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puretrail UG

Puretrail GmbH (Tobias Krumm)
Schreibershove 13
51503 Rösrath
GERMANY

info(at)puretrail.com
info(at)skinprotec.com

VAT ID: DE3130839900
Commercial Court: Köln / GERMANY

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This Privacy Notice complies with Data Protection Legislation. It serves as a notice for those visiting and using the website http://www.puretrail.de It notifies the users about the personal data that the company holds relating to their experience in the website, for what purpose it is processed and for how long it is expected to be used.

INTRODUCTION
Welcome to Puretrail AG’s website’s privacy notice.  We respect your privacy and we are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Please use the glossary, at the end of this privacy notice, to understand the meaning of some of the terms used in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE 
PURPOSE OF THIS PRIVACY NOTICE  

This privacy notice aims to give you information on how Puretrail AG collects and processes your personal data through your use of this website, including any data you may provide when you open an account on the website or when you voluntarily provide information to us.  This privacy notice is intended for those making use of this website. This website is not intended for children and we do not knowingly collect data relating to children.  It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
 
CONTROLLER 
Puretrail AG is the controller and responsible for this website, and is referred to as the “Company”, “we”, “us” or “our” in this privacy notice. We will let you know which entity will be the controller for your data when you purchase a product or service with us.  We have appointed a data protection lead (DPL) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPL using the details set out below.

CONTACT DETAILS 
Full name of legal entity: Puretrail AG  DPL: Crispian Knight, email: cknight@puretrail.de  Address: Am Brücker Bach 31, 51427 Bergisch Gladbach, Germany.
 
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES 
This version was last updated on May 2019 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
 
THIRD-PARTY LINKS 
This website includes links to third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU 
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
  • Identity Data includes first name, last name and User ID.
  • Contact Data includes delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, location data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • We do not collect any Special Categories of Personal Data about you. Nor do we collect any information about criminal convictions and offences.
 
IF YOU FAIL TO PROVIDE PERSONAL DATA 
Where we need to collect personal data by law, or under the terms of a contract and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with information related to your query).

HOW IS YOUR PERSONAL DATA COLLECTED? 
We use different methods to collect data from and about you including through:
  •  Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
    - Open an account;
    - Contact us through our contact form.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
    - Technical Data from the following parties: a) analytics providers; b) advertising networks; and c) search information providers.
    - Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    - Identity and Contact Data from data brokers or aggregators.

HOW WE USE YOUR PERSONAL DATA 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
Go to the glossary at the end to find out more about the types of lawful basis that we will rely on to process your personal data. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting our DPL.
 
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA 
 
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
 
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 _______________________________________________________________

1. Purpose/Activity: To send us a message
Type of data: (a) Identity, (b) Contact
Lawful basis for processing including basis of legitimate interest:
>> Performance of a contract with you

2. Purpose/Activity: To manage our relationship with you which will include notifying you about changes to our terms or privacy policy  
Type of data:(b) Contact, (c) Communications,
Lawful basis for processing including basis of legitimate interest:
>> a) Performance of a contract with you
>> b) Necessary to comply with a legal obligation

3. Purpose/Activity: To administer and protect our business and this portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity, (b) Contact, (c) Technical
Lawful basis for processing including basis of legitimate interest:
>> a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
>> b) Necessary to comply with a legal obligation

4. Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data: (a) Identity, (b) Contact, (c) Usage, (d) Marketing and Communications, (e) Technical
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

5. Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data: (a) Technical, (b) Usage
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

6. Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data: (a) Identity, (b) Contact, (c) Technical, (d) Usage
Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to develop our products/services and grow our business)

_______________________________________________________________
 
MARKETING 
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may change your preferred choice of how to receive our marketing material by contacting our DPO.
 
PROMOTIONAL OFFERS FROM US 
We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
 
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
 
COOKIES   (Optional)
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

CHANGE OF PURPOSE 
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our DPL.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 
DISCLOSURES OF YOUR PERSONAL DATA 
We may have to share your personal data with the parties set out below for the purposes set out in the table in the section above.
  • External Third Parties as set out in the glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
 
DATA SECURITY 
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 
DATA RETENTION 
HOW LONG WILL YOU USE MY PERSONAL DATA FOR? 
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.  In some circumstances you can ask us to delete your data: see Request erasure in the glossary below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
 
YOUR LEGAL RIGHTS 
Under certain circumstances, you have rights under data protection laws in relation to your personal data which are listed below.
  • Request access to your personal data.
  •  Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.
Further information about each right is available in the glossary below. If you wish to exercise any of the rights set out above, please contact our DPL.
 
NO FEE USUALLY REQUIRED 
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
 
WHAT WE MAY NEED FROM YOU 
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
 
TIME LIMIT TO RESPOND 
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
 
GLOSSARY 
PERSONAL DATA
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

LAWFUL BASIS 
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our DPO.
 
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
 
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
 
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
 
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
 
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
 
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
 
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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 consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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