fashionXact GmbH | Dagobertstr. 34 | 50668 Köln – Germany
CEO: Danny Fiedler & Thomas Fiedler
HRB 24380 – Amtsgericht Bonn
bravenew.it | design. coding. networks.
Data Protection Officer
M. Jambreusic | fashionxact | Dagobertstr. 34 | 50668 Köln – Germany
phone // tba | matthias[at]fashionxact[dot]de
Types of processed data
Master data (e.g. names, addresses)
Contact details (e.g. e-mail, telephone numbers)
Content data (e.g. text input, photographs, videos)
Usage data (e.g. visited websites, interest in content, access times)
Meta/communication data (e.g. device information, IP addresses)
Processing of special categories of data (Article 9 (1) GDPR)
In principle, no special categories of data are processed, unless they are entered by the user into the processing, e.g. in online forms.
Categories of persons concerned by the data processing (data subjects)
Visitors and users of the online offer. In the following, we will also summarise the concerned persons as “users”.
Purpose of the processing
Provision of the online offer, its contents and functions
To answer contact requests and communicate with users
Marketing, advertising and market research
1. Applicable legal basis
3. Security measures
3.1. We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 GDPR, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons; the measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and their separation. Furthermore, we have established procedures to ensure the exercise of rights of data subjects, deletion of data and reaction to endangerment of data. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly pre-settings (Article 25 GDPR).
4. Cooperation with contract processors and third parties
4.1. If we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transfer it to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transfer of the data to third parties, such as to payment service providers, pursuant to Article 6 (1) lit. b GDPR is required for contract fulfilment), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
4.2. If we commission third parties with the processing of data on the basis of a so-called “processing contract”, this is done on the basis of Article 28 GDPR.
5. Transfer to non-EU/EEA countries
If we process data in a non-EU/EEA country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a non-EU/EEA country only if the special requirements of Article 44 et seq. GDPR. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the US by the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
6. Rights of data subjects
6.1. You have the right to request confirmation as to whether the data concerned are being processed and to request information about these data as well as further information and a copy of the data in accordance with Article 15 GDPR.
6.2. In accordance with Article 16 GDPR, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.
6.3. In accordance with Article 17 GDPR, you have the right to demand that relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with Article 18 GDPR.
6.4. You have the right to request that the data concerning you which you have provided to us be received in accordance with Article 20 GDPR and to request that it be forwarded to other persons responsible.
6.5. You also have the right to file a complaint with the competent supervisory authority pursuant to Article 77 GDPR.
7. Cancellation rights
You have the right to revoke consents granted pursuant to Article 7 (3) GDPR with effect for the future.
8. Right to object
You can object to the future processing of the data concerning you in accordance with Article 21 GDPR at any time. The objection may be lodged in particular against processing for direct marketing purposes.
9. Cookies and right to object against direct advertising
10. Deletion of data
10.2. In accordance with statutory provisions, storage shall be effected in particular for 6 years in accordance with § 257 (1) HGB (accounting books, inventories, opening balance sheets, annual financial reports, commercial letters, posting receipts, etc.) and for 10 years in accordance with § 147 (1) AO (books, records, management reports, posting receipts, commercial and business letters, documents relevant for tax filings, etc.).
11. Establishment of contact
11.1. When contacting us (via contact form or e-mail), the user’s details will be processed for processing the contact request and its handling in accordance with Article 6 (1) lit. b) GDPR.
11.2. User information may be stored in our Customer Relationship Management System (“CRM System”) or comparable request organization.
12. Collection of access data and log files
12.1. On the basis of our legitimate interests within the meaning of Article 6 (1) lit. f. GDPR data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
12.2. Log file information is stored for a maximum of seven days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.
13. Cookies & Reach measurement
13.1. Cookies are information that is transferred from our web server or third party web servers to the user’s web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.
13.3. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
14. Integration of third-party services and content
14.1. Within our online offer, we make no representations or warranties of any kind based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Article 6 (1) lit. f. GDPR) content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as may be linked to such information from other sources.
14.2. The following presentation provides an overview of third-party providers and their contents, together with links to their Privacy Policies, which contain further information on the processing of data and, in some cases already mentioned here, possibilities of objection (so-called opt-out):