Reloop Wear Privacy Statement
Here at Reloop Wear we take your privacy and the processing of your personal data very seriously. That is why, we have prepared this Privacy Notice where we describe our contact details, information regarding what personal data we process and what rights you have towards us and how you may defend them. Always feel free to contact our customer experience team if you have any questions about our processing of personal data or this Privacy Notice.
LAST UPDATED: APRIL 2023
Interpretation and Definitions
Name of the company: Reloop Wear
National company registration number: DE334608703
Country of incorporation: Germany
E-mail address: firstname.lastname@example.org
Phone number: +49 151 53946604
Postal address: Fichtenstr. 9A, 87629 Füssen, Germany
E-mail address to the customer experience team: email@example.com
The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Account means a unique account created for You to access our Service or parts of our Service.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Reloop Wear, Fichtenstraße 9A, 87629 Füssen, Germany. For the purpose of the GDPR, the Company is the Data Controller.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: Bayern, Germany
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
Facebook Fan Page is a public profile named reloop.wear specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/reloop.wear
Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. The processing of special categories of data, defined as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and data concerning health or sex life, is prohibited, subject to certain exceptions.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Reloop Wear, accessible from www.reloopwear.com
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
Collecting and Using Your Personal Data
Your personal data may only be processed by us with your given consent, when it is necessary for the performance of a contract to which you are a party, or when it is necessary for our compliance with a legal obligation. The processing of the personal data, the specific purposes for the processing, the legal basis for the processing, and for how long we store your personal data, is described below.
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province,
- ZIP/Postal code, City
- Bank account information in order to pay for products and/or services within the Service
When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:
- Date of birth
- Passport or National ID card
- Bank card statement
- Other information linking You to an address
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:
If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, for payment processing, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
We are committed to securing personal information and any data we collect from clients. We use physical, technical and organisational security safeguards to help protect your personal data that we have collected from unauthorised access and third parties.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
We may use third-party Service providers to monitor and analyse the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
Newsletter and offers subscription
When you subscribe to our newsletter, we will process your name, email address, date of birth, preferred language and your country of residence as you optionally provide to us, and our processing of your personal data is based on your consent. We may also process your home/delivery address, for delivery of a physical catalogue which you optionally may subscribe to. We will store and process this information until you withdraw your consent by unsubscribing from our newsletter. You can unsubscribe from the newsletter via our website, or by following the Unsubscribe link in each sent email.
Your data may be shared with our third-party service providers such as our CRM system provider, email service provider and our employees or contractors on a need to know basis to carry out our services to you.
You can set your preferences in Your Account section, after logging in.
When you place an order with us, we will process your name, email, home and/or delivery address, country of residence, phone number, your payment and order details. Our storing and processing of such data is necessary for us to perform under a contract to which you are a party and to deliver your purchased products and provide you with post-purchase digital journey and service regarding your purchased products via email. In case you also purchase styling services, we may also process your photos, physical features, date of birth, gender and your measurements that you voluntarily provide to us.
All the above data that you provide to us, will be stored with us for 3 years from your last purchase, as this is the length of consumer related statutes of limitations for civil claims in our countries of operation.
When you purchase our styling services, the necessary personal data (e.g. photos, physical features and contact information) will be shared with the third-party stylist you consult and with whom we have signed a data processing agreement to keep your personal data confidential.
Your data may also be shared with our third-party service providers such as, but not limited to, our Website developers, CRM system provider, email service provider, online payment provider, shipping services provider, packaging provider and our employees or contractors on a need to know basis to carry out our services to you.
Shipping and logistics
During shipping operations we transmit, on the basis of Art. 6 (1f) of the EU’s General Data Protection Regulation, your data (name, address, if necessary email address and/or mobile phone number for notification options and re-directions, together with further shipment-related data) to our shipping partner DPD Deutschland GmbH and DHL International GmbH. You can reject the transmission of supplementary information such as email or mobile phone data both with us at firstname.lastname@example.org and with DPD direct under email@example.com and with the DHL direct through their website or, in the case of all parcel notifications, via a link.
Reloop Wear offers to ship orders with help of the returnable and reusable packaging service RePack (a brand of the Finnish company Plan B from Outer Space Ltd.). This service includes the delivery of the order in a reusable packaging (the Packaging) and the delivery of a reward for returning the Packaging to RePack. To deliver the reward Reloop Wear shares with RePack the customer’s email address and the individual identifier of the Packaging. RePack provides a personalised web link directing at an online marketplace where the customer can select a personal shopping voucher or similar offering. RePack provides the delivery of the reward web link and of the shopping voucher as a processor on behalf of Reloop Wear. Legal basis for the reward communication is fulfilment of a contract as the reward is part of the services by Reloop Wear. RePack is obliged to protect data by a data processing agreement in accordance with EU General Data Protection Regulation (GDPR).
We may also use your purchase data (gender, measurements, country of residence and product choices) on an aggregated and anonymous basis for analytical purposes. None of your data used for these purposes can ever be traced back to you.
If you open an account with us, we will store and process your name, home and/or delivery address, country of residence, language preference, phone number, date of birth, gender, your measurements, your payment details, photos, physical features, as you voluntarily chose to provide to us when you open an account but are yet to complete a purchase. We will also store and process your purchase history and conversation history with our customer experience team.
Would you choose to use social login, such as your Facebook or Google account, when you open an account with us or when link your social account later, we will store and process your social account information and the email address linked to that social account.
We process this data based on your consent and with the purposes of facilitating your use of our website and services, as well as helping you recycle your worn off products, to reward your loyalty and to request feedback and reviews of your purchase experience.
You can always withdraw your consent and inactivate and delete your account, whereafter we will delete your personal data within a month’s time (subject to data processed in accordance with “Purchases and deliveries” above). Your data will be stored and processed until you withdraw your consent, and we will send you a reminder of your account after 2 years of inactivity to make sure you still want to keep your account with us.
We also process your IP address on an anonymous basis when you have created an account or visited our site. We do this for the purposes of saving your site preferences such as chosen language and your country of residence, analysis of your logins and website usage for customizations of your user experience, for personalization of the content shown, for proactive customer support, and for saving the information of the time and place when you gave your consent to subscribing to our newsletter. We encrypt and anonymise your IP address to further ensure your privacy. We will store your IP address until you deactivate your account as described in the paragraph immediately above. You can also use a VPN or a proxy server to block our processing of your IP address.
Your data may be shared with our third-party service providers such as our CRM system provider, website hosting provider, email service provider, online payment provider and our employees on a need to know basis to carry out our services to you.
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.
We may use third-party Service Providers to provide better improvement of our Service.
We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.
The reCAPTCHA service may collect information from You and from Your Device for security purposes.
We may process Personal Data under the following conditions:
Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
Instagram / Facebook Fan Page
The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/reloop.wear, or Instagram page https://www.instagram.com/reloop.wear/ the Company and the operator of the social network Facebook/Instagram (Meta) are Joint Controllers.
The Company has entered into agreements with Instagram/Facebook (Meta) that define the terms for use of the Instagram/Facebook Fan Page, among other things. These terms are mostly based on the Instagram/Facebook (Meta) Terms of Service: https://www.facebook.com/terms.php
We use the Instagram/Facebook (Meta) Insights function in connection with the operation of the Instagram/Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.
For this purpose, Instagram/Facebook (Meta) places a Cookie on the device of the user visiting Our Instagram/Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.
Instagram/Facebook (Meta) receives, records and processes the information stored in the Cookie, especially when the user visits the Instagram/Facebook (Meta) services, services that are provided by other members of the Instagram/Facebook Fan Page and services by other companies that use Instagram/Facebook (Meta) services.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
With regard to the General Data Protection Regulation (EU) 2016/679 (“GDPR”), we must disclose what personal data we collect and process about you, and for what purposes. In this Privacy Notice, you find all such information that we are obliged to inform you.
The Regulation in its entirety in your language, may be accessed by following this link: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2016.119.01.0001.01.ENG&toc=OJ:L:2016:119:TOC
Would you like to defend your rights, which are listed in this Privacy Notice, or would you have any questions related to our processing of your personal data, you may always contact us using the contact information listed above.