PRIVACY POLICY
Last update: November 18, 2019
windsor. values the protection of your data and collects, processes, and uses your personal data exclusively in compliance with the applicable data protection laws, e.g. the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and the Telemedia Act (TMG), as well as in accordance with the principles described below.
The controller for the operation of this website (www.windsor.de/eu/en/ hereinafter: “website”) is Strellson AG, Sonnenwiesenstrasse 21, 8280 Kreuzlingen, Switzerland (hereinafter: windsor.). It is also the operator of the online shop (hereinafter: “online shop”), however, its subsidiary, Lenox AG, Sonnenwiesenstrasse 21, 8280 Kreuzlingen, Switzerland is the contractual partner of the customers for online shop purchases.
Lenox AG is also the controller for the data needed for contract implementation.
The data protection officer can be reached at: dataprotection@windsor.ch
The representative in the European Union can be reached under:
Kutzschbach Electronic GmbH & Co. KG
Mr. Manfred Schuster
Markham Str.15
D-86720 Nördlingen.
What data do we collect and for which purpose and on which legal basis?
General Information
Personal data are all information related to an identified or identifiable natural person. This includes, for example, your name, your phone number, and your mailing and e-mail addresses.
We collect, process and use your personal data in connection with the operation of the website, setting up and operating a customer account, and providing the services offered in connection with the customer account.
Our subsidiary, Lenox AG, collects, processes, and uses the data collected in the scope of an order in the online shop or released by you for this purpose in your customer account to establish, implement, and process the purchase agreements in the online shop.
Furthermore, we (and Lenox AG as well) collect, process, and use your personal data only within the extent permitted by law, in particular if you consented to this. This may be the case, e.g., if you subscribed to receive newsletters.
Provision of the Website; Communication
The provision of the website by windsor. requires the handling of personal data (IP addresses) to retrieve the website content.
In addition, you have the option of contacting us using the contact form. For this purpose, we collect your name and e-mail address.
We use cookies to provide our website. For more information about this, see “Web Analytics and Cookies, Social Plugins”.
For the provision of this website and for communication with windsor., your personal data is handled on the basis of our legitimate interest pursuant to Art. 6 (1)f) GDPR. For the provision of this website, it is technically necessary for us to process certain personal data (e.g. IP address). For your communication with windsor., it is necessary for us to handle the above-mentioned personal data.
In the scope of the required balancing of interests, we have weighed up your interests and fundamental rights and freedoms, in particular in the confidentiality of your personal data against our interests in providing this website and contact with you. In both cases, our interests are not overridden by your interests and fundamental rights and freedoms, in particular in confidentiality. Otherwise, we could not provide this website to you or respond to your contact request.
Your Customer Account
This website offers you the option of creating a personal customer account. In your customer account, which is managed by windsor., you can save personal information for convenient shopping in the online shop. In addition, in the customer account, windsor. offers you access to your purchase history and the option of creating a wish list to save articles for a later purchase.
To create the customer account, your first and last name, your e-mail address, mailing address and a freely chosen password are required. The provision of other data (telephone number, date of birth) is, of course, voluntary. You can update these data anytime or delete the account.
Your data is used to identify you, to be able to allocate your purchases or shopping baskets to you and subsequently to be able to provide you with a purchase history. If you log into your customer account with us, we can also determine whether you have subscribed to our newsletter. If you have already subscribed to our newsletter and are logged into your customer account, we will not display a banner advertising our newsletter.
You can carry out the deletion yourself by clicking on ‘Delete customer account’ in your customer account. Alternatively, you can also inform us of your request using any of the other contact options provided on this website. Please note that deleting your customer account does not automatically lead to the deletion of all your data held by us, but only to the deletion of the data linked to your customer account. For example, if you have subscribed to our newsletter, this subscription will not be included in the deletion of your customer account. You can cancel your newsletter subscription at any time by clicking on the unsubscribe link in the newsletter or by sending an email to dataprotection@windsor.com. If you would like us to delete all your personal data, please inform us accordingly.
Your personal data in the scope of the “customer account” online service is handled for the establishment, implementation, and processing of the corresponding user agreement in accordance with Art. 6 (1) b) GDPR.
The Online Shop
The online shop is operated by windsor.; however, our subsidiary, Lenox AG, is responsible for processing the transactions and it is also the sole contractual partner for the purchases made therein.
If you are logged into your customer account, the information required to process your order, which is stored in your customer account, will be filled in automatically in the order form. windsor. provides this information to Lenox AG, but exclusively for this purpose of contract performance. Of course, it is also possible to place an order without using a customer account. Lenox AG processes and uses the information in any case only to process the order, and, moreover, insofar as you have given your consent.
If you are logged into the online shop during the order, your wish lists and the information about the purchases (articles, price and time of purchase) will be saved in your customer account.
If, instead of a personal customer account, you would like to make a purchase from us as a guest, your data (same data as in your personal customer account is collected in this case) will be saved only for as long as necessary to process the respective purchase, and will then be deleted or blocked, unless windsor. is required to retain the data to comply with legal obligations.
Your personal data in the scope of the online shop is handled for the establishment, implementation and processing of the corresponding contracts in accordance with Art. 6 (1) (b) GDPR.
Consent and Withdrawal
If you have given us consent to process personal data for specific additional purposes (e.g. credit check, prevention of misuse and fraud, newsletter, preference center), these data are processed on the basis of your consent. When requesting consent, windsor. provides details about the content of that consent. You can find any granted consent of relevance for data protection and additional information about this here.
Consent is always voluntary. If the processing of personal data is based on consent given by you, you have the right to withdraw this consent at any time. This applies also to consent given to us before the entry into force of the GDPR, that is, before May 25, 2018. You can declare your withdrawal also by e-mailing dataprotection@windsor.ch. The legality of the data processed on the basis of consent before the withdrawal remains unaffected by your withdrawal. The legal basis for the data processing based on consent is Art. 6 (1) a) GDPR.
Prize competitions
Strellson AG regularly provides opportunities to participate in prize competitions.
To participate in prize competitions, you must state your full name and, in case of winning, your address.
Your personal data are handled within the framework of the online shop for initiating, implementing, and processing corresponding contracts as per art. 6 para. 1 b) GDPR.
Insofar as the prize competition is carried out on a social media platform, the following section should also be observed.
Facebook and social media sites
You have the option to follow us on Facebook and other social media platforms of third-party service providers. For this purpose, we use the personal data that you provide to us, or respectively, any data about you that are provided to us by the respective platform operator. You can control the privacy settings within a social media platform yourself.
We handle your personal data within the framework of our social media sites on the basis of our legitimate interest as per art. 6 para. 1 f) GDPR. To provide our social media sites, it is technically necessary for us to process certain personal data (for example, IP address; personal data that you have made available to the respective platform provider or to us).
As part of the required balancing of interests, we have in each case weighed up your interests and fundamental rights and freedoms, in particular in the respective secrecy of your personal data against our interests in providing our social media sites. In so doing, our interests are not overridden by your interests and fundamental rights and freedom, in particular in secrecy. Otherwise we would not be able to offer you our social media sites.
We use service providers to provide our social media sites (for example, Facebook). Any data you transfer to us via our social media sites is also automatically transferred to the respective social media platform operator.
For information about the purpose and scope of the collection, processing, and use of the data by the service provider, as well as your rights and setting options for your protection, please see the corresponding privacy notices, which are included in the paragraph “Web Analytics and Cookies, Social Plugins”.
Data Transfer and Data Use by Third Parties
We do not transfer your data to third parties, unless we are legally obligated to do so or you have given us your consent to this.
However, to process orders, certain personal data must be provided to our service providers in the EU and Switzerland, e.g. logistics companies, but also for credit checks and payment processing. In this process, known as contract data processing, the service providers are also contractually obligated to process your personal data only in adherence to the data protection regulations and the required security measures.
Storage Duration and Deletion
windsor. saves and processes your personal data only for as long as necessary for the intended purpose (see “What data do we collect and for what purpose and on what legal basis?”). In all other cases, we delete your personal data; data that we have to store in order to fulfill legal obligations (e.g. tax or commercial retention obligations) constitute an exception to this.
Your Rights as a Data Subject
As a data subject, you have a right of access pursuant to Art. 15 GDPR, a right to rectification pursuant to Art. 16 GDPR, a right to data erasure pursuant to Art. 17 GDPR, a right to restriction of processing pursuant to Art. 18 GDPR, and the right to data portability pursuant to Art. 20 GDPR. The limitations in accordance with Sections 34 and 35 BDSG apply to the rights of access and data erasure.
For reasons arising from your particular situation, you have the right to object anytime to the processing of your personal data, which is done on the basis of Article 6 (1) lit. e) GDPR (data processing in the public interest) and Article 6 (1) lit. f) GDPR (data processing on the basis of a balance of interests). If you object, we will no longer process your personal data, unless we are able to demonstrate compelling legitimate reasons for processing, which override your interests, rights and freedoms, or the processing is done in order to assert, exercise, or defend legal claims.
You can exercise your rights, or make a complaint with windsor., by contacting windsor. using the contact details in the next paragraph.
If you believe that the processing of your personal data violates legal requirements, you have the right to lodge a complaint with a data protection supervisory authority competent in our case (Art. 77 GDPR in conjunction with Section 19 BDSG).
Contact
We are available to answer any additional questions you might have on data protection and processing of your personal data, as well as for withdrawals or requests to provide information. You can reach us at:
dataprotection@windsor.ch or using the contact details provided in the legal notice.
Web Analytics and Cookies, Social Plugins
Our website uses features of various social networks (“plugins”):
- Google Plus “+1″
A button with the “+1” sign on a white or colorful background, operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”)
- YouTube plugins
A button with the YouTube logo, white triangle on a red or colorful background, operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”)
- Facebook plugins
Plugins with a white “f” on a blue tile or “Thumbs Up” or “Like”, operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”)
- Instagram plugins
Plugins of the Instagram social network, [provided by Instagram], Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA (“Instagram”) are integrated in this website. You can identify the Instagram plugin by the “Instagram” button.
- Twitter plugins
A button with the text “twitter”, “retweet” or a small bird, operated by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”)
If you visit a website offered by us that uses such plugins, your browser connects to the services of the plugin provider, if necessary in the USA. We have no influence on the scope of the data collected by the providers via the plugin. According to the providers, personal data, including the IP address, are collected and processed only if users are logged in. Please note that we receive no knowledge of the content of the transmitted data or their use by the social media provider.
Please consult the relevant data privacy policies to find out about the purpose and scope of the collection, processing and use of the data by the providers and your rights in connection with this and settings options for your protection:
- Google +1: https://developers.google.com/+/web/buttons-policy
- YouTube: https://policies.google.com/privacy
- Facebook: https://www.facebook.com/about/privacy/
- Twitter: https://twitter.com/privacy
- Instagram: http://instagram.com/about/legal/privacy
If you are a member of the respective network, but do not want the provider to collect data relating to you through our website and, if applicable, link them to other stored data, please always log out completely from the respective network before visiting other websites and delete any saved cookies as well.
In addition, we use “cookies” when you visit the website and the online shop. Cookies are small text files saved by your browser. For example, your shopping cart is managed through temporary “session” cookies. Other information is saved in permanent cookies in order to customize the appearance of the website to your preferences when you access it from your computer at a later time. Cookies do not contain any information that could directly identify the individual user. You can completely disable the use of cookies in the settings of your browser, but also automatically or manually delete cookies. Please note that, in this case, our website may not work or may not work as intended.
If necessary, we use certain data in accordance with the legal regulations in the scope of pseudonymous user profiles for purposes of advertising, market research, or customized design of our offers.
Our “Usercentrics” is regularly updated and provides you with the option to freely decide whether and, if yes, which cookie types can be used.
Some cookies are placed by third parties that appear on our pages.
You can change or withdraw your consent to the cookie declaration on our website at any time.
For this purpose, delete the local data in your browser. The next time you visit our website, you can specify your cookie preferences.
Hotjar
We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.
For further details, please see the ‘about Hotjar’ section on https://help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar.