gdpr-compliance

(1) Information about the collection of personal data and contact data of the controller

1.1 We are pleased that you visit our website and thank you for your interest. Below we inform you about the handling of your personal data when using our website. Personal data is all data that you can identify personally. < = Responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is KROMARIUM TECHNOLOGIES OÜ, Vowly, Harju maakond, Tallinn, Kesklinna linnaosa, Viru väljak 2, 10111, Estonia, E-mail: service@vowly.co. The controller for the processing of personal data is the natural or legal person who decides on the purposes and means of the processing of personal data alone or together with others.

1.3 This website uses SSL or TLS encryption for security reasons and to protect the transfer of personal data and other confidential content (e.g. orders or requests to the controller). You can recognize an encrypted connection at the string “https://” and the lock icon in your browser line.

2) Data collection when visiting our website

When using our website only for information purposes, so if you do not register or otherwise provide us with information, we only collect such data that your browser transmits to our server (so-called “server log files”). When you visit our website, we collect the following data that is technically necessary for us to show you the website:

• Our visited website
• Date and time at the time of access
• quantity of transmitted data in byte
• Source/reference from which you reached the page
• Used browsers
• Operating system used
• IP address used (possibly: in anonymized form)

Processing is carried out according to Art. 6 para. 1 lit. f GDPR based on our legitimate interest in improving the stability and functionality of our website. The data is not passed on or otherwise used. However, we reserve the right to review the server log files afterwards, if concrete indications indicate illegal use.

3) Cookies

To make the visit of our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your device and allow your browser to be recognized during the next visit (so-called persistent cookies). If cookies are set, collect and process individual user information such as browser and location data as well as IP address values. Persistent cookies are deleted automatically after a predetermined period which can differ depending on the cookie. The duration of the respective cookie storage can be found in the overview of the cookie settings of your web browser.

In some cases, cookies are used to simplify the ordering process by storing settings (e.g., saving the content of a virtual shopping cart for a later visit to the website). If personal data are also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b GDPR either for the implementation of the contract, pursuant to Art. 6 para. 1 lit. a GDPR in the case of granted consent or in accordance with Art. 6 para. 1 lit. f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the website visit.

Please note that you can set your browser so that you can be informed about the setting of cookies and decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general. Each browser differs in the way it manages the cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find these for the respective browsers under the following links:

Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies
Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
Chrome: https://support.google.com/chrome/answer/95647?hl=de&hlrm=en
Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac
Opera: https://help.opera.com/en/latest/web-preferences/#cookies

Please note that if cookies are not accepted, the functionality of our website may be limited.

4) Contact us

Personal data is collected as part of the contact with us (e.g. via contact form or e-mail). What data are collected when using a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of answering your request or for contacting and the associated technical administration. The legal basis for processing this data is our legitimate interest in answering your request in accordance with Art. 6 para. 1 lit. f GDPR. If your contact is aimed at the conclusion of a contract, additional legal basis for processing is Art. 6 para. 1 lit. b GDPR. Your data will be deleted after final processing of your request. This is the case if it can be seen from the circumstances that the situation concerned is finally resolved and if no statutory retention obligations are to be met.

5) Data processing at the opening of a customer account and for contract processing

According to Art. 6 para. 1 lit. b GDPR, personal data will continue to be collected and processed if you inform us about the performance of a contract or the opening of a customer account. The data collected can be seen from the respective input forms. Deletion of your customer account is possible at any time and can be done by sending a message to the aforementioned address of the controller. We store and use the data you provide for contract processing. After complete processing of the contract or deletion of your customer account, your data will be blocked with respect to tax and commercial retention periods and will be deleted after these deadlines have expired, unless you have expressly consented to further use of your data or a legally permitted further use of data has been reserved by our website.

6) Comment function

In the context of the comment function on this website, in addition to your commentary, information about the time of compiling the commentary and the commentator name you choose will be stored and published on this website. Your IP address is also logged and stored. This storage of the IP address takes place for security reasons and in the event that the data subject violates the rights of third parties or postes illegal content by a comment. We need your email address to get in touch with you if a third party should object to your published content as illegal. Legal basis for storing your data is the type. 6 para. 1 lit. b and f GDPR. We reserve the right to delete comments if they are challenged by third parties as illegal.

7) Use of customer data for direct marketing

7.1 Registration for our e-mail newsletter

If you sign up to our email newsletter, we will send you regular information about our offers. Mandatory information for sending the newsletter is only your email address. Data is voluntary and used to address you personally. We use the so-called Double Opt-in procedure for sending the newsletter. This means that we will not send you an e-mail newsletter until you have expressly confirmed that you consent to the reception of newsletters. We will then send you a confirmation email that you will be asked to confirm by clicking on a corresponding link that you want to receive the newsletter in future.

By activating the confirmation link, you give us your consent to the use of your personal data in accordance with Art. 6 para. 1 lit. a GDPR. When registering for the newsletter, we store your IP address entered by the Internet Service Provider (ISP), as well as the date and time of registration, in order to be able to understand a possible misuse of your email address at a later time. The data collected by us when registering for the newsletter is used exclusively for the purposes of advertising by means of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by corresponding message to the controller mentioned at the outset. After you have unsubscribed, your e-mail address will be deleted immediately in our newsletter distributor, unless you have expressly consented to further use of your data or we reserve the right to use additional data which is permitted by law and which we inform you about in this statement.

7.2 Newsletter delivery via Klaviyo

Our e-mail newsletters are sent via the technical service provider »Klaviyo«, 225 Franklin St, Boston, MA 02110, USA (http://www.klaviyo.com/), to which we share your data provided in the newsletter application. This transfer takes place in accordance with Art. 6 para. 1 lit. f GDPR and serves our legitimate interest in the use of a promotional, secure and user-friendly newsletter system. Please note that your data is usually transferred to a Klaviyo server in the USA and stored there.

Klaviyo uses this information to send the newsletter on our behalf. Klaviyo does not use the data of our newsletter recipients in order to write them or to pass them on to third parties.
In order to protect your data in the USA, we have a data processing agreement with Klaviyo, in which Klaviyo commits itself to protecting our users' data, to process their data protection regulations on our behalf and, in particular, not to disclose them to third parties.

You can see the data protection provisions of Klaviyo here: https://www.klaviyo.com/privacy

7.3 Newsletter via Shopify Email

Our e-mail newsletters are sent via Shopify Email, a service provided by Shopify International Limited, Victoria Buildings, 2nd floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland (“Shopify”), to which we share your data provided during the newsletter registration. This transfer takes place in accordance with Art. 6 para. 1 lit. f GDPR and serves our legitimate interest in the use of a promotional, secure and user-friendly newsletter system. The data entered by you for the purpose of newsletter subscription (e.g. e-mail address) are generally stored on the servers of Shopify in the EU.
Within the scope of the aforementioned services provided by Shopify, data can also be transmitted as part of a further processing on behalf of Shopify Inc., 150 Elgin St, Ottawa, ON K2P 1L4, Canada, Shopify Data Processing (USA) Inc., Shopify Payments (USA) Inc. or Shopify (USA) Inc. In the case of the transmission of data to Shopify Inc. in Canada, the appropriate level of data protection is guaranteed by the European Commission's adequacy decision.

Shopify uses this information for sending and statistical evaluation of the newsletter on our behalf. For evaluation, the sent emails can be so-called. Web beacons or tracking pixels contain single pixel image files stored on our website. Thus, it can be determined whether a newsletter message is opened and which links have been clicked. Technical information is also collected (e.g. time of retrieval, IP address, browser type and operating system). The data are collected exclusively pseudonymized and are not linked to your further personal data, direct personal data is excluded. These data are used exclusively for statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients. If you wish to object to data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter subscription.

Furthermore, Shopify can use these data in accordance with Art. 6 para. 1 lit. f GDPR itself, on the basis of its own legitimate interest in the design and optimization of the service as well as for market research purposes, to determine, for example, from which countries the recipients come. Shopify does not use the data of our newsletter recipients, however, in order to write them on their own or to forward the data to third parties.

We have entered into a contract processing agreement with Shopify, with which we commit Shopify to protect our customers' data and not to disclose it to third parties.

Shopify's privacy policy can be found here: https://www.shopify.de/legal/datenschutz

8) Data processing for order processing

8.1 - Transfer of image files for order processing by upload function
On our website we offer customers the opportunity to order the personalization of products by sending image files via an upload function. The submitted image motif is used as a template for the personalization of the selected product.
By means of the upload form on the website, the customer can transmit one or more image files from the memory of the used terminal directly to us by automated, encrypted data transmission. We collect, store and use the transferred files exclusively for the production of the personalized product within the meaning of the respective service description on our website. If the transmitted image files are passed on to special service providers for the production and processing of the order, you will be explicitly informed about this in the following paragraphs. A further transfer is not effected. If the transmitted files or the digital motifs contain personal data (in particular images of identifiable persons), all processing operations just named are carried out exclusively for the purpose of processing your online order in accordance with Art. 6 para. 1 lit. b GDPR. After final processing of the order, the transmitted image files are deleted automatically and completely.

8.2 To process your order, we work with the service provider(s) below, which supports us completely or partially in the implementation of contracts concluded. Some personal data are transmitted to these service providers in accordance with the following information.

The personal data collected by us will be forwarded to the transport company responsible for the delivery as part of the contract processing, as far as this is necessary for the delivery of the goods. We forward your payment data to the commissioned credit institution in the course of payment processing, provided this is necessary for payment processing. If payment service providers are used, we will inform you explicitly below. The legal basis for the disclosure of the data is Art. 6 para. 1 lit. b GDPR.

8.3 To fulfill our contractual obligations to our customers, we work with external shipping partners. We will give your name as well as your delivery address and, if necessary, your telephone number, exclusively for purposes of the delivery of goods Art. 6 para. 1 lit. b GDPR to a partner shipping selected by us. < =

8.5 Use of payment service providers (payment services)

- Apple Pay
If you opt for the payment method “Apple Pay” of Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, the payment processing is carried out using the “Apple Pay” function of your device operated with iOS, watchOS or macOS by loading a payment card deposited with “Apple Pay”. Apple Pay uses security features integrated into your device's hardware and software to protect your transactions. For the release of a payment, it is therefore necessary to enter a code previously set by you and to verify it by means of the “Face ID” or “Touch ID” function of its terminal.
For the purpose of payment processing, your information communicated during the ordering process and the information about your order will be forwarded to Apple in encrypted form. Apple then encrypts this data again with a developer-specific key before the data for the execution of the payment are transmitted to the payment service provider of the payment card deposited in Apple Pay. Encryption ensures that only the website through which the purchase was made can access the payment data. After payment has been made, Apple will send your device account number and a transaction-specific, dynamic security code to the output website to confirm the success of payment.
If personal data are processed in the transmissions described, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 para. 1 lit. b GDPR.
Apple maintains anonymous transaction data, including the approximate purchase amount, approximate date and approximate time, as well as whether the transaction has been successfully completed. The anonymization completely excludes a personal reference. Apple uses anonymized data to improve Apple Pay and other Apple products and services.
If you use Apple Pay on iPhone or Apple Watch to complete a purchase you made via Safari on Mac, the Mac and the authorization device communicate via an encrypted channel on the Apple servers. Apple does not process or store any of this information in a format with which your person can be identified. You can disable the option of using Apple Pay on your Mac in the settings of your iPhone. Go to "Wallet & Apple Pay, and disable payment on Mac.
Further information on data protection at Apple Pay can be found at the following Internet address: https://support.apple.com/de-de/HT203027
- Klarna> When select a Klarna payment service, payment is made via Klarna Bank AB (publ) [https://www.klarna.com/de], Sveavägen 46, 111. In order to enable payment to be processed, your personal data (first and last name, street, house number, postal code, place, gender, e-mail address, telephone number and IP address) as well as data related to the order (e.g. invoice amount, article, delivery type) will be passed on to Klarna for the purpose of identity and credit assessment, provided that you are in accordance with Art. 6 para. 1 lit. a GDPR have expressly consented to the ordering process. You can see which information your data can be forwarded here:
https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de_de/credit_rating_agencies
The credit assessment may contain probability values (so-called score values). Insofar as score values are included in the result of the credit assessment, they have their basis in a scientifically recognized mathematical-statistic procedure. The calculation of the score values includes, inter alia, but not exclusively, address data. The information obtained on the statistical probability of a default shall be used by Klarna for a balanced decision on the grounds, implementation or termination of the contractual relationship.
You can revoke your consent at any time by sending a message to the controller or to Klarna. However, Klarna may continue to be entitled to process your personal data if this is necessary for contractual payment processing.
Your personal details will be provided in accordance with the applicable data protection regulations and according to the data in Klarnas data protection regulations for data subjects based in Germany https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de en/privacy
or for persons with registered office in Austria https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de at/privacy
treated.
- Paypal
For payment via PayPal, credit card via PayPal, direct debit via PayPal or – if offered – "purchase on account" or "rate payment" via PayPal, we will forward your payment details to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). The transfer takes place according to Art. 6 para. 1 lit. b GDPR and only insofar as this is necessary for payment processing.
PayPal reserves the right to carry out a credit card via PayPal, direct debit via PayPal or – if offered – "purchase on account" or "rate payment" via PayPal. For this purpose, your payment data may be processed in accordance with Art. 6 para. 1 lit. f GDPR on the basis of the legitimate interest of PayPal on the determination of your eligibility for payment passed on to information. The result of the credit assessment in relation to the statistical default probability uses PayPal for the purpose of deciding on the provision of the respective payment method. The credit assessment may contain probability values (so-called score values). Insofar as score values are included in the result of the credit assessment, they have their basis in a scientifically recognized mathematical-statistic procedure. The calculation of the score values includes, inter alia, but not exclusively, address data. Further data protection information, including the information used, can be found in the PayPal privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full
You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may remain entitled to process your personal data if this is necessary for contractual payment processing.
- Shopify Payments
We use the payment service provider "Shopify Payments", 3rd Floor, Europa House, Harcourt Building, Harcourt Street, Dublin 2. If you choose a payment method offered by the payment service provider Shopify Payments, the payment processing is carried out via the technical service provider Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, to which we provide your information communicated during the ordering process, including the information about your order (name, address, account number, bank code, etc.). Credit card number, invoice amount, currency and transaction number) according to Art. 6 para. 1 lit. b GDPR. Your data will be transferred exclusively for the purpose of payment processing with the Stripe Payments Europe Ltd. and only insofar as it is necessary for this purpose. For more information on the privacy of Shopify Payments, see the following web address: https://www.shopify.com/legal/privacy.
Data protection information on Stripe Payments Europe Ltd. can be found here: https://stripe.com/en/privacy

9) Use of Social Media: Videos

Use of YouTube videos

This website uses the YouTube embedding function to display and play videos from the provider “Youtube”, which is part of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).

The extended data protection mode is used which, according to provider information, only initiates the storage of user information when the video is reproduced. When the playback of embedded YouTube videos is started, the provider “Youtube” uses cookies to collect information about user behavior. According to “Youtube”, these are used, among other things, to capture video statistics, improve user-friendliness and prevent abuse. If you are logged in to Google, your data will be assigned directly to your account if you click on a video. If you do not wish to assign your profile to YouTube, you must log out before activating the button. Google stores your data (even for non-logised users) as user profiles and evaluates them. Such an evaluation is carried out in particular in accordance with Art. 6 para. 1 lit. f GDPR based on the legitimate interests of Google in the inclusion of personalized advertising, market research and/or demand-oriented design of its website. You have a right to object to the formation of these user profiles, with you having to direct yourself to YouTube in order to exercise it. As part of the use of Youtube, personal data may also be transmitted to the servers of Google LLC in the USA.
Regardless of a reproduction of the embedded videos, a connection to the Google network is recorded every time this website is accessed, which can trigger further data processing operations without our influence.

For further information on data protection at “Youtube” please see https://www.youtube.com/static?template=terms and Google’s privacy policy at https://www.google.de/intl/de/policies/privacy.

If legally required, we have your consent in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future. To exercise your revocation, disable this service in the "Cookie-Consent Tool" provided on the website.

10) Online Marketing

10.1 Google AdSense

This website uses Google AdSense, a web ad service Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google AdSense uses so-called. Cookies are text files that are stored on your computer and allow an analysis of your use of the website. In addition, Google AdSense also uses so-called to collect information. "Web-Beacons" (small invisible graphics) by which simple actions such as visitor traffic can be recorded, collected and evaluated on the website. The information generated by the cookie and/or web beacon (including your IP address) about your use of this website is usually transmitted to a Google server and stored there. This may also result in a transmission to the servers of Google LLC in the USA.

Google uses the information thus obtained to evaluate your usage behavior with regard to the AdSense displays. The IP address transmitted by your browser as part of Google AdSense is not merged with other data from Google. The information collected by Google may be transferred to third parties if this is required by law and/or if third parties process this data on behalf of Google.

The described processing of data is carried out in accordance with Art. 6 para. 1 lit. f GDPR for the purpose of the targeted commercial address of the user by third parties whose ads are displayed on this website on the basis of the evaluated user behavior. This processing also serves our financial interest in the exhaustion of the economic potential of our website through the free inclusion of personalized third-party acquisitions.

For further information on Google's privacy policy, see the following web address: https://www.google.de/policies/privacy/

You can permanently disable cookies for ad presets by preventing them by setting your browser software accordingly or you can download and install the browser plug-in available under the following link:
https://www.google.com/settings/ads/plugin?hl=de

Please note that certain functions of this website may not be used or may only be used to a limited extent if you have deactivated the use of cookies.

If legally required, we have your consent in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future. In order to exercise your revocation, please follow the possibility described above to make an objection.

10.2 Use of Google Ads Conversion Tracking

This website uses Google Ads' online advertising program and Google Ads' conversion tracking of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). We use the offer of Google Ads to draw attention to our attractive offers with the help of advertising media (so-called Google Adwords) on external websites. With regard to the data of advertising campaigns, we can determine how successful the individual advertising measures are. We therefore pursue the concern to show you advertisements that are of interest to you to make our website more interesting for you and to achieve a fair calculation of the advertising costs incurred.

The conversion tracking cookie is set when a user clicks on an ad that is connected by Google. Cookies are small text files that are stored on your device. These cookies usually lose their validity after 30 days and do not serve personal identification. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize that the user has clicked on the ad and has been forwarded to this page. Each Google Ads customer receives another cookie. Cookies cannot therefore be traced through the websites of Google Ads customers. The information collected using the conversion cookie is used to create conversion statistics for Google Ads customers who have opted for conversion tracking. Customers will learn the total number of users who clicked on their ad and were forwarded to a page provided with a conversion tracking tag. However, you do not receive information that allows users to identify personally. If you do not want to participate in tracking, you can block this use by disabling the Google Conversion Tracking cookie via your Internet browser under the keyword “user settings”. You will not be included in conversion tracking statistics. We use Google Ads on the basis of our legitimate interest in targeted advertising. Article 6(1)(f) GDPR. As part of the use of Google Ads, personal data may also be transmitted to the servers of Google LLC in the USA.

For further information on Google's privacy policy, see the following web address: https://www.google.de/policies/privacy/

You can permanently object to the setting of cookies by Google Ads Conversion Tracking by downloading and installing Google’s browser plug-in available under the following link:
https://www.google.com/settings/ads/plugin?hl=de

Please note that certain functions of this website may not be used or may only be used to a limited extent if you have deactivated the use of cookies.

If legally required, we have your consent in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future. To exercise your revocation, disable this service in the "Cookie-Consent-Tool" provided on the website or alternatively follow the above-described possibility to object.

11) Use of a live chat system

Tawk.to
On this website, tawk.to inc. 187 East Warm Springs Rd, SB298 Las Vegas, NV, 89119, USA, (www.tawk.to) collects and stores anonymized data for web analysis and to operate the live chat system to answer live support requests. Use profiles can be created from these anonymized data under a pseudonym. Cookies can be used for this purpose. Cookies are small text files that are stored locally in the buffer store of the website visitor's Internet browser. Cookies allow the Internet browser to be recognized.
The data collected with tawk.to technologies are not used without the separately granted consent of the data subject to personally identify the visitor of this website and not to merge with personal data about the carrier of the pseudonym. In order to avoid the storage of tawk.to cookies, you can set your Internet browser in such a way that no cookies can be stored on your computer in the future. already stored cookies are deleted. However, the shutdown of all cookies can cause some functions to no longer be executed on our websites. You can object to data collection and storage for the purpose of creating a pseudonymiz