We are delighted by your interest in our webshop (zazzowear.com) (hereinafter referred to as “webshop” or “website”).

This privacy policy aims to provide you with a clear overview of how we process your personal data.

1. WHO IS RESPONSIBLE FOR PROCESSING MY DATA AND WHO IS THE DATA PROTECTION OFFICER?

The controller for data processing within the meaning of Article 4 No. 7 of the General Data Protection Regulation (GDPR) is:

SMART DG LTD
Company Number: 15510565

E-Mail: support@zazzowear.com

Managing Director: Nikolay Rachev

86-90 Paul Street, London, Greater London, England, EC2A 4NE

2. WHAT IS THE SUBJECT OF DATA PROTECTION?

Data protection law regulates the handling of personal data. Personal data refers to information relating to an identified or identifiable natural person (hereinafter referred to as “data”).

3. WHAT DATA CATEGORIES DO WE PROCESS AND WHERE DO THEY COME FROM?

Through your use of our webshop, we process the following categories of data in particular:

Data you provide to us: In the context of your order, when contacting us (e.g., via contact form or email), or when opening a customer account, you provide us with data. The specific data you provide to us is apparent from the respective input forms. For example, this may include your name, email address, phone number, other contact details including your address, or payment data.

You can see from the respective input form whether you are obliged to provide us with the corresponding data. Further information on this can also be found under section 4 of this privacy policy.

When you visit our website, we may also store access data in so-called server log files.

Data we collect from third parties: When you place an order in our webshop, we may also collect data about you from third parties, such as credit agencies and payment service providers.

Cookies: To make your visit to our website attractive and to enable the use of certain functions, we use so-called cookies or similar technologies on our website, including for advertising and analysis purposes. Further information on this can be found under section 4 below and in our cookie settings. You can change your cookie preferences there at any time.

Special categories of personal data: We do not collect or process any special categories of personal data.1

4. FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS ARE MY DATA PROCESSED?

We process your data for the purposes stated below. In general, you are neither legally nor for any other reason obliged to provide us with your data for these purposes. However, without your data, we may not be able to offer you our website and our services.

Contract-related processing purposes on the legal basis of Art. 6(1) sentence 1 lit. b) GDPR

Opening a customer account: In order to open a customer account, you must first register with us. In the course of this registration, we process certain data from you, such as your name and email address. The exact data we collect is apparent from the respective input form. We collect this data in order to establish a customer account for you.

Data collection and use for contract processing: We collect and process data when you provide it to us as part of your order. The data collected is apparent from the respective input forms. We use the data you provide to fulfill our contractual obligations to you and to process your inquiries, particularly for processing your order, completing your payment, and for contract-related communication with you, such as responding to questions and complaints. Your data is required for contract performance, especially to process your order. The input forms indicate which information is required for this purpose and which additional information you may optionally provide.

Data processing based on consent under Article 6(1)(a) of the GDPR

Use of your data for advertising and analytical purposes: We use your data based on your consent to contact you for advertising purposes (newsletter, customer satisfaction surveys, availability notifications) via email. If you consent, we personalize the content of the newsletters according to your interests. Additionally, we use your data on the legal basis of your consent to display interest-based advertising on our website and the websites of our advertising partners, based on the cookies or similar technologies we use. Furthermore, with your consent, we use cookies or similar technologies that enable us to offer you certain convenience features and analyze website usage to measure and improve its performance. Further information on the use of cookies and similar technologies can be found in our cookie settings.

You can revoke your consent for the use of your data for advertising and analytical purposes at any time with effect for the future. To do so, you can click on the unsubscribe link included in the respective advertising messages in the case of email advertising or contact us at support@zazzowear.com or via the address provided in section 1 of this privacy policy. You can revoke your consent for the use of cookies and similar technologies in our cookie settings.

Data processing to fulfill legal obligations based on Article 6(1)(c) of the GDPR

Data security: In operating the webshop, we are obligated to fulfill legal requirements. This includes, among other things, the obligation to ensure the security of your data when using the webshop. For this purpose, we may process your data as part of measures to ensure data security.

Retention obligations: In addition, we must retain certain data (e.g., commercial letters and documents) for a legally prescribed period. Such data may only be deleted after the expiration of the legally prescribed retention periods, even if deletion requests are made.

Data processing based on legitimate interests pursuant to Art. 6 (1) lit. f) GDPR

Below you will find information about data processing activities, including transfers, which we carry out on the legal basis of our legitimate interests in the respective purpose of processing, as described in more detail below. Processing takes place only to the extent necessary to safeguard our legitimate interests or those of a third party and does not override your interests, fundamental rights, and freedoms. If you require further information about the balancing of interests conducted during these processes, please contact us at the address provided in section 1 of this Privacy Policy.

Storage of access data in server log files: During your visit to our webshop, we store access data in so-called server log files, such as the name of the requested file, date and time of access, the amount of data transferred, and the requesting provider. To the extent that personal data is processed in this context, such processing is based on our predominant legitimate interest in ensuring the smooth operation of the website and improving our offering.

Country and language preferences: Upon the first visit to our webshop or if you delete our country preference cookie, you will be asked to select the country relevant to your order and, if applicable, a language for that country, so we can display prices in our webshop in the relevant currency. Based on your IP address, we may also suggest suitable countries via pop-up window, which our service provider determines as the probable delivery region based on your IP address. This data processing is based on our overriding legitimate interest in providing a user-friendly website. You can change the region and language at any time in our webshop by clicking on the globe icon in the website footer and then selecting the desired location and language.

Product recommendations: When you order goods from us, we may use your data to provide you with product information about similar products. This is based on our legitimate interest in being able to offer you suitable product recommendations. You can object to our use of your data for these advertising purposes at any time with effect for the future. To do this, you can click on the unsubscribe link in the respective advertising messages or contact us at support@zazzowear.com or at the address mentioned in section 1 of this privacy information.

Credit check and fraud prevention: We use your data to reduce the risk of payment default and fraud in online orders and the operation of our online webshop, especially when you choose payment by invoice. This is based on our legitimate interest in protecting ourselves, our customers, and other users from the misuse of your data, particularly through fraudulent orders. For this purpose, we process device and access data as well as shopping and payment data. We collaborate with credit and fraud prevention service providers who provide us with credit data, such as information to assess the risk determined by our service providers. The processing of your data for the stated purposes is necessary for the performance of the contract, and without the data, we may not be able to fulfill your order. You can object to our use of your data for these purposes at any time with effect for the future by stating the reasons arising from your particular situation. You can contact us at support@zazzowear.com or through the address provided in section 1 of this privacy information.

5. WITH WHOM WILL MY DATA BE SHARED?

Even when we share your data with service providers, we ensure that your data is processed, protected, and transmitted in accordance with applicable legal requirements.

We transmit your data to the following entities for the purposes stated:

Shipping

As part of fulfilling your order and for the purpose of package delivery, we provide your data to shipping or transport companies based in United Kingdom that are entrusted with the delivery, to the extent necessary for the delivery of your ordered goods.

The transfer of data is necessary for processing your order and thus for the fulfillment of our contractual obligations, and therefore takes place on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR.

Credit Check

If you choose to purchase on account, we have a legitimate interest in being able to assess the associated economic risks before concluding a contract. Therefore, if you select the payment method “purchase on account,” we will transmit your data (name, address, and possibly date of birth) for the purpose of credit checking, to assess the risk of payment default based on mathematical-statistical procedures using address data, and to verify your address (checking for deliverability) to a financial service provider. The legal basis for these transfers is Art. 6 para. 1 sentence 1 lit. f) GDPR. The transmission is based on our legitimate interest in ensuring your solvency when purchasing our products on account.

Fraud Prevention

We conduct fraud checks on orders and transmit your order data to our service providers for this purpose. If an order is deemed risky based on the check, your order may be canceled.

For purchases on account or payment via PayPal, we transmit your order data (name, address, gender, date of birth, cart value, order time, IP address, payment method) to a service provider based in United Kingdom for the purpose of fraud prevention.

If you choose credit card as the payment method, we transmit your order data to a service provider based in the USA. This service provider uses probability values in their fraud check to detect orders that pose a risk of fraud to us. For further information on how our service provider processes personal data, please contact us at any time using the contact details provided in Section 1 of this privacy notice. If you do not agree to the transfer of data to this service provider, please use an alternative payment method.

The legal basis for these transfers is our legitimate interest in preventing fraud cases to your or our detriment, Art. 6 para. 1 sentence 1 lit. f) GDPR.

Debt Collection

If there are outstanding claims from your orders, we will contact you by email with a reminder for payment. If you do not comply with this reminder despite the existence of a legitimate claim, we may transfer the claim to our debt collection service provider, to whom we will provide your order and contact details for this purpose.

The legal basis for the transfer of your data to this service provider is its necessity for the performance of the contract, Art. 6 para. 1 sentence 1 lit. b) GDPR.

Newsletter, Personalized Product Recommendations, and Surveys

For the technical handling of newsletter delivery and personalized product recommendations, as well as personalized messages based on user behavior via email, a service provider is used.

For conducting customer satisfaction surveys, we also use a service provider to obtain customer feedback, such as brand awareness and product feedback.

Our partners process your data solely according to our instructions and on our behalf. We have contractually ensured that our partners comply with all data protection requirements. The scope of the data transmitted is limited to the minimum required. The transfer of data is based on Art. 28 para. 1 GDPR.

Furthermore, as part of the use of tracking functions on our website, we also transmit additional data for advertising purposes to third parties. For more information, including your options, please see our Cookie Settings.

6. ARE MY DATA TRANSFERRED TO A THIRD COUNTRY?

Some of our service providers and group companies, to whom we transmit your data, are located outside the European Economic Area (EEA). In these countries, there may not be a level of protection for your personal data comparable to that provided by the GDPR. In particular, government authorities in those countries may have the right to access your data without effective legal remedies available to you to challenge such access. Such transmission only occurs if the third country has been confirmed by the EU Commission to provide an adequate level of data protection (Art. 45 (1) GDPR) or if you have expressly consented to the transfer of your data to recipients outside the EEA (Art. 49 (1) (a) GDPR). Otherwise, we ensure an adequate level of data protection is maintained through appropriate contractual, technical, and/or organizational measures (including the use of EU Standard Contractual Clauses, additional measures, and regular reviews). Further information and copies of the EU Standard Contractual Clauses are available from the contact details provided in section 1 of this privacy information.

7. HOW LONG WILL MY DATA BE STORED?

Your data will be stored in accordance with Art. 5 para. 1 lit. e) GDPR for as long as we are legally obligated to do so or as long as we need your data for the purposes mentioned above under point 4. Subsequently, the processing of your data will be restricted or your data will be deleted in order to comply with the principle of data minimization and storage limitation.

If you require further information regarding our deletion and retention periods, please contact us at the address provided in point 1 of this privacy information.

8. WHICH DATA PROTECTION RIGHTS CAN I ASSERT AS A DATA SUBJECT?

You can assert your data subject rights, as described below. To do so, you can contact us using the contact details provided in section 1 of this privacy information.

Right to information

You have the right to obtain information pursuant to Art. 15 GDPR about your personal data processed by us. In your request for information, you should specify your concerns to facilitate the compilation of the necessary data. Please note that your right to information may be restricted under certain circumstances in accordance with legal provisions (in particular § 34 BDSG).

Right to rectification

If the information concerning you is incorrect or incomplete, you have the right under Art. 16 GDPR to request rectification. If your data is incomplete, you can request completion.

Right to erasure

You can request the deletion of your personal data under the conditions of Art. 17 GDPR. Your right to erasure depends, among other things, on whether the data concerning you is still required by us to fulfill our contractual or legal obligations.

Right to restriction of processing

Within the framework of the provisions of Art. 18 GDPR, you have the right to request restriction of processing of your data.

Right to object

According to Art. 21 GDPR, you have the right to object to the processing of your data at any time for reasons arising from your particular situation. However, we may not always be able to comply with this request, for example, if legal regulations require us to process the data. If we process your data for direct marketing purposes, you can object to the processing at any time (Art. 21 para. 2 GDPR).

Right to Lodge a Complaint with a Data Protection Authority

We are committed to working with you to achieve a fair resolution of any complaints regarding data protection.You have the right to lodge a complaint with a data protection authority, particularly in the EU Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you believe that the processing of your personal data by us violates applicable data protection law.

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E-Mail: support@zazzowear.com