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Data Privacy Policy

Thank you for your interest in hhv.de. We respect the privacy of our customers and users. We strictly abide to the legal provisions when processing your personal data in line with our services. Therefore, we would like to provide you with detailed information on what data is collected when you visit our website and use the offers made there and how it is subsequently processed or used. As the data controller, we have implemented numerous technical and organisational measures, to ensure the best possible and complete protection of the personal data processed via our website.

Upon agreeing to the following privacy policy, you consent to the HHV Handels GmbH (hereinafter HHV) collecting, processing and using your personal data in compliance with data protection laws and the following provisions.

1. Controller / data security officer

The controller for the processing of your personal data is the HHV Handels GmbH, Zur Alten Börse 55, 12681 Berlin, Managing Director: Thomas Ulrich, District Court of Berlin-Charlottenburg, HRB (Commercial Registry no.) 117211 B; VAT ID no.: DE 263 440 712

If you would like to object to the collection, processing or use of your data by HHV in compliance with this privacy policy as a whole or for individual measures, you can send your objection via email or letter using the following contact data:

HHV Handels GmbH
Zur Alten Börse 55
12681 Berlin
Tel.: +49(0)30 29 38 12 40
Email: datenschutz@hhv.de

Furthermore, you can also receive information on the data we store at any time and free of charge (please refer to Section 8 of this privacy policy).

Data security officer:
Mr. Karsten Knappe
c/o DGI Deutsche Gesellschaft für Informationssicherheit AG
Kurfürstendamm 57
10707 Berlin

2. Security of data transmission

To ensure the security of your personal data during transmission, we use state of the art SSL encryption procedures. You can recognise encrypted data transmission by the “https://www.hhv.de” at the beginning of the browser line. Personal data includes, for instance, your name, your address or email address as well as other data you communicate to us when registering or creating a customer account. Only submit your confidential information if SSL encryption is activated.

3. This is how we use your data

3.1 Cookies

Cookies are text files, which are stored on your computer and which enable analysing your use of the website. For example, information regarding the operating system, the browser, your IP address, the website you previously accessed (referrer URL) as well as the date and time of your visit to hhv.de. Cookies enable determining which websites are preferably accessed. Consequently, we can better adjust the content of our pages to the visitors of our website and optimise our offers. Furthermore, this information serves automatically recognising you during your next visit to hhv.de and making navigation easier for you. For example, cookies allow the user to remain logged in permanently, so the repeated entry of the login data is not necessary.

Cookies cannot be used to start programs or transmit viruses to a computer.

3.2 Server data / server log files

Inter alia, the following data transmitted by your web browser to us or our web space provider is collected for technical reasons. This data includes:

  • browser type and version
  • operating system used
  • web page from which you are visiting us (referrer URL)
  • web page you are visiting
  • date and time of your access
  • your Internet Protocol (IP) address.

This anonymous data is stored separately from your possibly indicated personal data and is not attributable to specific individuals. It is analysed for statistical purposes, to be able to optimise our website and our offers. We reserve the right to subsequently review this data if we become aware of concrete indications of illegal use.

3.3 Cookie Management using Consentmanager

On our website we use a cookie management tool: the Consentmanager from Consentmanager AB, Håltegelvägen 1b, 72348 Västerås, Sweden. With the help of this tool, you have the option of agreeing to or rejecting the processing of your end device information and personal data using cookies for the purposes listed in the Consentmanager. We use the Consentmanager to comply with our data protection obligations and to allow the users of our website to decide whether to set cookies and similar functionalities and to offer them the opportunity to change settings that have already been made as part of their continued use of our website.

3.4 Newsletter

With the newsletter, we periodically inform you about us and our offers. We use the so-called double opt-in procedure for subscribing to our newsletter; that means we will not send you a newsletter via email until you click on a link in our notification email confirming that you would like to receive our newsletter. No other data is collected. Your data is not forwarded to third parties. Excluded from this are solely partner companies, which are responsible for the technical procedure involved in sending the newsletter.

With the subscription to the HHV newsletter, we store your IP address and the subscription date. This storage solely serves as proof in the event that a third party misuses an email address and subscribes to the newsletter, without the authorised individual being aware of this.

Our newsletters contain so-called tracking pixels, which enable us to detect whether and when an email was opened. Furthermore, link clicks are analysed within the newsletter. We store this data, to allow us to ideally adjust our newsletters to the wishes and interests of our subscribers. Therefore, the data collected in this manner is used, to send personalised newsletters to the respective recipients.

You can revoke your consent to the storage of the data, the email addresses as well as their use for sending the newsletter at any time. By revoking your consent to receive the newsletter, the consent for the aforementioned tracking is also revoked. Revocation can be conducted via a notification to the contact options listed in Section 1 of this privacy policy. Users, who would no longer like to receive our newsletter or our advertising emails, can of course unsubscribe at any time by clicking on the unsubscribe link at the end of every newsletter.

3.5 Product recommendations via email

At random intervals after a purchase with HHV you will receive product recommendations via email. You will receive these irrespective of whether or not you subscribed to a newsletter. By sending you these emails, we would like to provide you with information on our products, which you may be interested in based on your last purchases and your wish list in our shop. In the process, we strictly observe the legal provisions.

Insofar as you no longer want to receive any product recommendations or any kind of promotional content, you can object to this at any time without any costs arising for this other than the transmission costs in accordance with the basic rates. A written notification addressed to the contact details stated in Chapter 1 (via letter or email) suffices for this purpose. Of course you can also find an unsubscribe link in every email.

3.6 Contact form

Our website provides you with the option of contacting us via email and/or using a contact form. We only use your email address to process your enquiry as well as for possible follow-up questions.

3.7 Google services

We use the following services of the Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA on our website:

Web analysis with Google Analytics

We use Google Analytics, a web analysis service of the Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA on our website. We entered into an agreement with Google for order processing and fully implement the legal provisions for the use of Google Analytics.

We use the “Activation of the IP anonymisation” feature on this website. In this case, your IP address is already truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area and therefore, anonymised. The full IP address is only transmitted to a Google server in the USA and truncated there in exceptional cases.

Using cookies, information such as the operating system, the browser, your IP address, the website you previously accessed (referrer URL) and the date and time of your visit to our website is collected. The information on the use of our website, which is created in this manner, is transmitted to a Google server in the USA and stored there. Google uses this information to analyse your use of our website, to compile reports on the website activity for the website operator and to provide other services associated with the use of the website and Internet. Insofar as required by law or insofar as third parties process this data on behalf of Google, Google will also transfer this information to these third parties. This use is anonymised or pseudonymised. You can find more detailed information on this directly at Google.

More information on how user data is handled at Google Analytics can be found in the Google privacy policy: support.google.com/analytics/answer/6004245?hl=en

You can prevent the collection of the data created by the cookie and relating to your use of the website (incl. your IP address) by Google as well as the processing of this data by Google. However, we would like to point out that you may then not be able to use the full range of the functions on this website.

  • Select the respective setting in your browser software
  • Click on this link: Disable Google Analytics
  • An opt-out cookie is placed, which prevents the future collection of your data when visiting this website: At the same time, a collection on this website by Google Analytics and for this browser is prevented in the future, as long as the cookie remains installed in your browser.

Google Conversion Tracking

If you accessed our website from a Google ad, Google AdWords places a cookie on your computer. This cookie is no longer valid after 30 days and does not enable identifying you personally. If you visit certain pages of our website and the cookie has not yet expired, we and Google can detect that you, as a user, clicked on one of our ads placed at Google and were connected to our site. The information collected with the help of Google serves compiling statistics on visitors for our website. These statistics show us the total number of users, who clicked on our ad and furthermore, which pages the respective users then accessed. However, we as well as other advertisers do not receive any information via “Google AdWords”, which allow identifying users personally.
You can access the Google privacy policy in this regard here.

You can prevent the installation of the cookies by means of the respective setting in your browser, for instance using the browser setting, which disables the automatic placement of cookies in general or specifically only disables the cookies from the “googleadservices.com” domain.

Google Remarketing

Using this service, ads can be placed for users, who already visited our website in the past.

Within the Google advertising network, this enables showing advertisements on our website, which are adapted to your interests. Google remarketing uses cookies for this analysis. This enables recognising our visitors as soon as they access websites within the Google advertising network. This way, advertisements can be placed within the Google advertising network, which relate to content, which the visitor previously accessed on websites of the Google advertising network, which also use the Google remarketing feature. According to Google, no personal data is collected in the process. You can disable this feature if you make the corresponding settings at google.com/settings/ads.

Google Maps

Every time the “Google Maps” component is accessed, a cookie is placed by Google, to process user settings and data for the display of the page on which the “Google Maps” component is integrated. This cookie is normally not deleted by closing the browser but rather expires after a specific time, unless you already deleted it manually.
If you disagree with this processing of your data, you have the option of disabling the “Google Maps” service and in doing so, preventing the transmission of data to Google. In order to do this, you must disable the JavaScript function in your browser. However, we would like to point out that in this case, you will not be able to use “Google Maps” or will only be able to use it to a limited extent.

The use of “Google Maps” and the information obtained via “Google Maps” takes place according to the Google terms of use google.de/intl/de/policies/terms/regional.html.

3.8 Facebook services

We use the three following tools from the US service provider Meta Platforms Inc. on our website. The company Meta Platform Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland), hereinafter “Facebook”, is responsible for the European region.

As Facebook also processes your data in the USA, we would like to point out that, according to the European Court of Justice, there is currently no adequate level of protection for data transfer to the USA. This can be associated with various risks for the legality and security of data processing.

Facebook uses so-called standard contractual clauses (= Art. 46 Para. 2 and 3 GDPR) as the basis for data processing for recipients based in third countries or data transfer there. Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data also comply with European data protection standards if they are transferred to and stored in third countries (such as the USA).

With these clauses, Facebook undertakes to comply with European data protection standards when processing your data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementation decision of the EU Commission: For more information, please refer to the corresponding Resolution incl. Standard Contractual Clauses, which correspond to the standard contractual clauses.

Facebook Conversions API

The Conversions API enables a direct and reliable connection of the marketing data (e.g. website events and offline conversions) from our server and our website platform to Facebook. This marketing data is important for ad personalization, optimization and measurement on Facebook so that our ads can be shown to people who are likely to be interested in them.

You can also find out more about the data processed by using the Facebook Conversions API in the Facebook Data Policy.

Facebook Custom Audiences

This tool enables us to supply ads on Facebook, which are tailored to your interests. In the process, an irreversible and non-personal checksum (hash value) is basically generated from your user data, which can be transmitted to Facebook for analysis and marketing purposes. Therefore, the content is controlled anonymously solely based on encrypted values, for which one specific value is also always created for a specific identification value, without sending the plain data to us or Facebook. Data transmission takes place using TLS (Transport Layer Security). The Facebook cookie is activated for the Website Custom Audiences product.

Additional information regarding the purpose and scope of data processing and use of the data by Facebook as well as your setting options to protect your privacy can be found in the ad preferences settings . There you can also object to the use of Facebook Website Custom Audiences.

Facebook like button

hhv.de integrate the Facebook „like button”. You can find an overview of the Facebook plugins here. Every time access is made to our website, which is equipped with such a component, this component initiates that the browser you are using downloads a corresponding display of the Facebook component. This process informs Facebook of the precise page within hhv.de you are currently accessing. When you access our page while you are logged in to Facebook, the information collected by the component shows Facebook the precise page you are accessing and allocates this information to your personal account on Facebook. If you click the “like” button for instance or if you make respective comments, this information is transmitted to your personal user account on Facebook and stored there. Furthermore, the information that you visited our site is transmitted to Facebook. This takes place irrespective of whether or not you clicked the component.

We would like to point out that we, as the provider of the website, do not receive any information regarding the content of the transmitted data or its use by Facebook. Additional information on this matter can be found in the Facebook privacy policy. If you do not want Facebook to be able to allocate your visit to our site to your Facebook user account, please log out of your Facebook user account first.

3.9 Share function via AddToAny

Through a double-click procedure, our website offers the option of sharing content in social networks via the AddToAny service. While using this service, cookies are being employed. The so collected data (for example access time or browser language) will be sent to AddToAny to the USA.

Further information on data processing and privacy by AddToAny can be found under addtoany.com/privacy. Here you will find the type of data being processed as well as the purpose. HHV is not involved in the processing of the enlisted data.

By using AddToAny you agree on the data processing by AddToAny as stated on addtoany.com.

3.10 YouTube

We use components of YouTube, LLC 901 Cherry Ave., 94066 San Bruno, CA, USA, a company of the Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA, at hhv.de. In this connection, we use the option “extended data protection mode” provided by YouTube.

When you access a page with an embedded video, a connection is made to the YouTube servers and at the same time, the content is shown on the web page following an instruction to your browser. According to YouTube, data is only transmitted to the YouTube server in the “extended data protection mode”, in particular which of our web pages you visited, if you watch the video. If you are simultaneously logged in to YouTube, this information is allocated to your member account at YouTube. You can prevent this by logging out of your member account prior to visiting our website. Additional information on YouTube’s data privacy was made available by Google here.

3.11 Affiliate marketing

We use affiliate tracking cookies at hhv.de, to collect sales and/or leads (website visitors, who were acquired through online marketing measures) accurately. These affiliate tracking cookies do not store any personal data. Only the identification number of the intermediary partner as well the reference number of the advertising media you clicked on is collected. This information is required to handle payments between the website operator and the HHV. If a transaction is completed, the partner identification number serves the allocation of the commission to be paid to the intermediary partner.
You can prevent the installation of the cookies by means of a respective setting in your browser software; however, we would like to point out that you may then not be able to use the full range of the functions on our website.

3.12 Payment service providers

If applicable, your data can be transferred to one of the following payment service providers, which are respectively named in the order process. Payment can only be made using the online payment methods indicated in the shop.

PayPal

If payment is made using PayPal, we transfer your data to PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg, in line with the order. In the process, HHV does not have any access to the data pertaining to the customer’s bank details. You can find additional information on PayPal’s data privacy here.

Credit card

For credit card payments, HHV collaborates with the “ipayment” payment system of the 1 & 1 Internet AG, 1&1 Internet SE, Elgendorfer Str. 57, 56410 Montabaur, which is certified in accordance with the highest level of security standard PCI DSS (Payment Card Industry Data Security Standard). The customer enters the required credit card and payment data online via the ipayment interface. As a result, HHV does not have access to the customer’s respective data. Data transmission takes place via a secure connection (SSL encrypted). The customer’s credit card is charged when the order has been completed. More detailed information on how 1&1 handles personal data can be found here (German).

Sofort

You have the option of paying for your order using Sofortüberweisung. In this case, payment is handled by the Sofort GmbH, Theresienhöhe 12, 80339 Munich. The Sofort GmbH is part of the Klarna Group. Additional information on data privacy for this payment method can be found here (German).

C.O.D. (cash on delivery)

Furthermore, in Germany, HHV accepts cash on delivery payments. In this case, payment is made upon delivery by the shipping company DHL, to which your data is transferred.

Advance payment

For order processes using advance payment/bank transfer, you transfer the amount to be paid to our company account within the specified period. We treat the bank details we receive from you strictly confidential and solely transfer them to our logistics partners for the purpose of order processing.

3.13 Shipping providers

HHV collaborates with the following shipping providers, to which, depending on your shipping preferences, your data – and only the data required for order processing – is transferred. DHL, Hermes, UPS, FedEx and Deutsche Post (letter post).

3.14 User registration

We offer you the option of registering on hhv.de. The personal data you voluntarily submit to us in the process, such as name, address as well as date of birth and email address, is processed for the purpose of our offer.

We use the email address indicated during the registration process for important changes, e.g. regarding the scope of our services or for technically required adjustments, to inform you of these.

Registered users have the option of having the data they indicated during registration changed or deleted at any time. We are more than happy to change or delete this data upon your request, provided that this does not conflict with any legal retention periods. To do so, please use the contact details indicated on this page in Section 1 of this privacy policy.

Furthermore, we store your IP address and the date as well as time of your registration after you register on our site. This serves cases, in which a third party misuses your data and registers on our site without your knowledge; as protection on our part. Data is not transferred to third parties.

3.15 Guest orders

You have the option of placing orders as a guest. If you decide to use this type of ordering, you do not have to create a customer account before placing an order. Please note, that you have to re-enter your data for every additional order and that some of our website features are not available when ordering as a guest (e.g. wishlist features).

3.16 Customer / contract data

We only process your personal data, insofar as this is required for substantiation, content design or change in legal relationships (master data). We only process personal data pertaining to the usage of our website (usage data), insofar as this is required to enable or bill the use of the service.

3.17 Trusted Shops

Trustbadge Seal of Approval

Trusted Shops widgets are integrated on this website to display Trusted Shops services (e.g. seal of approval, collected reviews) and to offer Trusted Shops products to buyers after an order.

This serves to safeguard our overriding legitimate interests in optimal marketing by enabling secure shopping in accordance with Article 6 Paragraph 1 Sentence 1 lit. f GDPR. The Trustbadge and the services advertised with it are an offer from Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne.

The Trustbadge is provided by a US CDN provider (Content Delivery Network) as part of a shared responsibility. An appropriate level of data protection is ensured by standard data protection clauses and other contractual measures. Further information on data protection at Trusted Shops GmbH can be found in their data protection declaration (German).

When the Trustbadge is called up, the web server automatically saves a so-called server log file, which also contains your IP address, date and time of the call, amount of data transferred and the requesting provider (access data) and documents the call. The IP address is anonymized immediately after collection, so that the stored data cannot be assigned to you personally. The anonymized data is used in particular for statistical purposes and for error analysis.

Trusted Shops uses service providers in the areas of hosting, monitoring and logging to ensure trouble-free operation. Processing can take place in third countries (USA and Israel). An appropriate level of data protection is ensured in the case of the USA by standard data protection clauses and other contractual measures, and in the case of Israel by an adequacy decision.

Review requests via e-mail

In order to improve, we depend on feedback from our customers. You will therefore receive a review request via email a few days after your parcel has been delivered. The legal basis is Article 6 Paragraph 1 Clause 1 Letter f GDPR. This serves to check whether you are already registered for services with Trusted Shops GmbH and is therefore necessary for the fulfillment of our and Trusted Shops’ overriding legitimate interests in the provision of buyer protection linked to the specific order and the transactional evaluation services in accordance with Art. 6 paragraph 1 sentence 1 lit. f GDPR required. If this is the case, further processing takes place in accordance with the contractual agreement made between you and Trusted Shops. If you are not yet registered for the services, you will then be given the opportunity to do so for the first time. Further processing after registration is also based on the contractual agreement with Trusted Shops GmbH. If you do not register, all transmitted data will be automatically deleted by Trusted Shops GmbH and a personal reference is then no longer possible.

If you do not wish to receive any e-mails from Trusted Shops about your order, you will of course find an unsubscribe link in each such review request.

3.18. Trustami

In order to display our collected reviews and social media feedback, the Trustami badge is incorporated into this web page. Whenever a Trustami badge is displayed, the web server automatically stores a server log file (access data) which contains, the name of the visited website, the file, date and time of display, your reduced IP address, the transmitted data volume, the status of your request, the browser type, the operating system of the user, the referring URL (from the previous webpage) and the requesting provider. This access data will not be evaluated and will be automatically overwritten seven days after your visit to the page. The Trustami badge and connected services advertised are an offer of Trustami GmbH, Schröderstraße 5, 10115 Berlin. For the processing of the data collected by Trustami, the privacy policy of Trustami is valid (www.trustami.com/privacy).

3.19 Employment ads

If you apply for a job at HHV, we process your application information for the purpose of carrying out the application process, among other things electronically. In particular, processing is done electronically if the application documents are submitted to us electronically, for instance via email.

If your application results in the conclusion of an employment contract, your submitted data can be stored in your personnel file for the purpose of the customary organisational and administrative processes in compliance with the relevant legal provisions.

In the event that your job application is unsuccessful, the data you submitted is automatically erased two months after notification of rejection.

This does not apply if a longer retention period is required by law (for example for the burden of proof in compliance with the German General Act on Equal Treatment) or if you explicitly agreed to a longer retention period.

4. Legal basis for the processing of personal data

We only process your personal data, insofar as this is required for substantiation, content design or change in legal relationships (master data) or if the law dictates the processing of personal data or if you have explicitly agreed to said processing.

5. Processing based on legitimate interests

By law, we are entitled to protect other legitimate interests to process personal data, unless the interests or basic rights and freedoms of the data subject prevail.

6. Transmission of personal data to third parties

Your personal data is only forwarded or transferred to third parties if this is required for the purpose of contract implementation – in particular forwarding of order data to suppliers – or for billing purposes or if you have previously agreed to this.

A transmission of your data to third parties without explicit consent, for instance for advertising purposes, does not take place. All providers are obligated to observe the applicable data protection requirements.

7. Storage duration of personal data

We store personal data pursuant to legal requirements and as long as required to render a service, which you ordered or gave your consent to, provided that there are no other legal obligations such as retention periods under commercial or tax law.

8. Your rights regarding data privacy

Information

At all times, you have the right to information regarding the storage of your personal data; also in regard to its origin, the recipients, whom the data was transferred to and the purpose of data processing.

Correction

You have the right, to request us to immediately correct your inaccurate personal data or to complete incomplete personal data for the purpose of processing.

Erasure

An erasure of the stored personal data is conducted, provided that you revoke your consent for storage, you object to the processing of your personal data, the keeping of data is no longer required to fulfil the purpose pursued with the storage or storage is impermissible based on legal specifications.

Restriction of processing

In the event that you dispute the personal data stored in connection with you or if you require the personal data for the assertion, exercising or defence of legal claims but at the same time, we do no longer require this data, you can request the restriction of the processing of said personal data.

Furthermore, you can restrict the processing for the period from lodging an objection against processing to the decision and the granting of such.

If the restriction of processing your personal data takes place, this data is no longer processed.

Objection

In the event that processing your personal data is required based on a legitimate interest, on our part as well as on the part of a third party or the processing is required to perform a task in the public interest or is being exercised in public authority, you have the right, for reasons resulting from your specific circumstances, to lodge an objection against said processing at any time.

In the event of an objection, we no longer process your personal data, unless we can verify compelling grounds requiring protection, which predominate your interests, rights and freedoms or require processing for the assertion, exercising or defence of legal claims.

This right to object also applies to direct advertising and profiling in connection with it.

Revocation

You have the right to revoke consent given for the use of data at any time. The legality of processing conducted based on the consent remains unaffected by this until revocation.

9. Provision and non-provision of personal data

As a matter of principle, you can visit hhv.de without submitting any personal data. We do not store any personal data in this connection. However, we would like to point out that you may then not be able to use the full range of the functions on our website. We solely analyse statistical data, to improve our services; said data does not allow us to personally identify you.

10. Change of purpose for the processing of personal data

As soon as we intend to continue processing the personal data for a purpose other than the purpose the personal data was collected for, we will inform you of this other purpose prior to this further processing.

11. Changes to the privacy policy

We reserve the right to change our security and data privacy measures, provided that this is required based on legal and/or technical developments. In these cases, we will also adapt our information regarding data privacy accordingly. Therefore, please observe the respectively current version of our privacy policy.

12. Questions, suggestions and complaints

Of course we are more than happy to answer any questions you have regarding the processing of your personal data by the HHV Handels GmbH at any time. For questions this privacy policy was not able to answer or for further information, suggestions or complaints, please contact us using the contact options stated in Section 1 of this privacy policy – by post with the words “data privacy” or via email.

Alternatively, you can contact our data security officer directly with any questions pertaining to data privacy. These contact details can also be found in Section 1 of this privacy policy.

You also have the right to lodge a complaint with the responsible supervisory authority regarding the processing of your personal data:

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219
10969 Berlin
mailbox@datenschutz-berlin.de