We, The Cloakroom B.V. (below ‘The Cloakroom’ and ‘we’) take the security of your personal data very seriously, and strictly adhere to the regulations of data privacy laws. Personal information is collected on this website only for technical purposes. Moreover, personal data is only disclosed or transferred to third parties if this is necessary for the purpose of contract processing or if there is any other legal basis for passing on data. Collected data may not be sold or shared with third parties for any other purpose without legal permission.
The statement below provides an overview of how we ensure the security of data, and the purpose for which certain kinds of data are collected.
The contact person and the person responsible for the processing of your personal data within the context of the data protection laws is
The Cloakroom B.V.
Het Lentfert 51
7547 SN Enschede
Phone: +49 (30) 255 585 260
If you have any questions regarding data protection at The Cloakroom, please do not hesitate to contact our Data Protection Officer. This can be reached at the above postal address or by e-mail at email@example.com.
If you use our website or interact with our website (e.g. order a Cloakroom Box), personal data will be processed.
Personal data is information that relates to an identified or identifiable natural person. In particular, this includes information that enables us to identify you, such as your name, your telephone number, your address or e-mail address. A natural person who can be identified directly or indirectly is already considered identifiable.
Statistical data that we process for example when you visit our website and that cannot be directly linked to you do not fall under the term ‘personal data’.
The Cloakroom automatically processes information (e.g. in server log files) that your browser transmits to us when you visit this website.
* Browser type and version
* Operating system used
* Referrer URL (page you visited before)
* Hostname of the accessing computer (IP address)
* Time of server request
This data is not attributed to any particular person by The Cloakroom. This data will not be combined with any other sources of data, and will be deleted after being statistically evaluated, or anonymized according to privacy protection compliance.
The data processing is necessary so that you can inform yourself about the contents of The Cloakroom. Legal basis is Art. 6 para. 1, b) GDPR.
The Cloakroom is a very personal service provider. We collect data from our customers in order to continuously improve, and provide optimal service. For this purpose, we collect address data, and personal data such as clothing size and style preferences, as well as other similar information. We acknowledge that this data is sensitive and requires special protection. Therefore, we take every required effort necessary for the protection of this data.
In order to benefit from all the services offered by The Cloakroom, the user has to log in and provide the mentioned data. This data is required to use the products and services of The Cloakroom, such as when ordering a Cloakroom Box. It is also used to respond to enquiries, questions and complaints about our service. We process your data for the placing and managing of your order, inclusive of any potential warranty, for technical administration and for our own marketing purposes, as well as for selecting fitting outfits in your future orders. Legal basis is Art. 6 para. 1, b) GDPR.
In addition, data may be disclosed in connection with official inquiries, court orders and legal proceedings if this is necessary for legal prosecution or enforcement.
IP addresses (see section 2.1) will be deleted or made anonymous after seven days at the latest.
Data of logged in users or user accounts (see section 2.2) are used to store information for future orders for Cloakroom Boxes. As a company providing a personal service, we also learn from previous orders in order to be able to send you suitable outfits for you and your style in the future. If you have a user account with The Cloakroom, your data will therefore only be deleted when you approach us with the request for deletion.
To register for our newsletter a so-called double opt-in process is used, during which the user is required to confirm their subscription by clicking a link sent via a notification email, before they can receive their first newsletter from The Cloakroom. If you would like to receive the newsletter offered on the website, we require a valid e-mail address, as well as information which allows us to check whether you are indeed the owner of the provided email address, or that the owner consents to receiving the newsletter. We collect the name and surname of existing customers in order to personally address them. No further data is collected. The processing serves the sole purpose of sending you the newsletter and proving your registration. Legal Basis is Art. 6 para. 1, a.) GDPR. The permission to store this data as well as use it to send the newsletter can be withdrawn at any time via e-mail or post to the addresses listed in the ‘Contact’ section of the website, as well as by clicking the ‘unsubscribe’ link in every newsletter.
The Cloakroom would like to offer its clients the best possible solution to try on outfits in the comfort of their own home, without having to pay all the goods beforehand. In order to possibly approve the customer for the payment method 'invoice', The Cloakroom assigns a credit check to Alektum Group.
The credit agency receives the name, the date of birth and the address data of the client from The Cloakroom. In return the credit agency sends The Cloakroom a value concerning the probability of failure ('score') and, if existent, information about possible negative effects on the payment performance (e.g. an ongoing collection process) as well as stored address and identity information (e.g. 'identity checked'). Negative scores can prompt The Cloakroom to not offer certain payment methods or to demand a preauthorization (reservation) in the amount of €100 on the credit card before the actual purchase. Additional information concerning this topic can be found in our TERMS AND CONDITIONS under point 7.5. If you don’t wish to have a solvency check carried out, select 'credit card' as the payment method when you order. If you don’t wish to have a solvency check carried out, select ‘credit card’ as the payment method when you order.
For the score values, a forecast of future events is made on the basis of collected information and experience from the past. The calculation of the probability values is primarily based on the information stored at the credit agencies about an affected person. Based on the entries stored for a person and other data, they are assigned to statistical groups of persons who have had similar payment patterns in the past. The method used is called "logistic regression" and is a well-founded, mathematical-statistical method for predicting risk probabilities that has been tried and tested in practice for many years.
The Cloakroom thus transmits to The Alektum Group, Augustenstraße 79, 8033 München, Germany, personal data collected within the framework of contractual relationships about the application, the execution and termination of this business relationship as well as data about non-contractual behaviour or fraudulent behaviour. The legal basis for these transfers is Art. 6 para. 1 b.) and Art. 6 para. 1 f) GDPR. Transmissions on the basis of Art. 6 para. 1 letter f) GDPR may only take place if this is necessary to protect the legitimate interests of The Cloakroom or third parties and does not outweigh the interests or fundamental rights and freedoms of the person concerned, which require the protection of personal data. The data exchange with the Alektum Group also serves the fulfilment of legal obligations to carry out creditworthiness checks of customers (§ 505a and 506 of the BGB).
Alektum Group processes the data received and also uses them for the purpose of profile building (scoring) in order to provide its contractual partners in the European Economic Area and in Switzerland and, if necessary, other third countries (if an adequacy decision of the European Commission exists for these) with information, inter alia, for assessing the creditworthiness of natural persons. Further information on the activities of the Alektum Group can be viewed online at https://www.alektumgroup.de/%C3%BCber-die-alektum-group/datenschutz-und-cookies .
‘Persistent’ cookies are used, for example, to save your language so that you do not have to repeat this setting every time you visit our website. Persistent cookies are automatically deleted after a specified period, which can vary depending on the cookie.
The Cloakroom's analysis and advertising measures are also based on cookies (see section 8).
In order to improve our website, we use various technologies to analyse usage behaviour and evaluate the associated data. In addition, we draw attention to our services through online advertising measures. These processes are anonymous or using pseudonyms, but never personal. In the following section, we would like to explain these technologies and the providers used for them in more detail.
The legal basis is Art. 6 para. 1, f.) GDRP, based on The Cloakroom's legitimate interest in advertising the services and in analysing user behaviour to improve and further develop the website.
Google uses the information collected via Cookies to analyze the usage of our website, to create reports about the website activities for the website operators, and for further services related to the usage of the website and the internet. In addition, Google might share this information with third parties as far as they are legally bound to do so or as far as third parties are commissioned by Google to process this data. You can prevent the installation of Cookies with a specific setting in your browser software; however, doing so may limit the functionalities of some parts of the website.
Furthermore, you can prevent Cookies from collecting data regarding your usage of this website (including your IP-address) as well as the processing of this data by Google by downloading and installing this BROWSER PLUG-IN.
Alternatively to browser Plug-ins or within browsers on mobile devices, an OPT-OUT-COOKIE can also be set to block the collection of data by Google Analytics on this website during future visits (the Opt-Out will only be valid for this domain and this browser). When the Cookies are deleted in this browser, the Opt-Out has to be set up again.
You can prevent the installation of Cookies with a specific setting in your browser software; however, doing so may limit the functionalities of some parts of the website.
We offer the option to sign in to the The Cloakroom website using your existing Facebook profile. For this purpose, we use Facebook Connect, a service offered by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ‘Facebook’). In the event that personal data is transferred to the USA, Facebook has submitted to the EU-US PRIVACY SHIELD. If you intend to use the Facebook Connect function, you will first be redirected to Facebook. There you will be asked to sign in with your username and password. We do not register your login data. If you are already signed in to Facebook, this step will be skipped. Afterwards, your name, birthday and email address will be shared with us if you agree to this by confirming via the ‘Login with Facebook’ button. During the signup process on our website, you can optionally upload an image from Facebook to The Cloakroom to allow our stylists to provide a more personalized clothing selection. A permanent link between your user account and Facebook profile will be established.
Further information on data privacy and settings for protecting your privacy can be found in Facebook’s DATA POLICY section.
On our website remarketing-tags (so-called ‘Facebook-Pixel’) provided by Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA (‘Facebook’) are embedded. In the event that personal data is transferred to the USA, Facebook has submitted to the EU-US PRIVACY SHIELD. When you visit our website, using the re-marketing tags a connection is set between your browser and a Facebook server. Through this Facebook receives the information, that our website has been visited with your IP Address. Facebook uses this data to provide us statistical and anonymous information about the general use of our website as well as the efficiency of our Facebook-advertisement (‘Ads’). If you are registered at Facebook and you have allowed so in your personal Facebook Privacy Settings, Facebook will connect the information on your visit with your Facebook user account in order to provide targeted Facebook-Ads.
You can view and change the Privacy Settings in your Facebook profile at any time. If you deactivate the processing of your data via Facebook, Facebook will show Facebook-Ads which were not selected by the re-marketing tags. If you do not have a Facebook profile registered, you can also disable the overall data connection with Facebook by using external add-ons, e.g. Facebook Blocker.
You can view and change the AD PREFERENCES in your Facebook profile at any time. If you deactivate the processing of your data via Facebook, Facebook will show Facebook-Ads which were not selected by the re-marketing tags. You can also prevent data processing by pressing the following button:
Further information on data privacy and settings for protecting your privacy can be found in Facebook’s DATA POLICY SECTION.
We operate a Fanpage on the social network Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA ("Facebook") in joint responsibility in order to communicate, among others, with prospects and followers, and to impart information through our products and services.
In so doing, we are able to obtain from Facebook statistics on the use of our Fanpage (e.g. details on numbers, names, interactions, e.g. likes or comments, as well as summarised demographic and other information or statistics based on certain parameters about our company and the offers on our Fanpage that help us to find out more about the interaction with our site) through Facebook / Fanpage users. For more information on the nature and scope of these statistics, see the Facebook Site Stats & Tips, as well as information on the Agreement regarding Responsibilities in the Facebook Page Insights Supplement. The legal basis is art. 6 para. 1, b) GDPR.
On our website Social Media Plug-ins (e.g. the Like-Button) from Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA (‘Facebook’) are embedded. In the event that personal data is transferred to the USA, Facebook has submitted to the EU-US PRIVACY SHIELD. Facebook receives the information that you have visited the relevant page of our online-offers. This occurs independent of whether you have an account with Facebook or whether you are logged in. When you are logged in to Facebook, this data is directly collated with your account. When you click the activated button and e.g. link the sites together, Facebook saves this information including the time and date in your account and publicly shares it with your contacts. If you do not wish to connect your Facebook account this way, you have to log out before activating the button.
Facebook stores this data as a user profile and uses it for the purpose of advertising, market research and/or tailoring their website presentation and layout. An assessment as such is in particular carried out (also for not logged in users) for the presentation of tailored advertising and in order to inform other users about your activity on our site. You have the right to refuse the user profiling, as a Facebook user you can deactivate the ads based on social activities in your AD PREFERENCES. You can also completely block the loading of the Facebook Social Media Plug-Ins by using an external add-on in your browser, e.g. Facebook Blocker.
Further information on data privacy and settings for protecting your privacy can be found in Facebook’s DATA POLICY SECTION.
This website uses Hotjar, a web analytics service by Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe (‘Hotjar’) in order to improve the user experience by analysing user behaviour on our website.
Hotjar uses the information collected via Cookies to analyse the usage of our website, to create reports about the website activities for the website operators, and to provide further services related to the usage of the website and the internet.
You can prevent the installation of the Cookie with the relevant setting in your browser software; however, doing so may limit the functionalities of some parts of the website. You can block the collection of data by Hotjar during future visits by setting an OPT-OUT COOKIE (the Opt-Out will only be valid for this domain and this browser). When the Cookies are deleted in this browser, the Opt-Out Cookie has to be set up again.
This website uses MATOMO, an open source web analytics service published under the GNU General Public License (‘Matomo’). Matomo uses a Cookie to analyze websites in regard to user behavior. The Cookie, which is stored on your computer when visiting our website, also stores and transfers your shortened IP address. That means that IP addresses are anonymized when data is transferred to our server so that we cannot identify visitors to our website. Only we will have access to the usage data transferred to us via the Cookie and this data will not be transferred to third parties. The sole purpose of this analysis is to optimize and further develop our web presence.
You can prevent the installation of the Cookie with the relevant setting in your browser software; however, doing so may limit the functionalities of some parts of the website. In addition, you can also block the recording of data generated by the Cookies and by the general use of this website (incl. IP-addresses) as well as block the processing of this data by enabling the button below. Your browser will enable an opt-out Cookie that blocks Matomo from generating usage data in the future. Please note that after deleting all Cookies in your browser, or if you use a different browser and/or profile a new opt-out Cookie has to be set. You can re-activate the opt-out Cookie in your browser, by clicking this button again.
You may choose not to have a unique web analytics cookie identification number assigned to your computer to avoid the aggregation and analysis of data collected on this website.
To make that choice, please click here and then select the Matomo opt-out cookie button.
Further information on data privacy can be found in the WEB ANALYTICS PRIVACY in Matomo.
This website uses exactag, a web analysis service of Exactag GmbH, Philosophenweg 17, 47051 Duisburg, Germany ('exactag'). Exactag collects and stores data on this website and its subpages for marketing and optimisation purposes. Cookies and so-called browser fingerprints can be used to create user profiles from this data. Fingerprint technology stores Internet browser environment variables in a database without directly storing user-related data such as an IP address. The cookies and/or the fingerprint enable the recognition of the Internet browser. The data collected with exactag technologies will not be used to personally identify the visitor to this website.
You can prevent the collection of data generated by cookies and fingerprints and related to your use of this website and the processing of this data by exactag by setting an opt-out cookie (the opt-out only works in the browser and only for this domain). If you delete your cookies in this browser, you must click this link again.
Our website uses interest-based online advertising to make our offer more interesting and more fitting to you. We employ so-called retargeting technologies, which allow us to address previous visitors to our site who have shown interest in our products via advertising on our partners’ websites based on Cookies. We only collect anonymized and alias data during this process. No personal data will be stored nor user profiles created with your personal data – if it’s available. If you do not wish to receive interest-based advertising, in addition to the possibilities of consent refusals mentioned in this data privacy statement, you can opt out with the relevant settings on HTTP://PREFERENCES-MGR.TRUSTE.COM/, where bundled disagreement forms for advertisers are available. TRUSTe, Inc, 835 Market Street, San Francisco, CA 94103-1905, USA (‘TRUSTe)’s website provides the option to deactivate all advertising at once with the help of opt-out Cookies or to alternatively make individual setting per provider. Please note that after deleting all Cookies in your browser, or if you use a different browser and/or profile a new opt-out Cookie has to be set.
Finally, we use various technologies on our website to enable our customers to interact socially, offer additional functions and facilitate further development. In the following section, we would like to explain these technologies and the providers used for them in more detail.
The legal basis is Art. 6 para. 1, f.) GDPR, based on The Cloakroom’s legitimate interest in creating opportunities for interaction and effective development and improvement of the website.
This website uses the services of Zenloop GmbH, Brunnenstr. 196, 10119 Berlin ("zenloop") for customer feedback (collection and analysis). The legal basis is Art. 6 Para. 1, f.) GDPR.
If you have decided to participate in customer feedback and no longer wish to do so, you can object to further processing by contacting us.
Upon request, we will inform you whether and which data about you is stored by us. If the legal requirements are met, you also have the right to correct, restrict the processing or delete the data. You also have the right to receive the data concerning you that you have provided to us in a structured, common and machine-readable format. To assert these rights, please contact the above-mentioned contact details. This also applies if you wish to receive copies of guarantees to prove an adequate level of data protection or if you wish to object to the processing of your data as a whole or for individual measures in accordance with this data protection notice.
You can also make corrections to your personal data directly via our website under ‘My Cloakroom’.
Finally, you have a right of appeal to the responsible supervisory authority for data protection if you believe that the processing of personal data concerning you violates data protection laws. You may exercise this right before a supervisory authority in the Member State in which you are resident, in your place of work or in the place where the alleged infringement is committed.
Date: November 2018