Effective as of December 20th, 2021
1. Contact details of the controller and the data protection officer
1.1 This data protection information applies to data processing by the controller, within the meaning of the General Data Protection Regulation (GDPR): Avea Life Ltd, 85 Great Portland Street, 1st Floor, London, W1W 7LT, United Kingdom, Email: email@example.com, Internet: https://avea-life.com/. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
1.2 All interested parties and visitors to our website reach our data protection officer at: firstname.lastname@example.org
1.3 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.
2. What personal data do we collect?
We collect the following types of personal data from you:
- A) Contact information – Such as name, email address, address, phone number.
- B) Data we collect when you are visiting our website – Such as IP address of the requesting device, date and time of access, name and URL of the retrieved file, website from which access is made (referrer URL), used browser and if applicable, the operating system of your computer as well as the name of your access provider.
- C) Marketing data – Such as the device you are browsing from, its operating system, and browsing behavior on the website.
- D) Payment data - Such as credit / debit card information, IBAN, BIC, currency, billing address, shipping address.
3. How do we collect your personal data?
We collect your personal data in the following ways:
- When you sign-up for our Service and for contract processing - When you sign up for our Service, we collect certain personal data such as name, address and email address. Which data is collected can be seen from the respective input forms.
- Through the use of our Service - When you use ourService, we collect personal data about your use of it such as frequency of use and time of access.
- When you contact us - When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form or e-mail conversation. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration.
- From third-parties - We receive personal data about you and your activity from third-parties, including advertisers and partners we work with. We will use this personal data either where you have provided your consent to the third-party or to us. Data sharing is taking place where we have a legitimate interest to use the personal data in order to provide you with our service.
4. What do we use your personal data for?
We may use your personal data for the following purposes (“Processing Purposes”):
Type(s) of personal data
To provide you with products and services you have requested, to fulfill our contract, for the purpose of order handling
Type A, B, C, D
To manage and operate our websites and applications, including online registration
Type A, B, C
For troubleshooting and repairing purposes
Type A, B, C
To communicate with you, either directly or through one of our partners about marketing, research, surveys and promotional purposes
Type A, C
To provide you with administrative notices such as user guidance/ product safety notices relating to your appliance, service or account
Type A, C
Internal business purposes, including security, analytics, audit, and for our core operational activities
Type A, B, C
To evaluate your feedback when you rate and review our products or services
Type A, B, C
If we process your data to protect legitimate interests, you may object to such processing by contacting email@example.com, free of charge at any time.
Third-party service providers
Transfer to other countries
Service providers who process personal data on our behalf outside of the UK or the European Union (so-called third countries) are only used if there is an adequacy decision by the European Commission or appropriate or appropriate guarantees to the recipient for that third country, such as the EU-US Privacy Shield.
5. Cookies and similar technologies
When you visit our website, we store information on your computer in the form of cookies. Cookies are small files that are transferred from an internet server to your browser and stored on your hard disk. In the cookie information is stored, each resulting in connection with the specific terminal used. However, this does not mean that we are immediately aware of your identity.
The data processed by cookies are for the purposes mentioned to protect our legitimate interests as well as the third party pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR required.
6. Marketing Tools
We are using Klaviyo (Klaviyo Inc., 125 Summer Street, Floor 6, Boston, MA, 02110, United States) for the purposes of sending you personalized emails to keep you informed about our product and services. To ensure that you are the owner of the specific email address, we are using the so-called double opt-in method. This means, we will only send you newsletters by email if you have confirmed your email address by clicking on a notification link. If you confirm your email address, the registration data, the time of registration and the IP address used for registration will be saved until you unsubscribe from the newsletter. The storage serves the purpose to send you the newsletter and to prove your registration.
On the website, we offer you the opportunity to subscribe to our personalized email newsletter, where we regularly inform you about news about our products and promotions. When subscribing to the newsletter, certain information is collected, such as your email address (required), first name, last name (optional). We use the so-called double opt-in method, i.e. we will only send you newsletters by email if you confirm by clicking on a link in our notification email that you are the owner of the specified email address. If you confirm your email address, the registration data, the time of registration and the IP address used for registration will be saved until you unsubscribe from the newsletter. The storage serves the purpose to send you the newsletter and to prove your registration. This is a legitimate interest within the meaning of the legal basis of this processing (Art. 6 para. 1 lit a GDPR). The provision of your personal data is voluntary. The legal basis for sending our newsletter to your email address is, in principle, your consent (Art. 6 para. 1 lit a GDPR). Insofar as you participate in a raffle organized by us and register for the purpose of concluding the contract for the raffle in return for our newsletter, the legal basis for the dispatch of our newsletter is the fulfillment of the contract (Art. 6 para. 1 lit. b GDPR). In cases in which we use the advertising use of your data as consideration in return for a participation in the competition, we clearly state this in the terms and conditions for the conclusion of the contract. You can unsubscribe from the newsletter at any time. A corresponding unsubscribe link can be found in every newsletter. Alternatively, you can also send your unsubscribe request to firstname.lastname@example.org by email. We also use technologies in our newsletter that allow us to evaluate your use of the newsletter (such as opening the email, clicking links). This is done with the help of small graphics that are embedded in the newsletter (so-called pixels). The data is collected exclusively pseudonymized and also not linked with your other personal information.
The purpose of the processing is to produce general statistical evaluations as well as to optimize and develop our content and customer communication. Through our newsletter, we want to share content relevant to our customers and better understand what readers are actually interested in. This is a legitimate interest within the meaning of the legal basis of this processing (Art. 6 para. 1 lit f GDPR). If you do not wish to analyze your usage behavior, you can click on this link or disable graphics in your email program by default. The data for your use of the newsletter is stored pseudonym for 30 days and then completely pseudonymized.
Advertising by Post
Based on our legitimate interest in personalized direct mail, we reserve the right to store your first and last name, your postal address and - if we have received this additional information from you within the framework of the contractual relationship - your title, academic degree, year of birth and your professional, industry or business name in accordance with Art. 6 (1) point f GDPR and to use this data for sending interesting offers and information on our products by letter post.
You can object to the storage and use of your data for this purpose at any time by sending an appropriate message to the controller.
We use HotJar (Level2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta) to record anonymous user session and for the purpose of site analysis and optimization. No personally identified user data is captured or stored by this service.
We have integrated Google AdWords on this site. Google AdWords is an Internet advertising service that allows advertisers to run both Google and Google Network search engine results. Google AdWords allows an advertiser to pre-set keywords that will display an ad on Google's search engine results only when the search engine retrieves a keyword-related search result. On the Google Network, ads are distributed to topic-related sites using an automated algorithm and according to pre-defined keywords. The operating company for the services of Google AdWords is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, USA.
The purpose of Google AdWords is to promote our site by displaying interest-based advertising on third-party websites and in the search engine results of Google's search engine, and by displaying third-party advertisements on our site. If an affected person reaches our website via a Google ad, a so-called conversion cookie will be placed on Google's information technology system by Google. The data and information collected through the use of the conversion cookie is used by Google to provide visitor statistics for our website. These visit statistics are then used by us to determine the success or failure of each AdWords ad and to optimize our AdWords ads for the future.
We make use of the services of Taboola, Inc., 1115 Broadway, 7th Floor, New York, NY 10010, USA., which provides a remarketing feature. This allows users of our website and other websites using Taboola‘s services to display interest-based ads.
Link to Opt-Out: https://www.taboola.com/privacy-policy#user-choices-and-optout
We are using Taboola, a platform to purchase media which provides display advertising space.
We make use of the services of Outbrain Inc., 39 West 13th Street, 3rd floor, New York, NY 10011, USA which provides a remarketing feature. This allows users of our website and other websites using Outbrain’s services to display interest-based ads.
This link also includes an opt-out option.
Customer Review Tools
Our website uses customer rating tools by Junip Inc. (1809 - 1 Victoria Street South Kitchener, ON N2G 1C2, Canada) and Trustpilot A/S (Pilestraede 58, 5th floor, DK-1112 Copenhagen K). Following your order, we would like to ask you to evaluate and comment on your purchase with us.
We will write to you for this purpose via email, making use of the technical system of the provider of the customer rating tool in processing the order.
As part of this, your data is processed either with your consent or on the basis of our legitimate interests.
Processing is carried out on the basis of Article 6(1)(a) GDPR with your consent, insofar as you have expressly consented to the receipt of feedback requests. You can withdraw your consent at any time using the corresponding link in the email, without affecting the legality of the processing carried out with your consent up to the withdrawal. Your email address will then be removed from the distributor.
Processing is carried out without your express consent on the basis of Article 6(1)(f) GDPR due to our justified interest in truthful, verified evaluations of our services as part of direct advertising. For this purpose we send you a feedback request electronically for our own goods or services which you have already purchased from us. Emails are sent to the address that we obtained from you in the course of selling a good or service. The sending of feedback requests is subject to the proviso that you have not objected to the use of your email address.
You can object to this at any time by notifying us. You can also use the link provided in the feedback request.
Data collection when you post a comment
When you comment on an article or a contribution, we collect your personal data (name, email address, comment text) only in the scope provided by you. The processing serves to allow you to comment and to display comments. By submitting the comment you agree to the processing of the transmitted data. The processing will be carried out on the basis of art. 6 (1) lit. a GDPR with your consent. You can withdraw your consent at any time by contacting us without affecting the legality of the processing carried out with your consent up to the withdrawal. Your personal data will then be deleted.
On publication of your comment only the name you have entered will be published.
7. Analytics tools
In order to constantly improve our content and adapt it to the interests of our users we use tracking measures (e.g. frequency of visits, increase of page views) based on Art. 6 para. 1 sentence 1 lit. f GDPR. Our service providers are not themselves responsible for data protection purposes, they always process the pseudonymised user data according to instructions, based on a data processing agreement. You can deactivate the individual analysis services at any time for the future. Below you can find details about the analysis services we use.
Google Tag Manager
We use Google Tag Manager on our website. This is a service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, hereinafter referred to as "Google"). The Google Tag Manager enables us to manage so-called website tags via a dashboard and does not itself collect any personal data.
We use Google Analytics, a web analytics service provided by Google Inc., for the purpose of designing and continuously optimizing our pages www.google.com/intl/en/about (1600 Amphitheater Parkway, Mountain View, CA 94043, USA, hereafter "Google"). ). In this context, pseudonymised usage profiles are created and cookies are used. The information generated by the cookie about your use of this website such as:
- Browser type / version,
- used operating system,
- Referrer URL (the previously visited page),
- Host name of the accessing computer (IP address),
- Time of server request,
All information is transmitted and stored on Google servers in the US. For the US, there is a European Commission adequacy decision (EU / US Privacy Shield) under which Google is certified. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage for the purposes of market research and tailor-made website design. This information may also be transferred to third parties if required by law or if third parties process this data in the order. Under no circumstances will your IP address be merged with any other data provided by Google. The IP addresses are anonymized, so that an assignment is not possible (IP masking).
You can prevent the installation of cookies by setting the browser software accordingly; however, we point out that in this case not all features of this website may be fully exploited. In addition, you may prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on.
For further information about privacy related to Google Analytics, see the Google Analytics Help Center.
Facebook conversion pixel
We use the "conversion pixel" or visitor action pixel from Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook”) to track the effectiveness of Facebook ads for statistical and market research purposes. By calling this pixel from your browser, Facebook can see whether a Facebook ad was successful. For this we receive exclusively statistical data from Facebook without reference to a specific person. In particular, if you are logged in to Facebook, we also refer to their privacy information. Please click here if you wish to revoke your consent to conversion pixels. Alternatively, you can disable the Facebook Pixel on the Digital Advertising Alliance page at the following here.
8. Processing of Data for the Purposes of Order Handling / Miscellaneous
We work with certain service providers, for example in the area of customer service (e.g. hotline service providers such as Zendesk (Zendesk Inc, 1019 Market Street, San Francisco, CA 94103, USA)), with technical service providers (e.g. running computer centres), with logistics companies (e.g. postal companies such as DHL, FedEx) and payment providers (e.g. Paypal). Where we use them to process orders, the service providers only receive access to your data in the scope and for the time period required for provision of the relevant service.
8.1 Passing on Personal Data to Shop System Provider
We use an enterprise resource planning system for order processing. For this purpose, your personal data collected in the context of the order is transmitted to Shopify Inc, 150 Elgin Street, Suite 800, Ottawa, ON K2P 1L4, Canada.
8.2 Passing on Personal Data to Shipping Service Providers
For the purposes of order handling the personal data collected by us will be passed on to the transport company commissioned with the delivery within the scope of contract processing, insofar as this is necessary for the delivery of the goods.
We pass on your e-mail address to the shipping company as part of the contract processing. The purpose of the transfer is to inform you by e-mail about the shipping status. The processing is based on Art. 6 para. 1 lit. a DSGVO with your consent. Otherwise, only the name of the recipient and the delivery address will be passed on to the shipping company for the purpose of delivery in accordance with Art. 6 (1) point b GDPR. The data will only be passed on if this is necessary for the delivery of the goods. You may revoke your consent at any time by notifying us or the shipping company, without affecting the lawfulness of the processing carried out on the basis of the consent until revocation.
8.3 Use of Payment Service Providers
We will pass on your payment data to the commissioned credit institution within the framework of payment processing, if this is necessary for payment handling. If payment service providers are used, we explicitly inform you of this below. The legal basis for the transfer of data is Art. 6 (1) point b GDPR.
If you choose a payment method of the payment service provider Shopify, payment is processed by the payment service provider Shopify Inc., 150 Elgin Street, Suite 800, Ottawa, ON K2P 1L4, Canada, to whom we send your order information and payment data in accordance with Art. 6 (1) point b GDPR. Your data will only be passed on for the purpose of payment processing with the payment service provider Shopify and only to the extent necessary.
When you pay via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "payment by instalments" via PayPal, we transmit your payment data 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 in accordance with Art. 6 (1) point b GDPR and only insofar as this is necessary for payment processing.
We also use the PayPal Express payment service of PayPal (Europe) S.à.r.l. et Cie, S.C.A. (22-24 Boulevard Royal L-2449, Luxembourg; "PayPal").
PayPal reserves the right to carry out credit checks for the payment methods credit card via PayPal, direct debit via PayPal or, if offered, "purchase on account" or "payment by installments" via PayPal. For this purpose, your payment data may be passed on to credit agencies on the basis of PayPal's legitimate interest in determining your solvency pursuant to Art. 6 (1) point f GDPR. PayPal uses the result of the credit assessment in relation to the statistical probability of non-payment for the purpose of deciding on the provision of the respective payment method. The credit report can contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on recognized scientific, mathematical-statistical methods. The calculation of the score values includes, but is not limited to, address data. For further information on data protection law, including the credit agencies used, please refer to PayPal's data protection declaration at: https://www.paypal.com/uk/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 still be entitled to process your personal data if this is necessary for contractual payment processing.
The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. Our security is subject to constant improvement and our privacy policies are constantly being revised. Please make sure you have the latest version.
10. Personal data retention
We store personal data only as long as we are entitled to do so and the processing purpose is not eliminated. For the duration of storage of personal data, the respective statutory retention period applies. After the deadline, the corresponding data will be routinely deleted, if they are no longer required to fulfill the contract or to initiate a contract.
11. Your rights
Information and correction
You can receive information from us at any time free of charge if personal data about you are processed by us and also concretely which data about you are stored as well as a copy of the stored data. You can also correct and complete incorrect data.
Deletion, restriction and the right to be forgotten
You can request that we temporarily or permanently stop processing all or some of your personal data or in accordance with Art. 17 GDPR, demand the deletion of your personal data stored by us.
You have the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.
Right to object
You can withdraw your consent at any time and also have the right to object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights. You can submit these requests by email to email@example.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
Right to complain to supervisory authority
You also have the right of appeal to the competent supervisory authority as well as the possibility of seeking legal remedies.