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Privacy Policy

1. Controller

Controller within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws, as well as other data-protection-related provisions, is:

SicherShopping Limited
Chai Wan Kok Street 66, Room 1911A, Unit F, 19/F, Golden Bear Centre, New Territories
00000 Hongkong
Germany
Email: sichershopping@gmail.com
Phone: +85296820432

2. Overview of Processing

The following overview summarizes the categories of data processed and the purposes of their processing, and refers to the affected persons:

  • Basic data (e.g. names, addresses)
  • Contact data (e.g. email, phone numbers)
  • Content data (e.g. entries in contact forms)
  • Contract data (e.g. subject matter, term, customer category)
  • Payment data (e.g. bank details, payment history)
  • Usage data (e.g. websites visited, access times)
  • Meta/communication data (e.g. IP addresses, device information)

3. Legal Bases for Processing

Below is an overview of the GDPR legal bases on which we process personal data:

  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR): Processing is necessary for the performance of a contract or to carry out pre-contractual measures.
  • Consent (Art. 6(1)(a) GDPR): The affected person has given their consent to the processing.
  • Legal obligation (Art. 6(1)(c) GDPR): Processing is necessary to comply with a legal obligation (e.g. statutory retention requirements under tax law).
  • Legitimate interests (Art. 6(1)(f) GDPR): Processing is necessary to safeguard a legitimate interest of the controller or a third party, provided this is not overridden by the interests or fundamental rights of the affected person.

4. Security Measures

In accordance with statutory requirements, and taking into account the state of the art, the cost of implementation, and the nature, scope, context and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transmission of, and availability and segregation of the data. Data transmitted between your browser and our server is encrypted via HTTPS/TLS.

5. Server Log Files

The provider of these pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

  • Browser type and version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address

This data is not merged with other data sources. The legal basis is Art. 6(1)(f) GDPR. The data is deleted after 30 days at the latest, unless further retention is required for evidentiary purposes.

6. Cookies and Consent Management

We use cookies. Cookies are small text files stored by your browser. Some cookies are "technically necessary" (e.g. shopping cart, session), while others serve analytics or personalization purposes.

Technically necessary cookies are set on the basis of Art. 6(1)(f) GDPR, as we have a legitimate interest in the technically flawless presentation of our website. All other cookies are set only with your explicit consent (Art. 6(1)(a) GDPR).

You can configure your browser so that you are notified when cookies are set and allow cookies only in individual cases, exclude the acceptance of cookies for specific cases or in general, and activate automatic deletion of cookies when you close your browser.

7. Order Process and Contract Data

When placing an order in our online shop, we collect the following personal data, which is necessary for performance of the contract:

  • First and last name
  • Delivery address and, where applicable, a differing billing address
  • Email address
  • Phone number (optional, for delivery inquiries)
  • Payment information
  • Products ordered and order history

Processing takes place on the basis of Art. 6(1)(b) GDPR for performance of the purchase agreement. The data is deleted once the statutory retention periods under tax and commercial law (generally 6 or 10 years) have expired, unless other grounds for further retention exist.

8. Customer Account

You can create a customer account in which we store your data for future orders. During registration, your email address and a password are collected. Use of the customer account is voluntary.

Processing takes place on the basis of your consent (Art. 6(1)(a) GDPR). You may have your customer account deleted at any time. Data stored in the customer account is removed when the account is deleted, unless statutory retention obligations prevent this.

9. Contact Form and Email Contact

If you contact us via the contact form or by email, the information you provide (name, email address, message) is stored by us in order to process your inquiry. Processing takes place on the basis of Art. 6(1)(b) GDPR (pre-contractual measures) or Art. 6(1)(f) GDPR (legitimate interest in responding to inquiries). The data is deleted once your inquiry has been fully processed and no statutory retention obligations apply.

10. Payment Service Providers

To process payments, we use external payment service providers:

Stripe
Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Dublin 2, Ireland.
Privacy policy: https://stripe.com/de/privacy

PayPal
PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg.
Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full

Your payment data is transmitted to the respective payment service provider on the basis of Art. 6(1)(b) GDPR (performance of a contract) and in the interest of a secure, convenient payment process (Art. 6(1)(f) GDPR). Your credit card data is never stored on our servers.

11. Shipping Service Providers

To deliver your order, we pass your name and delivery address to the shipping service provider we have commissioned. Processing takes place on the basis of Art. 6(1)(b) GDPR (performance of a contract). We work with the following shipping service providers: DHL, DPD, Hermes, and, where applicable, further print-on-demand fulfillment partners.

12. Newsletter

When you subscribe to our newsletter, we process your email address on the basis of your consent (Art. 6(1)(a) GDPR). Depending on the shop's settings, after you sign up we first send you a confirmation email (double opt-in procedure); in that case you only receive marketing emails from us once you have confirmed your signup in that email. Otherwise your signup is confirmed immediately. To be able to prove your consent, we store the time of your signup and of your confirmation, as well as your IP address and your browser identifier (user agent) at the time of signup.

Our marketing emails (newsletters and automated emails, e.g. reminders about items left in your shopping cart or welcome series) contain a tracking pixel (a small, invisible image) and links that are routed via the domain of our shop. We record whether and when an email was opened and which link was clicked, and we link this information to your email address. No such evaluation takes place in transactional emails (e.g. order confirmation, shipping notification, invoice). We use this information to:

  • create statistics about our emails (e.g. open and click rates),
  • send future emails at the time of day at which you usually read emails (best send time),
  • determine whether an order was placed within 7 days after a link in one of our emails was clicked.

For newsletter subscribers, the legal basis is your consent (Art. 6(1)(a) GDPR) and, insofar as the tracking pixel accesses or reads information on your device, Section 25(1) of the German Telecommunications Digital Services Data Protection Act (§ 25 Abs. 1 TDDDG). You may withdraw your consent at any time with effect for the future by using the unsubscribe link in every marketing email or by sending us an email. After you unsubscribe we no longer send you marketing emails, and the open and click data is anonymized, i.e. it is no longer linked to your email address. The lawfulness of the processing carried out before the withdrawal remains unaffected. Please note: if your email program blocks the loading of images, the tracking pixel cannot be loaded and an opening is not recorded.

Existing customers: if you leave the option “Receive news and offers by email” ticked when you place an order, we use the email address from your order to send you advertising for our own similar products (Section 7(3) of the German Unfair Competition Act, § 7 Abs. 3 UWG, and Art. 6(1)(f) GDPR). The legal basis for evaluating these emails (tracking pixel and links, see above) is also our legitimate interest in direct marketing and in measuring its success (Art. 6(1)(f) GDPR). You may object to the use of your email address for advertising at any time, at checkout by unticking the box or later via the unsubscribe link in every email or by emailing us, at no cost other than the transmission costs at basic rates.

Storage period: we store your newsletter data until you withdraw your consent. After that we keep your email address and the proof of consent and unsubscription for as long as we need it to honor your unsubscription and to defend ourselves against claims (Art. 6(1)(f) GDPR). We delete open and click data after 24 months at the latest.

13. Hosting

This website is hosted by an external service provider (hosting provider). The personal data collected on this website is stored on the hosting provider's servers. This may include IP addresses, contact inquiries, meta and communication data, contract data, contact details, names, website visits and other data. The hosting provider is used on the basis of Art. 6(1)(f) GDPR (legitimate interest in a reliable presentation of our website).

14. Advertising and Remarketing

a) Meta Pixel (Facebook/Instagram)

We use the Meta Pixel of Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, on our website. The Meta Pixel allows us to track the behavior of users after they have been redirected to our website by clicking on a Facebook or Instagram advertisement. This allows us to measure the effectiveness of advertisements and to display targeted advertising on Facebook and Instagram (so-called remarketing/retargeting).

The data collected is anonymous to us, meaning we do not see personal data of individual users. However, this data is stored and processed by Meta. Meta may link this data with your Facebook/Instagram account and use it for its own advertising purposes. The legal basis is your consent (Art. 6(1)(a) GDPR). Meta's privacy policy: https://www.facebook.com/privacy/policy/.

b) Pinterest Tag

We use the Pinterest Tag of Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland. The Pinterest Tag allows us to measure the effectiveness of our Pinterest advertisements and to show users relevant content on Pinterest based on their behavior on our website.

In doing so, information such as page views, shopping cart activity and completed purchases is transmitted to Pinterest. The legal basis is your consent (Art. 6(1)(a) GDPR). Pinterest's privacy policy: https://policy.pinterest.com/de/privacy-policy.

c) Google Ads and Google Conversion Tracking

We use Google Ads to draw attention to our offerings using advertising material on external websites. Google Ads sets a cookie for so-called conversion tracking. This cookie is set when a user clicks on an advertisement placed by Google. This allows Google and us to recognize that someone clicked on an advertisement and was redirected to our page.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The legal basis is your consent (Art. 6(1)(a) GDPR). Privacy policy: https://policies.google.com/privacy.

15. Analytics Tools

If we use analytics tools, this is done exclusively with your consent (Art. 6(1)(a) GDPR). We will inform you separately, where applicable, about the use of specific analytics tools in our cookie consent banner.

16. Email Communication

a) Transactional Emails

We send transactional emails related to your purchase, e.g. order confirmations, shipping notifications, invoices and notifications about your customer account. These emails are necessary for performance of the contract and are sent on the basis of Art. 6(1)(b) GDPR.

b) Marketing Emails

With your explicit consent (Art. 6(1)(a) GDPR), we send you marketing emails, e.g. about new products, offers and promotions, including automated emails (such as reminders about items left in your shopping cart). These emails contain a tracking pixel and links routed via our shop with which we record opens and clicks; details, purposes, withdrawal and storage period are described in section 12 (Newsletter). You may withdraw your consent at any time by using the unsubscribe link at the end of every marketing email. If you leave the option “Receive news and offers by email” ticked when you place an order, we send you, as an existing customer, advertising for our own similar products on the basis of Section 7(3) UWG and Art. 6(1)(f) GDPR (see section 12); you may object at any time.

c) Email Delivery Service Provider

For sending emails, we use the service Resend (Resend, Inc., 2261 Market Street #4381, San Francisco, CA 94114, USA). Resend processes email addresses and email content on our behalf. A data processing agreement (DPA) is in place. Data transfers to the USA take place on the basis of the EU Commission's standard contractual clauses. Privacy policy: https://resend.com/legal/privacy-policy.

17. Social Media

We maintain online presences within social networks (Facebook, Instagram, Pinterest, TikTok) in order to communicate with customers and prospects there and to provide information about our products. The terms of service and data processing policies of the respective operators apply when accessing those networks.

Unless stated otherwise in this Privacy Policy, we process the data of users who communicate with us within social networks. The legal basis is our legitimate interest in effectively informing and communicating with users (Art. 6(1)(f) GDPR).

18. Your Rights as a Data Subject

Subject to the requirements of the GDPR, you have the following rights:

  • Right of access (Art. 15 GDPR): You have the right to obtain confirmation as to whether personal data concerning you is being processed. If so, you have a right of access to that data as well as to further information pursuant to Art. 15 GDPR.
  • Right to rectification (Art. 16 GDPR): You have the right to request the correction of inaccurate data concerning you and the completion of incomplete data.
  • Right to erasure (Art. 17 GDPR): You have the right to request erasure of your personal data, provided the statutory requirements are met.
  • Right to restriction of processing (Art. 18 GDPR): You have the right to request restriction of the processing of your data if certain requirements are met.
  • Right to data portability (Art. 20 GDPR): You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format.
  • Right to object (Art. 21 GDPR): For reasons arising from your particular situation, you have the right to object at any time to the processing of personal data concerning you that is carried out on the basis of Art. 6(1)(f) GDPR. Where personal data is processed for direct marketing purposes, you have the right to object at any time to such processing.
  • Right to withdraw consent (Art. 7(3) GDPR): You have the right to withdraw any consent given, at any time. The lawfulness of processing carried out on the basis of consent prior to its withdrawal remains unaffected.

19. Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of personal data concerning you infringes the GDPR. The supervisory authority responsible for us is determined by the federal state (Bundesland) of our registered place of business. A list of data protection authorities and their contact details can be found at: https://www.bfdi.bund.de.

20. Data Transfers to Third Countries

If we process data in a third country (i.e. outside the European Union or the European Economic Area) or if this occurs in connection with the use of third-party services, this takes place only if it is necessary to fulfill our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation, or on the basis of our legitimate interests. Subject to statutory or contractual permissions, we process data in a third country only where an adequate level of data protection exists (e.g. an EU adequacy decision, standard contractual clauses).

21. Retention Period

We store personal data only for as long as is necessary for the respective processing purposes or as required by statutory retention obligations. Once the purpose has been fulfilled or the relevant periods have expired, the data is routinely deleted. In detail:

  • Contract data and invoices: 10 years (Section 147 AO (German Fiscal Code), Section 257 HGB (German Commercial Code))
  • Business correspondence: 6 years (Section 257 HGB)
  • Server log files: max. 30 days
  • Customer account data: until the account is deleted by the customer
  • Newsletter data: until consent is withdrawn, afterwards only the proof of consent and unsubscription for as long as we need it; open and click data: 24 months at most

22. Currency and Amendment of this Privacy Policy

This Privacy Policy is currently valid. As we further develop our website and offerings, or due to changed statutory or regulatory requirements, it may become necessary to amend this Privacy Policy. The current Privacy Policy can be accessed on this page at any time.