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DATA PRIVACY STATEMENT

We, Curated Shopping GmbH (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.

1. Contact

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.

Reguliersdwarsstraat 50

1017 BM Amsterdam

Phone: +31 (0) 20 82079 00

E-Mail: contact@thecloakroom.dk

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 privacy@curated-shopping.com.

2. Processing of personal data

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’.

2.1 Data processing when visiting this website

The Cloakroom automatically processes information (e.g. in server log files) that your browser transmits to us when you visit this website.

These are:

  • 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) DSGVO.

2.2 Data of logged in users

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) DSGVO.

3. Passing on of data to third parties

The data collected by us will only be passed on if this is necessary for the purpose of contract processing or if there is another legal basis for passing on data. Part of the data processing can be carried out by our service providers. In addition to the service providers mentioned in this privacy policy, this may include data centers that store our website and databases, IT service providers that maintain our systems, and consulting firms. If we pass on data to service providers, they may use the data exclusively for the fulfilment of their tasks. The service providers have been carefully selected and commissioned by us. They are contractually bound by our instructions, have appropriate technical and organisational measures in place to protect the rights of the persons concerned and are regularly monitored by us.

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.

4. Storage and deletion

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.

5. Newsletter

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.) DSGVO. 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.

6. Solvency check

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. 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. The legal basis for the credit agencies' solvency check is Art. 6 para. 1, f.) DSGVO, on the basis of The Cloakroom's legitimate interest in protection against non-payment.

In order to avoid fraudulent behaviour, we furthermore use the Services of a co-operation between SCHUFA and Risk.Ident GmbH, Am Sandtorkai 50, 20457 Hamburg (hereinafter: Risk.Ident). Risk.Ident processes within a time framework of the co-operation with SCHUFA, and with the help of cookies and other tracking technologies, data for determining the device used by the user and further data regarding the use of the website. An assignment to a specific user is not made. As far as IP addresses are collected, an immediate encipherment takes place. The data is collected by Risk.Ident as part of the co-operation with SCHUFA in a fraud prevention database. In the database, data transmitted by ourselves is also stored to devices which are already suspected of fraudulent behavior. In this respect, no assignment is made to certain users. In the course of a registration or ordering process on our website, we call the database for a risk assessment to the device as well as further parameters to the identification of the device.

The algorithm for risk assessment is created by SCHUFA and is constantly being further developed. Technical processing is carried out between ourselves and Risk.Ident. The risk assessment of a fraudulent attempt takes into account such things as, whether the device has a frequently changing geo-reference, how many transactions have been made via the device and also whether a proxy connection is being used.

If a risk assessment should not be carried out during the scope of co-operation to the device, it can be disagreed to and the creation of the risk assessment will be deactivated on the following link for the respective device: https://www.dev-secu.de/opt-out. The legal basis for the fraud check by Risk Ident and SCHUFA is Art. 6 Para. 1, f.) DSGVO, based on The Cloakroom's legitimate interest in protection against abusive orders and non-payments.

7. Cookies

For some of our services it is necessary that we use so-called cookies. A cookie is a text file that is stored either temporarily ('session cookie') or permanently ('persistent' cookie) on the hard disk. Cookies are not used to run programs or download viruses onto your computer. The main purpose of cookies is rather to provide you with an offer tailored to your needs and to make the use of the service as time-saving as possible. Most browsers are set to accept cookies by default. However, you can change your browser so that it rejects cookies or requires confirmation from you beforehand. If you refuse cookies, not all of our offers can function without any errors for you.

We use cookies to customize and optimize your online experience. We mainly use 'session cookies' which are deleted when the browser is closed. Session cookies are used for login authentication and load balancing.

‘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).

8. Analysis and advertising measures

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.) DSGVO, based on The Cloakroom's legitimate interest in advertising the services.

8.1. Google Analytics

This website uses Google Analytics, a web analytics service by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (‘Google’). Google Analytics uses Cookies to analyze websites for user behavior. Information generated by Cookies regarding the usage of this website is transferred to a server by Google in the USA where it is stored. In the event that personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield. IP addresses are shortened before any analysis of user statistics so that no conclusions about user identity can be drawn. To ensure the collection of IP-addresses is anonymous, Google Analytics has been extended by the code ‘anonymizeIp’ on our 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.

More information on data protection can be found in the Data Privacy and Security from Google Analytics and the Privacy Policy from Google.

8.2. Google AdWords Conversion-Tracking

This website uses Google AdWords Conversion-Tracking, a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (‘Google’). Using this service the efficiency of the provided advertising (so-called AdWords-Campaigns) is measured. Through the analytics program Google can assess the performance of the provided ads better, and Google as well as us as a customer of Google, can improve the quality and relevance of the ads you are seeing. Google AdWords Conversion-Tracking uses Cookies. Information generated by Cookies for this analysis is transferred by Google to a server in the USA and there stored. In the event that personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield. The Cookies are in general active for 30 days on your computer. If you visit our website during this time period, Google and we will be informed that you have seen the provided advertisement.

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.

More information on data privacy can be found on the Google Privacy Policy.

8.3. Google remarketing

This website uses the remarketing- or ‘similar audiences’- feature provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (‘Google’). By using this feature, the provider can address visitors of the site with targeted advertising by showing personalized, content-related ads, when they visit other websites on the Google Display Network. In the event that personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield. Google uses cookies to perform the analysis of the website usage, which builds the basis for the creation of the interest-related advertisements. For this purpose, Google stores a small file with a sequence of numbers in the browsers of the visitors to the website. Visits to the website and anonymous data through the use of the website are stored within this number. There is no retention of personal data of visitors to the website. When visiting a different Google Display Network page, advertising ads are shown, which are highly likely to include previously accessed product and information areas. You can permanently disable the use of cookies by Google, by following the link below and downloading and installing the plug-in provided. As an alternative to the browser plug-in or within browsers on mobile devices, you can disable the ‘Personalized Advertising’ option in Google Advertising Settings. In this case, Google will only display general advertising that has not been selected based on the information collected about you.

More information on data privacy can be found on the Google Privacy Policy.

8.4. Facebook Connect

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.

8.5. Facebook Pixel

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:

CUSTOM OPT-OUT

Further information on data privacy and settings for protecting your privacy can be found in Facebook’s Data Policy section.

8.6. Facebook Social Media Plug-ins

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.

8.7. Hotjar

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.

Further information on data privacy can be found on Hotjar’s Privacy Policy page.

8.8. Matomo

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.

Further information on data privacy can be found in the Web Analytics Privacy in Matomo.

8.9. Interest-based online advertising

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.

8.10. Exactag

Exactag GmbH collects and stores data on this website and its subpages for marketing and optimisation purposes. From this data user profiles can be created. For this purpose, cookies and a technique that is called fingerprint can be used. Cookies are small text files that are stored locally in the cashe of the visitor’s web browser. The fingerprint technology stores environment variables of the Internet browser in a database, without storing user-related data such as an IP address. Cookies and/or fingerprints allow for the recognition of the Internet browser. The data collected by the Exactag technology is, without the explicit consent of the person concerned, not used to identify the user personally nor aggregated with any personal data. To ensure this exclusion from data storage, a cookie is set in your browser. This cookie is named "optout" and is set by "exactag.com". It may not be deleted as long as the storage of the data is contradicted. If you want to object to the storage of your anonymously collected visitor data for the future, please click this LINK.

9. Your rights

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: Mai 2018

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