.
By clicking on the following button: Disable Google AdWords. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website.
By disabling interest-based ads from providers who are part of the “YourAdChoices” self-regulation initiative via the link http://optout.aboutads.info/?c=2#!/; please note that this setting will be erased if you erase your cookies.
The legal bases for the processing of your data are Art. 6(1) Sentences 1(a) and (f) GDPR.
Third-party provider information: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. For further information about privacy at Google, please refer to: https://policies.google.com/privacy?hl=policies 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 subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework).
b) Use of Meta Custom Audiences, Website Custom Audiences and Conversion Tracking
– Meta Custom Audiences
Our website also uses the Website Custom Audiences remarketing function of Meta Platforms, Inc. (“Meta”). This allows users of the website to see interest-based ads (“Meta Ads”) when visiting the social network Facebook or other website (e.g., Instagram) that also use the process. Our intention here is to show you ads that are of interest to you.
Due to the marketing tools used, your browser automatically establishes a direct connection to the Facebook server. We have no influence on the extent and further processing of the data collected by Meta through the use of this tool and therefore inform you according to what we know: By integrating Custom Audiences, Meta receives the information that you have retrieved the corresponding part of our website, or that you have clicked on one of our ads. If you are registered with a Facebook service, Meta can associate the visit with your account. Even if you are not registered with Facebook or have not logged in, it is possible that Meta will obtain and store your IP address and other identifying information.
– Website Custom Audiences
Our website also uses the Meta product “Custom Audiences from your website”. For this purpose, we have integrated remarketing tags (so-called Meta Pixel or web beacon) into our website. The Meta Pixel is a small piece of JavaScript code that provides a range of functionalities for sending application-specific events and user-defined data to Meta. We use the Meta Pixel to track how visitors use our site. The Meta Pixel records and reports to Meta information about the user’s browser session, a hashed version of the Facebook ID, and the URL being viewed. Every Facebook user therefore has a device-independent Facebook ID, which enables us to recognise users across multiple devices on the social network Facebook so that we can use Meta Ads to reach our visitors again for advertising purposes. After 180 days, the user information is deleted until the user returns to our website. No personal information is transmitted to us about individual website visitors, and we can only specifically deploy ads to website custom audiences if the custom audience has reached a critical size. This makes it impossible for us to determine the individual identities of visitors.
– Conversion Tracking
We also use the Meta Pixel on our website to measure the reach of ads. This allows us to track users’ actions after they have seen or clicked on a Meta Ad. The Meta Pixel records and reports to Meta information about the user’s browser session, a hashed version of the Facebook ID, and the URL being viewed. The way it works is comparable to Meta Website Custom Audiences via the Meta Pixel, which is already described above. Using the hashed Facebook ID, we can measure the reach and effectiveness of an ad to find out whether you are actually interested in our advertising. This enables us to measure the effectiveness of Meta Ads for statistical and market research purposes. For us, the data used is not personally identifiable.
You can prevent Meta from recording your data on this website by clicking here: Disable Meta Custom Audiences, Website Custom Audiences and Conversion Tracking. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website. How to prevent the recording of your data on other websites is explained on the respective sites, and if you are a user who has logged in to Facebook, here: https://www.facebook.com/settings/?tab=ads#_.
The legal bases for the processing of data when using the functions specified above are Art. 6(1) Sentences 1(a) and (f) GDPR. You may revoke your consent anytime as described above (without this affecting the lawfulness of processing up to the point of revocation).
Third-party provider information: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, D2 Dublin, Ireland, telephone: +0016505434800, fax: + 0016505435325. For more information about data processing by Meta, please refer to Facebook’s privacy policy: https://www.facebook.com/about/privacy.
c) Use of Pinterest conversion tracking
Our website uses the Pinterest Tag, which is a conversion tracking technology from Pinterest Europe Limited (“Pinterest”).
This allows us to follow the actions you take on our website after you have clicked on one of our advertisements on the social network Pinterest, including e.g. which pages and products you consult, and whether you purchase something from our website and at what value. This is done by means of a cookie stored in your browser to record and evaluate your usage behavior. No personal information about individual website visitors is transmitted to us, only an aggregated and anonymous analysis of conversions that originate from Pinterest. Based on this information, it is impossible for us to determine your identity.
We use this information to measure the reach and effectiveness of our ads on Pinterest.
There are various ways for you to disable this tracking. You can adjust your browser settings to prevent the storage of cookies, although this may result in restricting the functionality of our website for you. You can also prevent Pinterest from recording your data on this website by clicking here: Disable Pinterest conversion tracking. This will place an opt-out cookie that will prevent the recording of activities on future visits of our website. The opt-out cookie is set via top-level domain, browser and device, and it will only prevent the recording of data for this website. In addition, you can disable interest-based ads from providers who are part of the “YourAdChoices” self-regulation initiative (http://optout.aboutads.info/?c=2#!/), or, e.g. part of the Network Advertising initiative (http://optout.networkadvertising.org/?c=1#!/). Please note that this setting will be deleted if you delete your cookies.
The legal basis for this data processing is Art. 6(1) Sentence 1(a) GDPR. You can revoke your consent to this processing at any time according to the process described above (without this affecting the lawfulness of the processing up to the point of revocation).
Third-party provider information: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland. Pinterest privacy policy:
https://policy.pinterest.com/en/ad-data-terms
https://policy.pinterest.com/en/privacy-policy
If you log in to your Pinterest account after visiting our website, or if you are logged in to a Pinterest account when you visit our website, it is then possible that Pinterest will associate the data described above with your Pinterest account and use it for Pinterest’s own advertising purposes. You can find more information in the above-mentioned Pinterest privacy policy.
d) Use of LinkedIn conversion tracking and retargeting
– LinkedIn conversion tracking
Our website uses the feature “LinkedIn conversion tracking” from LinkedIn Ireland Unlimited Company (“LinkedIn”) to measure the reach of ads. This is to determine how successful individual advertising activities are on LinkedIn. Our intention here is to develop and display advertising that is of interest to you and make our website more attractive. For this purpose, the LinkedIn Insight Tag is integrated into our website. This JavaScript code enables LinkedIn to use cookies to collect pseudonymous data about your visit and the use of our website (e.g. about the browser session and the website displayed) and to provide us with aggregated, non-personal statistics on this basis. This allows us to trace the actions that have taken place after a LinkedIn ad has been viewed or clicked on.
– LinkedIn website retargeting
Our website also uses the “LinkedIn website retargeting” feature. After visiting our website, this feature makes it possible to show you our ads when you continue to use the internet. Our intention here is to show you ads that are of interest to you. This is done by means of a cookie stored in your browser (see above for more information), which is used to record and evaluate your usage behaviour. No personal information is transmitted to us about individual website visitors, and we can only specifically deploy ads to website custom audiences if the custom audience has reached a critical size. This makes it impossible for us to determine the individual identities of visitors.
There are various ways in which you can disable this tracking. You can adjust your browser settings to prevent the storage of cookies, although this may result in a restriction of the functionality of our website for you. You also can prevent LinkedIn from recording your data on this website by clicking here: Disable LinkedIn conversion tracking and website retargeting. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website. In addition, you can disable interest-based ads from providers who are part of the “YourAdChoices” self-regulation initiative (http://optout.aboutads.info/?c=2#!/) or e.g. part of the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/); please note that this setting will be erased if you erase your cookies.
The legal bases for the processing are Art. 6(1) Sentences 1(a) and (f) GDPR.
Third-party provider information: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy?_l=en_GB.
e) Use of Bing Ads Conversion Tracking and remarketing
– Bing Ads Conversion Tracking
Our website also uses the “Bing Ads Conversion Tracking” feature from Microsoft Corporation (“Microsoft”) to measure the reach of ads. This is to determine how successful our individual advertising activities are on Bing and Yahoo. Our intention here is to develop and display advertising that is of interest to you and make our website more attractive. For this purpose, Microsoft’s UET tag (Universal Event Tracking tag) is integrated into our website. This JavaScript code enables Microsoft to use cookies to collect pseudonymous data about your visit and the use of our website (e.g. about the browser session and the website displayed) and to provide us with aggregated, non-personal statistics on this basis (e.g. how many visitors have reached a particular target page). This allows us to trace the actions that have taken place after an ad has been viewed or clicked on on Bing or Yahoo.
– Bing Ads remarketing
Our online offering also uses the “Bing Ads remarketing” feature. After visiting our website, this feature allows us to show you our ads when you continue to use the internet. Our intention here is to show you ads that are of interest to you. This is done by means of a cookie stored in your browser (see above for more information), which is used to record and evaluate your usage behaviour. No personal information is transmitted to us about individual website visitors, and we can only specifically deploy ads to website custom audiences if the custom audience has reached a critical size. This makes it impossible for us to determine the individual identities of visitors.
There are various ways in which you can disable this tracking. You can adjust your browser settings to prevent the storage of cookies, although this may result in a restriction of the functionality of our website for you. You also can prevent Microsoft from recording your data on this website by clicking here: Disable Bing Ads Conversion Tracking and Remarketing. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website. In addition, you can disable interest-based ads from providers who are part of the “YourAdChoices” self-regulation initiative (http://optout.aboutads.info/?c=2#!/) or e.g. part of the Network Advertising Initiative (http://optout.networkadvertising
.org/?c=1#!/); please note that this setting will be erased if you erase your cookies. It is also possible to disable interest-based ads at https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads.
The legal bases for the processing are Art. 6(1) Sentences 1(a) and (f) GDPR.
Third-party provider information: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Microsoft’s privacy policy: https://privacy.microsoft.com/en-us/privacystatement. Microsoft has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework).
f) Use of Twitter Ads conversion tracking
Our website also uses the “Twitter Ads conversion tracking” feature from Twitter, Inc. (“Twitter”) to measure the reach of ads. This is to determine how successful our individual tweets and advertising activities are on Twitter. Our intention here is to develop and display advertising that is of interest to you and make our website more attractive. For this purpose, a conversion tag is integrated into our website. This JavaScript code enables Twitter to use cookies to collect pseudonymous data about your visit and the use of our website (e.g. about the browser session and the website displayed) and to provide us with aggregated, non-personal statistics on this basis (e.g. how many visitors have reached a particular target page). This allows us to trace the actions that have taken place after a tweet or an ad has been viewed or clicked on.
There are various ways in which you can disable this tracking. You can adjust your browser settings to prevent the storage of cookies, although this may result in a restriction of the functionality of our website for you. You also can prevent Twitter from recording your data on this website by clicking here: Disable Twitter Ads Conversion Tracking. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website. In addition, you can disable interest-based ads from providers who are part of the “YourAdChoices” self-regulation initiative (http://optout.aboutads.info/?c=2#!/) or e.g. part of the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/); please note that this setting will be erased if you erase your cookies.
The legal bases for the processing are Art. 6(1) Sentences 1(a) and (f) GDPR.
Twitter’s privacy policy: https://twitter.com/en/privacy. Twitter has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework).
g) Use of Webgains tracking
In addition, we use a plug-in of the international affiliate network Webgains, which is provided by ad pepper media GmbH (“Webgains”). This enables us to measure the success of our ads on partner sites brokered for us by Webgains. In this way we want to show you advertising that is of interest to you, make our website more attractive to you and achieve a fair calculation of advertising costs. For this purpose, a tracking code is integrated into our site. This code enables Webgains to collect pseudonymous data about your visit and the use of our online offer via cookies and make aggregated, non-personal statistics available to us on this basis, in particular about how many visitors of a certain partner site have ordered something from us after clicking on our advertisement.
There are various ways in which you can disable this tracking. You can adjust your browser settings to prevent the storage of cookies, although this may result in a restriction of the functionality of our website for you. You also can prevent Webgains from recording your data on this website by clicking here: Disable Webgains tracking. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website. In addition, you can disable interest-based ads from providers who are part of the “YourAdChoices” self-regulation initiative (http://optout.aboutads.info/?c=2#!/) or e.g. part of the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/); please note that this setting will be erased if you erase your cookies.
The legal bases for the processing are Art. 6(1) Sentences 1(a) and (f) GDPR.
Information from the third-party provider: ad pepper media GmbH, FrankenStraße 150C, FrankenCampus, 90461 Nuremberg, Germany. Webgains privacy policy: http://www.webgains.com/public/en/privacy/.
h) Use of Nextperf retargeting
Our website also uses the feature “Nextperf Retargeting” from Nextperf. After visiting our website, this feature allows us to show you our ads when you continue to use the internet. Our intention here is to show you ads that are of interest to you. This is done by means of a cookie stored in your browser by Nextperf, which is used to pseudonymously record and evaluate your usage behaviour (e.g. which products were clicked on). No personal information is transmitted to us about individual website visitors. This makes it impossible for us to determine the individual identities of visitors.
There are various ways in which you can disable this tracking. You can adjust your browser settings to prevent the storage of cookies, although this may result in a restriction of the functionality of our website for you. You also can prevent Nextperf from recording your data on this website by clicking here: Disable Nextperf retargeting. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website. In addition, you can disable interest-based ads from providers who are part of the “YourAdChoices” self-regulation initiative (http://optout.aboutads.info/?c=2#!/) or e.g. part of the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/); please note that this setting will be erased if you erase your cookies. It is also possible to disable interest-based ads from Nextperf on other sites at http://www.nextperf.com/privacy/.
The legal bases for the processing are Art. 6(1) Sentences 1(a) and (f) GDPR.
Third-party provider information: Nextperf, 25 rue de Choiseul, 75002 Paris, France. Nextperf’s privacy policy: http://www.nextperf.com/privacy/.
i) Use of features by Calebh’s Shop Partners
Our partners can also use a Meta Pixel (see Section 2.7 b for a detailed explanation) in their Calebh shops themselves, as a rule in order to be able to show you advertising on Facebook and Instagram that is of interest to you after your visit to their shop, or in order to measure the reach of ads and in turn make their products more attractive. In this case, they determine the purposes and means of processing personal data. The name and contact details of our partners are stored in the legal information section of the respective shop.
2.8 Processing of personal data when using our mobile partner app
If you are a partner of ours, we will provide you with a mobile app (hereinafter referred to as “Calebh App”) in addition to our online service that you can use to get an overview of your partner statistics (credits, sales and bestsellers) at any time.
a) Processing of personal data when using our Calebh App
– Log-in
In order to connect your mobile device to your Calebh user account via the Calebh App, it is either necessary for you to use your smartphone camera to scan the QR code displayed or to enter your Calebh user name or e-mail address and password in the input screen provided. The legal basis for processing the data is Art. 6 Para. 1 S. 1 lit. b GDPR.
– App permissions and notifications
If you allow this on your mobile device, Calebh App has the authorization to access your camera. This enables you to connect your mobile device to your user account by scanning a QR code. If you allow this on your mobile device, you will also receive notifications from Calebh App (e.g. about new sales). You can manage these types of access at any time on your mobile device in the system settings. Calebh App can also be used without the functions. The legal basis for the processing is Art. 6 Para. 1 S. 1 lit. a GDPR.
– Display of information from the Calebh user account
The Calebh App reads out and displays the following information from your user account: Your username, the user account number, your credit balance, an overview of your sales and your bestselling products and designs. This is necessary for the implementation of the amended contract that exists with you as our partner. The legal basis for the processing is Art. 6 Para. 1 S. 1 lit. b GDPR.
– Log files
When using the Calebh App, we also process personal data mentioned below. These are technically necessary for us to enable you to use the functions of the app comfortably and to guarantee stability and security (legal bases are Art. 6 Para. 1 S. 1 lit. b and f GDPR):
IP address,
date and time of the request,
content of the request (concrete page),
page from which the request comes,
access status/HTTP status code,
the amount of data transferred in each case,
browser,
language and version of the browser software,
operating system and its interface,
device identification,
type and name of your mobile device,
screen size and resolution,
country and city,
version of the app,
number of your Calebh user account.
b) Processing of data for app analysis
In addition to processing the aforementioned data, a technology comparable to cookies is used for your use of Calebh App. By the use of JavaScript code, counting impulses are transmitted to counting servers of the service providers listed below. This information enables us to analyse how you use our Calebh App. You can prevent this usage information from being collected by deactivating the “I’m in” button when you install the Calebh App or by deactivating the “App analysis” button in the “Settings” section of your Calebh App later on.
– Google Analytics
The Calebh App uses Google Analytics, an analysis service of Google Ireland Ltd. (“Google”). The information generated by the JavaScript code about your usage is usually transmitted to a Google server in the USA and stored there for 26 months. Due to the activation of IP anonymisation in the Calebh App, your IP address will be shortened beforehand by Google within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and truncated there. On our behalf, Google will use this information to evaluate how you use the Calebh App in order to compile reports on app activity and to provide us with other services relating to the app use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other data from Google. Calebh App uses Google Analytics with the extension “_anonymizeIp()”. This means that IP addresses are shortened for further processing, so that it is not possible to identify individuals. If the data collected about you is related to your person, it is excluded immediately, and the personal data is deleted immediately. We use Google Analytics to analyse and improve the use of Calebh App on a regular basis. The statistics obtained enable us to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google LLC has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework). The legal basis for the use of Google Analytics is Art. 6 Para. 1 S. 1 lit. f GDPR.
Third-party information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: + 353 (1) 436 1001. See also the terms of use (https://marketingplatform.google.com/about/analytics/terms/us/) and privacy policy overview (https://support.google.com/analytics/answer/6004245?hl=en) for Google Analytics and Google’s privacy policy: https://policies.google.com/privacy?hl=en.
– Adobe Analytics
Our Calebh App also uses the Adobe Analytics analysis service to analyse and regularly improve the use of Calebh App. The statistics obtained enable us to improve our offer and make it more interesting for you as a user. For the exceptional cases where personal information is transferred to the USA, Adobe has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework). The legal basis for the use of Adobe Analytics is Art. 6 Para. 1 S. 1 lit. f GDPR. Our website uses Adobe Analytics with the settings “Before Geo-Lookup: Replace visitor’s last IP octet with 0” and “Obfuscate IP-Removed”, which removes the last octet from your IP address and replaces it with a generic IP address, i.e. one that can no longer be assigned. Any personal connection can therefore be ruled out. The usage information is stored for 25 months.
Third-party information: Adobe Systems Software Ireland Limited, 4–6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; [email protected]; Adobe’s privacy policy: https://www.adobe.com/privacy/policy.html.
– Sentry
Calebh App also uses the “Sentry” service of the provider Functional Software, Inc. The service detects and documents errors and performance problems that may occur during your use of Calebh App. We use the service to improve the technical stability of Calebh App by monitoring system stability and detecting code errors. The data (e.g. information about the device or time of error) is collected anonymously, is not used for personal purposes and stored for 90 days. The legal basis for the processing is Art. 6 Para. 1 S. 1 lit. f GDPR.
Third-party information: Functional Software, Inc., 132 Hawthorne Street, San Francisco, CA 94107, USA. Functional Software, Inc. has subjected itself to the EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework). For more information about this third party’s privacy practices, please refer to Functional Software, Inc.’s Privacy Statement: https://sentry.io/privacy/.
3. What are my rights?
If you have given your consent to the processing of your data, you can revoke this consent with future effect at any time. This does not affect the lawfulness of processing carried out on the basis of the consent before you revoke your consent.
If we base the processing of your personal data on our legitimate interests, you are entitled to object to the processing. This is the case if the processing is not necessary in particular for the performance of a contract with you, which was described by us in each case with the description of the individual functions. When exercising such a right of objection, we ask that you explain the reasons why we should not process your personal data as carried out by us. In the event that your objection is justified, we will examine the situation and either stop or adjust the data processing or point out to you the compelling legitimate reasons on the basis of which we will continue processing.
However, you can of course object to the processing of your personal data for advertising or web analytics purposes at any time without giving reasons.
As described in the relevant sections, we sometimes use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are regularly checked.
The personal data processed by us is generally erased or blocked as soon as the purpose of storage ceases to apply. Data may be stored for a longer period if this has been provided for by laws or other rules to which we as the controller are subject. The data will also be blocked or erased once a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.
Further processing operations may be required for contests and other promotional campaigns. In such cases we will inform you in the context of the respective promotional campaign.
4. We Will Share Your Information with Third Parties in Specific Circumstances
a) Legal Compliance and Safety
We will share your information with third parties in specific circumstances. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a similar event, we may transfer your information as part of that transaction. In addition, there are a few times when we must share your information either to protect our rights, to further our legitimate interests, or to comply with a legal obligation to which we are subject. We will share your personal information when we believe in good faith that:
a subpoena or warrant is duly issued, or we receive any other legitimate government agency request to produce information;
we need to share the information in order to enforce or protect our own rights, for example, to respond to and resolve third-party claims or complaints, or with respect to contracts with our users and third parties;
we need to address a security or technical issue within our website;
sharing the information is necessary to prevent harm to others or others’ property, especially in an emergency situation;
b) Corporate Change in Control Events
If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a similar event, we may transfer your information as part of that transaction.
5. Is My Information Secure?
We use reasonable measures to secure our website and any private information you submit to us against loss, tampering, unauthorized access, and other malicious acts. For example, we use SSL connections when possible to protect your data while it is in transit (for example login data and customer orders). However, no data transmission over the Internet is completely secure, so we cannot completely guarantee the security of any data. You use our services at your own risk, and are responsible for taking reasonable measures to secure your password, information, and account.
6. Do-Not-Track (“DNT”) Requests
Due to lack of technical standards across browsers, we do not respond to DNT signals.
7. Consumer privacy act (“CCPA”) – for California residents
This Section 7 applies only to users of our Marketplace who are California residents. As used in this Section, “Personal Information” in this Section 7 means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).
a. CCPA DISCLOSURE
The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding twelve (12) months since this California Resident Privacy Notice was last updated, as well as the categories of sources from which that Personal Information was collected, and the categories of third parties with whom we shared Personal Information. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.
| Category | We Collect | We Disclose | We Sell | Categories of Third Parties with Whom We Share Personal Information |
| A. IdentifiersExamples: Name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. | Yes | Yes | No | All |
| B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)Examples: Name, signature, social security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | Yes | Yes | No | All |
| C. Characteristics of Protected Classifications under California or Federal LawExamples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military, and veteran status. | No | N/A | N/A | N/A |
| D. Commercial InformationExamples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes | Yes | No | All |
| E. Biometric InformationExamples: Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. | No | N/A | N/A | N/A |
| F. Internet or Other Electronic Network Activity InformationExamples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. | Yes | Yes | No | All |
| G. Geolocation DataExamples: Precise physical location. | No | N/A | N/A | N/A |
| H. Sensory InformationExamples: Audio, electronic, visual, thermal, olfactory, or similar information. | No | N/A | N/A | N/A |
| I. Professional or employment-related informationExamples: Job application or resume information and past and current job history. | Yes | Yes | No | All |
| J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)Examples: Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution. | No | N/A | N/A | N/A |
| K. Inferences Drawn from Personal InformationExamples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | No | N/A | N/A | N/A |
b. USE OF PERSONAL INFORMATION
We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes as described in Sections 3-5 of this Policy.
c. COLLECTION OF PERSONAL INFORMATION
In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:
You/Your Devices: You or your devices directly.
Users: Other users of our services.
Affiliates.
Analytics Providers.
OS/Platform Provider: Operating systems and platforms.
Social Networks.
Partners: Business partners.
d. DISCLOSURE OF PERSONAL INFORMATION
As set forth in Section 5 of this Policy, we share your Personal Information with the following categories of third parties:
Affiliates.
Analytics Providers.
Vendors: Vendors and service providers.
Integrated Third Parties: Third parties integrated into our Services.
Third Parties as Legally Required: Third parties as required by law and similar disclosures.
Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.
e. RIGHT TO KNOW AND ACCESS
You may submit a verifiable request for information regarding the: (i) categories of Personal Information collected, sold, or disclosed by us; (ii) purposes for which categories of Personal Information are collected or sold by us; (iii) categories of sources from which we collect Personal Information; (iv) categories of third parties with whom we disclosed or sold Personal Information; and (v) specific pieces of Personal Information we have collected about you during the past twelve months.
f. RIGHT TO DELETE
Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
g. VERIFICATION
Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, we may request that you provide us with personal information that matches the identifying information that you have already provided to us.
h. AUTHORIZING AN AGENT
To authorize an agent to make a request to know or delete on your behalf, please email us at [email protected]
i. SUBMIT REQUESTS
To exercise your rights under the CCPA, please contact our team here.
k. RIGHT TO EQUAL SERVICE AND PRICE
You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations. Calebh may offer certain financial incentives to the extent permitted by the CCPA that result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive that is offered will reasonably relate to California consumers’ personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program would require prior opt in consent, which may be revoked at any time.
l. SHINE THE LIGHT
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California consumers to request certain information regarding Calebh’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].
8. Children’s Online Privacy Protection
Our website is not intended or directed at individuals under the age of 13. We do not knowingly collect or keep any information of children under the age of 13. If we discover it, we will delete it as soon as possible.
Thank you for reading this privacy policy in its entirety.