Privacy

Contents

• 1. Name and Contact Details of the Person in Charge of Data Processing
• 2. Collecting and Storing Personal Data and the Nature and Purpose of its Use
• 3. Disclosing Data
• 4. Cookies and Web Beacons
• 5. Analytic Tools
• 6. Advertising and Marketing Tools
• 7. Social Media
• 8. Use of AddToAny
• 9. Store Evaluation Systems
• 10. Google Maps
• 11. User Rights
• 12. Right of Objection
• 13. Data Security
• 14. Validity and Modification of this Privacy Policy

1. Name and Contact Details of the Person in Charge of Data Processing

This privacy statement applies to data processed by:

Edeloptics GmbH Straßenbahnring 19a 20251 Hamburg Germany

Telephone: +44 330 818 6761 Fax: +49 40 689878-828 Email: info@edel-optics.co.uk

You can reach the company’s data protection officer at the address above or by email to datenschutz@edel-optics.co.uk.

2. Collecting and Storing Personal Data and the Nature and Purpose of its Use

a) Visiting the website

On visiting our website at www.edel-optics.co.uk, information is automatically sent to our website server via your chosen browser. This information is temporarily stored in a log file. The following information is collected and stored until it is automatically deleted, without any action required on your part: - your computer’s IP address; - the access time and date; - the name and URL of the selected file; - the website used to access our site (referrer URL); - the browser used, along with your computer’s operating system and the name of your access provider, if applicable.

The specified data are processed for the following purposes:

• to ensure a smooth connection setup for the website;
• to ensure convenient use of our website;
• to evaluate system security and stability; and
• for other administrative purposes.

The legal basis for data processing is Article 6, paragraph 1, point (f) of the General Data Protection Regulation (GDPR). Our legitimate interest entitles us to collect data for the above-listed purposes. Under no circumstances do we use collected data to draw conclusions about you.

b) Signing up to our newsletter

If you have expressly provided consent in accordance with Article 6, paragraph 1, point (a) of the GDPR, we will use your email address to send you our newsletter on a regular basis. For receipt of the newsletter disclosure of an email address is sufficient. Your email address may be passed on, if at all, to a third party only for technical purposes to enable newsletter distribution by a service provider who strictly adheres to privacy policy. Cancellation is possible at any time, e.g. via a link at the end of each newsletter. Alternatively, you may send your cancellation by email to info@edel-optics.co.uk at any time.

c) Comments and contributions in our blog / subscriptions

If you leave a comment or other contribution in our blog, we save your IP address in addition to the details you entered. This is for security purposes in case any comments or other contributions contain unlawful contents (e.g. insults, illegal political propaganda, etc.). In such a case we would pass on the IP address concerned to the authorities. You can also subscribe to the contributions and comments in our blog. You then receive an email to confirm that you are the holder of the email address provided. You can unsubscribe at any time. The confirmation email contains further information on this. Alternatively, you can unsubscribe by email to info@edel-optics.co.uk at any time. The data you provided in the blog is processed in accordance with Article 6, paragraph 1, point (a) of the GDPR on the basis of your voluntary consent, and in the case of passing on to the authorities in accordance with Article 6, paragraph 1, point (c) or (f) of the GDPR.

d) Online fitting

We offer you the possibility of comfortably trying on your glasses online by way of 2D or 3D fitting. To this end you may either upload your photograph or use your webcam. The online glasses fitting is voluntary and the data are collected on the basis of our legitimate interest in being able to offer you the corresponding service, Art. 6 Para. 1 lit. f) GDPR. In the case of the 3D fitting, we make use of an external provider in order to implement the service. We use the photographic/video material you supply solely in order to be able to offer you our service. Video material is deleted immediately, an uploaded photograph automatically after 14 days.

e) Order and payment details

To initiate, process and carry out your order, your details, as far as necessary, will be passed on to an assigned service provider, e.g. the shipping company. Payment details will be encrypted and used exclusively for the respective transaction. Only the selected payment service provider will receive your data. These are - for credit card payments, Crédit Industriel et Commercial, Paris; - for PayPal, PayPal (Europe), Luxemburg.

In the case of bank transfer, there is no transmission of data to external payment service providers. The processing takes place exclusively via the respective service provider.

f) Processing of your data for advertising purposes

In addition to processing your data for the purpose of implementing the contracts concluded with us, we also use your data in order to exchange information with you concerning your orders, to communicate with you concerning certain products or marketing actions and to be able to recommend products or services that might be of interest to you. Your data will only be used for our own marketing purposes if you have given us your prior consent to do this. On subscribing to our newsletter, your email address will be used for our own advertising purposes until you unsubscribe. You can withdraw your permission for Edel-Optics to use your email address to send you service and product information emails at any time without incurring any costs other than the transmission costs in accordance with the basic rates. If you no longer wish to receive service and product information emails, simply email us at info@edel-optics.co.uk. We of course guarantee the security of your data in accordance with the German Data Protection Act. Once you have withdrawn your permission, your contact details will no longer be used for marketing purposes. The legal basis for the aforementioned types of processing is in each case Art. 6 Para. 1 lit. f) GDPR. The processing of regular customers’ data for our own advertising purposes is to be regarded as a legitimate interest.

g) Deletion of data

Your data will be stored with us only as long as is required for optimal processing. Then the data will be deleted, unless there is a legal retention obligation. Exempt from deletion are data that we require for the processing of tasks still due, or for implementation of our rights and claims, as well as data that we are legally obliged to store. In this case, the data will be kept from further use.

3. Disclosing Data

Your data will not be passed on to third parties in any other circumstances than those listed below. We will only pass your details on to third parties if:- You have expressly consented to this in accordance with Article 6, paragraph 1, point (a) of the GDPR;

• Disclosing data according to Article 6, paragraph 1, point (f) of the GDPR is necessary for establishing, exercising or defending legal claims and there is no reason to believe that you have an overriding and legitimate interest in the non-disclosure of your data;
• There is a legal obligation to disclose data according to Article 6, paragraph 1, point (c) of the GDPR and this is permitted by law and required to handle contractual relationships in accordance with Article 6, paragraph 1, point (b) of the GDPR.

4. Cookies and Web Beacons

a) Cookies

We use cookies on our website. Cookies are files automatically created by your browser, which are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site. Cookies do not damage your device in any way: they do not contain viruses, Trojans or other malware. Cookies store information relating to your specific device, but this does not mean that we can immediately ascertain your identity. We use cookies to compile statistics on the use of our website and evaluate this for the purpose of optimising our offer (see section 5). They enable us to automatically recognise when you have visited our website before. These cookies are automatically deleted after a set period of time. Data processed by cookies are required for the specified purposes to safeguard our and third parties’ legitimate interests according to Article 6, paragraph 1, point (f) of the GDPR. Most browsers accept cookies automatically, but you can configure your browser so that no cookies are stored on your computer or you are always notified before a new cookie is stored. Deactivating all cookies can prevent you from using all of our website’s features.

b) Web Beacons

Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small graphic files that are usually employed together with cookies to identify user behaviour on a web page. The provisions on cookies described above are valid for web beacons, accordingly; in particular, we do not use web beacons if you have objected to the use of cookies.

5. Analytic Tools

For the purpose of shaping our websites in accordance with your needs, and of continuously optimising our websites we, on the basis of Art. 6 Para. 1 lit. f) GDPR, deploy the following tools. At the same time this also represents the legitimate interest we are pursuing hereby.

a) Contentsquare:

We use the analytical software of the provider Contentsquare (Content Square GmbH, Implerstraße 25a, 81371 Munich, Germany), which enables an evaluation of visits to our website and uses cookies in this context (see section 4). This enables us to determine, for example, which areas are viewed for a particularly long time. We can also track a user's entire visit in individual cases. We can then understand which sub-pages are visited and in what order, how a mouse was guided and how quickly certain passages are scrolled. This information about a specific website visit is only collected anonymously. Therefore, we cannot assign this information to a specific user or a specific person. The evaluation serves our legitimate interest in improving our offer because it enables us to track how random users experience a visit to our website. The legal basis is therefore Art. 6 para. 1 p. 1 lit. f of the German Data Protection Act (DSGVO). The evaluation takes place on Contentsquare's servers. The IP address transmitted by your browser is not merged with other Contentsquare data. Contentsquare guarantees that your IP address will be shortened so that the analyses are anonymous. Further information on data protection in connection with Contentsquare can be found here: https://contentsquare.com/gb-en/support/faqs/

b) Google Analytics:

For the purpose of demand-oriented design and continuous optimisation of our pages, we use Google Analytics, a web analysis service of Google Ireland Limited (Gordon House Barrow Street, Dublin 4, Ireland; hereinafter "Google"). In this context, pseudonymised usage profiles are created and cookies (see point 4) are used. The information generated by the cookie about your use of this website, such as your

• Browser type/version,
• Operating system used,
• Referrer URL (the previously visited page),
• Host name of the accessing computer (IP address),
• Time of the server request,

are transferred to a Google server and stored there. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services associated with the use of the website and the Internet for the purposes of market research and the design of these Internet pages in line with requirements. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymised so that an allocation is not possible (IP masking). You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. You can also 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 (https://tools.google.com/dlpage/gaoptout).

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking here to automatically add a Google Analytics opt-out cookie to your browser. This will prevent future collection of your data when visiting this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again. Further information on data protection in connection with Google Analytics can be found here: https://marketingplatform.google.com/about/analytics/terms/gb/.

c) Google Analytics Audience (GA Audience):

We also use GA Audience, which is also a service provided by Google (see lit. b above). - With the help of GA Audience, we can create so-called "audience reports" that allow us to categorise visitors to our website. We do this in the interest of showing you advertising that may be of interest to you, in order to make our website more interesting for you. Depending on the category and corresponding user and search behaviour, the user can then be shown advertisements that are likely to be of interest to users in the corresponding category. To make this possible, GA Audience uses a web beacon (para. 4 lit. b)) in conjunction with cookies (para. 4 lit. a)), which make it possible to analyse the use of the relevant end devices. GA Audience also accesses the cookies created as part of the use of Google Adwords and Google Analytics to analyse your interests. In addition, GA Audience uses a variety of data points derived from places like Gmail, app messages, internet browsing habits and YouTube history to guess each user's personal interests. By visiting our site, Google also receives the information that you have accessed on our website. We have no influence on the data collected, nor are we aware of the full extent of the data collection and the storage period. Your data will be transferred to the USA and evaluated there. If you are logged in with your Google account, your data can be directly assigned to it. If you do not wish to be associated with your Google profile, you must log out. It is possible that this data will be passed on to third parties and authorities to Google's contractual partners. You can prevent the installation of GA Audience cookies in various ways:

• by adjusting your browser software accordingly; in particular, the suppression of third-party cookies will result in you not receiving any third-party ads;
• by deactivating Google's interest-based ads via the link http://www.google.de/ads/preferences, whereby this setting is deleted when you delete your cookies;
• by deactivating the interest-based ads of the providers that are part of the self-regulation campaign "About Ads" via the link http://www.aboutads.info/choices, whereby this setting is deleted when you delete your cookies;
• by permanently deactivating it in your Firefox, Internet Explorer or Google Chrome browsers at the link http://www.google.com/settings/ads/plugin. We would like to point out that in this case you may not be able to use all functions of this offer to their full extent.
• Further information on the purpose and scope of the data collection and its processing as well as further information on your rights in this regard and setting options to protect your privacy can be obtained from Google (see section 5 lit. b above).

Privacy policy for advertising: https://policies.google.com/technologies/ads?hl=en-GB

6. Advertising and Marketing Tools

a) DoubleClick by Google

We use the online marketing tool DoubleClick by Google. DoubleClick uses cookies to serve ads relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same ads more than once. Google uses a cookie ID to record which ads are placed in which browser. This prevents the ads from being displayed more than once. In addition, DoubleClick may use cookie IDs to collect so-called conversions related to ad requests. This is the case, for example, when a user sees a DoubleClick ad and later uses the same browser to visit the advertiser's website and buy something there. According to Google, DoubleClick cookies do not contain any personal information. Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google using this tool and are therefore informing you in accordance with our current state of knowledge: By integrating DoubleClick, Google receives information that you have opened the relevant part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can associate the visit with your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may find out and store your IP address. You may opt out of participating in this tracking process by disabling cookies for conversion tracking. To do this, set your browser to block cookies from the domain www.googleadservices.com, https://www.google.com/settings/ads. Please note that this setting is deleted when you delete your cookies. Alternatively, you can contact the Digital Advertising Alliance at the Internet address www.aboutads.info to find out about how and when cookies are set and configure your settings. Finally, you can set your browser so that you are informed whenever cookies are set and can decide individually to accept them or to exclude their acceptance in certain cases or generally. If cookies are not accepted, the functionality of our online offer may be restricted. Google LLC, headquartered in the USA, is certified for the US-European "Privacy Shield" privacy agreement, which ensures compliance with the data protection level applicable in the EU. You can find out more about the Privacy Policy of DoubleClick by Google at the following Internet address: http://www.google.com/policies/privacy/. Alternatively, please visit the Network Advertising Initiative (NAI) at http://www.networkadvertising.org. The legal basis for data processing is Article 6, paragraph 1, point (f) of the General Data Protection Regulation (GDPR).

b) Facebook Pixel und Facebook Custom Audience

Our website uses the services Facebook Pixel and Facebook Custom Audience. These are products by Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland (“Facebook“)). With these services, transactions on our website, such as the duration of a page visit, the placing of products in the shopping cart, or purchases, are documented. The respective data is stored on your computer using cookies. The stored data is initially used to analyse visitors’ search and purchase behaviour on the website (tracking). Based on the retrieved information the stored cookies are also used to recognise visitors of our website when they visit websites belonging to the Facebook advertising network. Using these services then enables us to show the user on the “partner website” (e.g. Facebook, Instagram or other Audience network websites) interest-related ads and so make it more attractive to the user (retargeting). You have the option of deactivating the retrieval of data for the purposes described above. Then a permanent cookie will be set that prevents the data retrieval as long as you do not specifically delete this cookie. You can repeat the objection at any time.

7. Social Media

We use plugins of the social networks Facebook, Twitter and Google+ on our website in accordance with Article 6, paragraph 1, point (f) of the GDPR, with the purpose of making our company known to a wider audience. The commercial purpose of this is deemed a legitimate interest in the context of GDPR. The responsibility for data protection compliance lies with each respective provider. The integration of these plugins is realised via the so-called two-click method in order to protect the visitors of your website in the best possible way.

a) Facebook

On our website we employ social media plugins by Facebook to personalise its usage. For this we use the buttons “LIKE” and “SHARE”. This is a service by Facebook. When you open a page of our web appearance that contains such a plugin, your browser enables a direct connection to the Facebook server. Facebook transmits the content of the plugin directly to your browser and integrates it on the website. With the integration of the plugins Facebook receives the information that your browser has opened the respective page of our website, even if you don’t have a Facebook account or are not currently logged in at Facebook. This information (including your IP address) is transmitted directly from your browser to a Facebook server in the USA and stored there. When you are logged in at Facebook, Facebook can directly associate our website with your Facebook account. When you interact with the plugins, for example by clicking the “LIKE” or “SHARE” button, the respective information is also transmitted directly to the Facebook server and stored there. The information is also published on Facebook and displayed in your friends’ newsfeed. Facebook can use this information for the purposes of advertising, market research, and the customisation of Facebook pages. For this, Facebook profiles about usage, interests and relationships are developed, e.g. in order to evaluate our website regarding the ads that you see, to inform other Facebook users about your activities on our website and to provide further services connected to the use of Facebook. If you do not want that Facebook connects the collected data about our website with your Facebook account, you need to log out of your Facebook account before you visit our website. For further information about the purpose and scope of this data collection and processing, as well as your rights in this regard and the optional settings to protect your privacy, please refer to Facebook’s privacy policy section (https://www.facebook.com/about/privacy/).

b) Instagram

On our website we also employ social media plugins by Instagram, operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA (hereinafter „Instagram“). The plugins are marked with an Instagram logo, e.g. an “Instagram camera“. When you open a page of our web appearance that contains such a plugin, your browser enables a direct connection to the Instagram server. Instagram transmits the content of the plugin directly to your browser and integrates it on the website. With this integration, Instagram receives the information that your browser has opened the respective page of our website, even if you don’t have an Instagram account or are not currently logged in at Instagram. This information (including your IP address) is transmitted directly from your browser to an Instagram server in the USA and stored there. When you are logged in at Instagram, Instagram can directly associate our website with your Instagram account. When you interact with the plugins, for example by clicking the “Instagram“ button, this information is also transmitted directly to the Instagram server and stored there. The information is also published on your Instagram account and shown to your contacts. If you do not want that Instagram connects the collected data about our website with your Instagram account, you need to log out of Instagram before you visit our website. For further information, please refer to Instagram’s privacy policy (https://help.instagram.com/155833707900388).

8. Use of AddToAny

On our website we employ the sharing service AddToAny. AddToAny offers you the opportunity to share contents in social media networks. To make this possible, AddToAny stores cookies in your browser (see section 4). Data will only be retrieved if you yourself request the service. The data retrieved by AddToAny are stored on a server in the USA. We don’t receive any personalised data resulting from the use of the share button. If you do not agree with the processing of your data by AddToAny, please use this link to opt out: http://optout.networkadvertising.org/?c=1#!/.

9. Store Evaluation Systems

a) Integration of the Trusted Shops Trust Badge

The Trusted Shops Trust Badge is integrated on this website to display our Trusted Shops seal of approval and the possibly collected evaluations, as well as to offer Trusted Shops products to buyers after an order is placed. This serves to safeguard our legitimate interest in accordance with Art. 6 para. 1 lit. f) within GDPR for optimal marketing of our offer within the scope of a balancing of interests. The trust badge and the services advertised with it are an offer of the Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne, Germany. When the trust badge is activated, the server automatically stores a so-called server log-file, which contains, for example, your IP address, date and time of retrieval, amount of data transmitted and the requesting provider (access data) that contains and documents the call. This access data will not be evaluated, and it will be automatically overwritten within seven days after the end of your page visit. Other personal data (order number, hashed email address, sum, currency, payment method) will only be transferred to Trusted Shops if you decided to use Trusted Shops products after completing an order or if you have already registered. In this case, the contractual agreement between you and Trusted Shops applies.

b) Integration of Trustpilot

We also provide the option to rate us using the evaluation service www.trustpilot.com. Here, the following conditions and privacy terms by Trustpilot apply: http://legal.trustpilot.com/end-user-privacy-terms and http://legal.trustpilot.com/end-user-terms-and-conditions. To evaluate us, you need to register. Should you decide to do this, your evaluation will be published with us as well as on the websites of Trustpilot and their partners. For the purpose of use by Trustpilot, we pass on your email address, your first name and surname, and your order number we have generated to Trustpilot A/S, Pilestræde 58, 5th floor, 1112 Copenhagen, Denmark (support@trustpilot.com). Commissioned by us, Trustpilot will send you invitations for evaluations by email. The data processing is based on Article 6, paragraph 1, point (f) of the General Data Protection Regulation (GDPR) and the rightful interest to receive user assessments to create a trustful basis for the use of our website. You have the right to object to the processing of your data in the framework of the assessment system by Trustpilot at any time (see section 12 below).

10. Google Maps

Our website employs a Google Maps interface (API), to visually display geographical information. Google Maps is also a product by Google (section 5). With the use of Google Maps, also data on the use of Maps functions by visitors of the websites are retrieved, processed and used. For further information on data processing by Google please refer to Google’s privacy policy statement. For further instructions of how to manage your own data in relation to Google products please refer to: https://support.google.com/accounts/answer/3024190.

11. User Rights

You have the right:- To request access to the personal data processed by us, pursuant to Article 15 GDPR. In particular, you may request the following information: the purposes of the processing, the categories of personal data concerned, the categories of recipient to whom your personal data have been or will be disclosed, the envisaged period for which the data will be stored, the existence of the right to request from the controller rectification or erasure or restriction of processing or to object, the right to lodge a complaint, the source of your data where the personal data are not collected by us, as well as the existence of automated decision-making, including profiling and, if applicable, meaningful information about relevant details;

• To obtain without undue delay the rectification of inaccurate personal data held by us or to have incomplete personal data completed, pursuant to Article 16 GDPR;
• To obtain the erasure of the personal data held by us to the extent that processing is not necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims, pursuant to Article 17 GDPR;
• To obtain restriction of processing of your personal data where you contest the accuracy of the data or where the processing is unlawful, and you oppose the erasure or where we no longer need the data, pursuant to Article 18 GDPR. Or where you need the data for the establishment, exercise or defence of legal claims or you have objected to processing, pursuant to Article 21 GDPR;
• To receive the personal data you have provided us with in a structured, commonly used and machine-readable format or to obtain transmission of those data to another controller, pursuant to Article 20 GDPR;
• To withdraw your consent at any time, pursuant to Article 7(3) GDPR; this means that we may not continue to process the data for which consent had been given;
• To lodge a complaint with a supervisory authority, pursuant to Article 77 GDPR; you can normally contact the supervisory authority in your habitual residence, place of work or our company`s location.

12. Right of Objection

If your personal data are processed on the basis of legitimate interests in accordance with Art. 6 para. 1 sent. 1 letter f) of the GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 of the GDPR, provided that the reasons for the objection relate to your particular situation or that the objection is aimed at direct advertising. In the latter case, you have a general right to object, with which we will comply whether or not you base your objection on any particular situation. To exercise your right of revocation or right of objection, it is sufficient to send an email to info@edel-optics.co.uk.

13. Data Security

During your visit to our website we will employ the widely used SSL method (secure socket layer) in combination with the highest encryption level supported by your browser. As a general rule, 256-bit encryption will be used. If your browser does not support 256-bit encryption, we will use 128 bit v3 technology instead. To check whether any particular page of our website is transmitted in encrypted form, look for the closed key or lock symbol in the lower status bar of your browser. In addition, we have implemented appropriate technical and organizational safeguards to protect your data from accidental or intentional manipulation, partial or complete loss or destruction, and unauthorized access by third parties. Our safeguards are continuously updated as technology evolves.

14. Validity and Modification of this Privacy Policy

This Privacy Policy is currently valid and was last revised in May 2018. As a result of upgrades to our website, services offered on our website, or new laws or regulatory requirements, it may be necessary to modify this privacy policy in the future. The most recent version of this privacy policy can be found on and printed out from our website at www.edel-optics.co.uk/Datenschutz.html, at any time.