Data Protection

1) Introduction and Contact Details of the Person Responsible

1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, we will inform you about how we handle your personal data when you use our website. Personal data is all data with which you can be personally identified.

1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Lukas Günther Teissl, 27 Old Gloucester Street, WC1N 3AX London, United Kingdom, Business WhatsApp: +44 7858 827067, Email: info@high-level-closer.de. The controller of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2) Data Collection when Visiting our Website

2.1 If you only use our website for informational purposes, i.e. if you do not register or otherwise provide us with information, we only collect the data that your browser transmits to the site server (so-called "server log files"). When you visit our website, we collect the following data, which is technically necessary for us to display the website to you:

• Our visited website
• Date and time at the time of access
• Amount of data sent in bytes
• Source/reference from which you reached the page
• Browser used
• Operating system used
• IP address used (if applicable: in anonymized form)

The processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not passed on or used in any other way. However, we reserve the right to check the server log files retrospectively if there are concrete indications of unlawful use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string "https://" and the lock symbol in your browser line.

3) Cookies

In order to make visiting our website attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. Some of these cookies are automatically deleted after you close your browser (so-called "session cookies"), while others remain on your device for longer and enable page settings to be saved (so-called "persistent cookies"). In the latter case, you can find the storage period in the cookie settings overview of your web browser.

If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b GDPR either for the execution of the contract, in accordance with Art. 6 para. 1 lit. a GDPR in the case of consent given or in accordance with Art. 6 para. 1 lit. f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.

You can set your browser so that you are informed about the setting of cookies and can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

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

4) Contact us

4.1 WhatsApp-Business

We offer visitors to our website the opportunity to contact us via the WhatsApp messaging service provided by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. We use the so-called "business version" of WhatsApp for this purpose.

If you contact us via WhatsApp on the occasion of a specific transaction (e.g. an order placed), we will store and use the mobile phone number you use on WhatsApp and - if provided - your first and last name in accordance with Art. 6 para. 1 lit. b. GDPR to process your request. GDPR to process and respond to your request. On the same legal basis, we may ask you to provide further data (order number, customer number, address or e-mail address) via WhatsApp in order to be able to assign your request to a specific process.

If you use our WhatsApp contact for general inquiries (e.g. about the range of services, availability or our website), we store and use the mobile phone number you use on WhatsApp and - if provided - your first and last name in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in the efficient and timely provision of the requested information.

Your data will only ever be used to respond to your request via WhatsApp. Your data will not be passed on to third parties.

Please note that WhatsApp Business receives access to the address book of the mobile device we use for this purpose and automatically transfers telephone numbers stored in the address book to a server of the parent company Meta Platforms Inc. in the USA. To operate our WhatsApp Business account, we use a mobile device whose address book only stores the WhatsApp contact data of those users who have also contacted us via WhatsApp.

This ensures that every person whose WhatsApp contact details are stored in our address book has already consented to the transmission of their WhatsApp telephone number from the address books of their chat contacts in accordance with Art. 6 para. 1 lit. a GDPR when using the app on their device for the first time by accepting the WhatsApp terms of use. The transmission of data of such users who do not use WhatsApp and/or have not contacted us via WhatsApp is excluded in this respect.

The purpose and scope of the data collection and the further processing and use of the data by WhatsApp as well as your rights in this regard and setting options to protect your privacy can be found in WhatsApp's data protection information: https://www.whatsapp.com/legal/?eea=1#privacy-policy

4.2 When you contact us (e.g. via contact form or e-mail), personal data is processed exclusively for the purpose of processing and responding to your request and only to the extent necessary for this purpose.

The legal basis for the processing of this data is our legitimate interest in responding to your request in accordance with Art. 6 para. 1 lit. f GDPR. If your contact is aimed at a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR. Your data will be deleted if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

5) Use of customer data for direct marketing

5.1 Subscribe to our e-mail newsletter

If you subscribe to our e-mail newsletter, we will send you regular information about our offers. The only mandatory information for sending the newsletter is your e-mail address. The provision of further data is voluntary and is used to address you personally. We use the so-called double opt-in procedure for sending the newsletter, which ensures that you only receive newsletters if you have expressly confirmed your consent to receive the newsletter by clicking on a verification link sent to the email address provided.

By activating the confirmation link, you give us your consent to use your personal data in accordance with Art. 6 para. 1 lit. a GDPR. We store your IP address entered by the Internet service provider (ISP) as well as the date and time of registration in order to be able to trace any possible misuse of your e-mail address at a later date. The data we collect when you register for the newsletter is used strictly for the intended purpose.

You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a message to the controller named at the beginning. Once you have unsubscribed, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this declaration.

5.2 CleverPush

On this website you have the option of registering for regular push notifications with information about our offer.

For this purpose, we use the services of the following provider: CleverPush UG (haftungsbeschränkt), Tondernstr. 1, 22049 Hamburg, Germany

In the course of registration, with which you give your express consent to receive push notifications and related processing in accordance with Art. 6 para. 1 lit a GDPR, your browser ID and end device ID are collected, stored and used by the provider for the correct assignment and display of the notifications.

Subject to your express consent in accordance with Art. 6 para. 1 lit. a GDPR, the provider also carries out a statistical evaluation of push integrations and interactions, whereby further information (e.g. time of access, IP address) is collected and evaluated, but not merged with other data sets.

You can revoke your consent to data processing for receiving push notifications and for statistical performance measurement at any time with effect for the future by deactivating the service in your browser settings or - depending on the operating system - by interacting with the respective push message to unsubscribe from receiving it.

We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

5.3 Signalize

On this website you have the option of registering for regular push notifications with information about our offer.

For this purpose, we use the services of the following provider: etracker GmbH, Erste Brunnenstraße 1, 20459 Hamburg, Germany

In the course of registration, with which you give your express consent to receive push notifications and related processing in accordance with Art. 6 para. 1 lit a GDPR, your browser ID and end device ID are collected, stored and used by the provider for the correct assignment and display of the notifications.

Subject to your express consent in accordance with Art. 6 para. 1 lit. a GDPR, the provider also carries out a statistical evaluation of push integrations and interactions, whereby further information (e.g. time of access, IP address) is collected and evaluated, but not merged with other data sets.

You can revoke your consent to data processing for receiving push notifications and for statistical performance measurement at any time with effect for the future by deactivating the service in your browser settings or - depending on the operating system - by interacting with the respective push message to unsubscribe from receiving it.

We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

6) Data processing for order processing

Insofar as necessary for contract processing for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 para. 1 lit. b GDPR.

If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we process the contact data (name, address, e-mail address) provided by you when ordering in order to inform you personally by suitable means of communication (e.g. by post or e-mail) about upcoming updates within the legally prescribed period within the scope of our statutory information obligations pursuant to Art. 6 para. 1 lit. c GDPR. Your contact details will be used strictly for the purpose of notifying you of updates owed by us and will only be processed by us for this purpose to the extent necessary for the respective information.

To process your order, we also work together with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information.

7) Retargeting/ Remarketing and Conversion-Tracking

Facebook pixel for the creation of custom audiences

Within our online offering, we use the "Facebook Pixel" service of the following provider: Meta Platforms Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland ("Facebook")

If a user clicks on an advertisement placed by us on Facebook, a parameter is added to the URL of our linked page with the help of "Facebook Pixel". This URL parameter is then entered in the user's browser after redirection by a cookie that our linked page sets itself.

On the one hand, this enables Facebook to determine the visitors to our online offering as a target group for the display of ads (so-called "Facebook ads"). Accordingly, we use the service to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Facebook (so-called "custom audiences").

On the other hand, "Facebook Pixel" can be used to track whether users have been redirected to our website after clicking on a Facebook ad and what actions they take there (so-called "conversion tracking").

The data collected is anonymous for us, so it does not allow us to draw any conclusions about the identity of the user. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes.

All processing described above, in particular the setting of cookies for reading information on the terminal device used, will only be carried out if you have given us your express consent to do so in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the "cookie consent tool" provided on the website.

We have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

The information generated by Facebook is usually transmitted to a Facebook server and stored there; in this context, it may also be transmitted to Meta Platforms Inc. servers in the USA.

For the transfer of data to the USA, the provider refers to standard contractual clauses of the European Commission, which are intended to ensure compliance with the European level of data protection.

8) Page Functionalities

Google Customer Reviews (formerly Google Certified Merchant Program)

We work with Google as part of the "Google Customer Reviews" program. The provider is Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). This program gives us the opportunity to obtain customer reviews from users of our website. After making a purchase on our website, you will be asked whether you would like to take part in an e-mail survey from Google.

If you give your consent in accordance with Art. 6 para. 1 lit. a GDPR, we will transmit your e-mail address to Google. You will receive an email from Google Customer Reviews asking you to rate the buying experience on our website. The review you provide will then be aggregated with our other reviews and displayed in our Google Customer Reviews logo and in our Merchant Center dashboard. Your review will also be used for Google seller reviews. As part of the use of Google Customer Reviews, personal data may also be transmitted to the servers of Google LLC. in the USA.

You can withdraw your consent at any time by sending a message to the data controller or to Google.

9) Tools and Other

Cookie Consent Tool

This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users when they access the website in the form of an interactive user interface, on which consent for certain cookies and/or cookie-based applications can be given by ticking a box. By using the tool, all cookies/services requiring consent are only loaded if the respective user gives their consent by ticking the appropriate box. This ensures that such cookies are only set on the user's end device if consent has been granted.

The tool sets technically necessary cookies to save your cookie preferences. Personal user data is not processed in this process.

If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.

Another legal basis for the processing is Art. 6 para. 1 lit. c GDPR. As the controller, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.

Where necessary, we have concluded an order processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

Further information about the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.

10) Rights of the Data Subject

10.1 The applicable data protection law grants you the following data subject rights (information and intervention rights) vis-à-vis the controller with regard to the processing of your personal data, whereby reference is made to the legal basis stated for the respective exercise requirements:

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

10.2 RIGHT OF OBJECTION

IF WE PROCESS YOUR PERSONAL DATA AS PART OF A BALANCING OF INTERESTS ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME WITH EFFECT FOR THE FUTURE ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION.

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

IF YOUR PERSONAL DATA ARE PROCESSED BY US FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING. YOU CAN EXERCISE YOUR OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

11) Duration of storage of personal data

The duration of the storage of personal data is determined by the respective legal basis, the purpose of processing and - if relevant - additionally by the respective statutory retention period (e.g. retention periods under commercial and tax law).

When processing personal data on the basis of express consent in accordance with Art. 6 para. 1 lit. a GDPR, the data concerned will be stored until you withdraw your consent.

If there are statutory retention periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 para. 1 lit. b GDPR, this data will be routinely deleted after the retention periods have expired, provided that it is no longer required for contract fulfillment or contract initiation and/or we no longer have a legitimate interest in further storage.

When processing personal data on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object in accordance with Art. 21 para. 1 GDPR, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.

When processing personal data for the purpose of direct marketing on the basis of Art. 6 para. 1 lit. f GDPR, this data is stored until you exercise your right to object in accordance with Art. 21 para. 2 GDPR.

Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data is deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.

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