Privacy Policy
1. Security and protection of your personal data when visiting our website
HEBE Ltd (referred to hereafter as "HEBE Ltd" or "we") takes the protection of your personal data very seriously and uses extreme care and the most advanced security standards to guarantee it.
We consider it our overriding responsibility to safeguard the confidentiality of the personal data provided by you and to protect them from unauthorised access.
2. Definitions
In order to ensure a transparent and easily understandable declaration regarding the processing of your personal data, we would like to inform you about the individual legal definitions used in this privacy policy:
(1) Personal data
"Personal data" means any information relating to an identified or identifiable natural person (hereafter referred to as "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
(2) Processing
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
(3) Restriction of processing
"Restrictions on processing" means the marking of stored personal data with the aim of limiting their processing in the future.
(4) Profiling
"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.
(5) Pseudonymisation
"Pseudonymisation" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
(6) Filing system
"File system" means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.
(7) Data controller
"Data controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
(8) Processor
"Processor" means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
Recipient
(9)"Recipient" means a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
(10) Third party
"Third party" means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
(11) Consent
"Consent" of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
3. Lawfulness of processing
Processing shall be lawful only if there is a legal basis for processing data. Pursuant to Article 6 paragraph 1 points (a) – (f) GDPR such legal basis for processing data can be in particular:
(1) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
(2) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
(3) processing is necessary for compliance with a legal obligation to which the controller is subject;
(4) processing is necessary in order to protect the vital interests of the data subject or of another natural person;
(5) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(6) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
4. Collection of personal data during a visit to our website
In case of a merely informative use of the website, i.e. if you do not register, buy something, or disclose to us data in other ways, we collect only those personal data which your browser transmits to our server. If you visit our website, we collect the data below which are technically necessary for us to show you our website and ensure its stability and security (the legal basis for this is Art. 6 paragraph 1 clause 1 point (f) GDPR):
- IP address
- Date and time of your inquiry
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (actual page)
- Access status/HTTP status code
- Transmitted data volume
- Website from which the request is received
- Browser
- Operating system and its interface
- Language and version of the browser software.
5. Information about the collection of personal data – (email, contact form, customer account and online shop)
(1) In what follows we inform you about the collection of your personal data when you use our website (contact form, customer account and online shop)
If you contact us by email or via our contact form, the data disclosed by you to us (email address, if necessary your name and your telephone number) are stored by us to allow us to answer your questions. We erase the data collected in this context after storage is no longer necessary or if processing is restricted or of there exist legal retention obligations.
(2) If you buy products via our website or if you open a customer account for the administration of your current or future orders, we collect for this purpose the data that we need for the performance of the contract. These can be seen in the respective input fields for registration (customer account) or the purchase order form. When you place an order, we need as a minimum the obligatory data marked with a star (*). We use these data pursuant to Art. 6 paragraph 1 clause 1 point (b) GDPR for the performance of the contract and for handling your inquiries.
(3) Our shop is hosted by Shopify Inc. Shopify offers us an e-commerce platform that allows us to sell our goods and services to you.
Your data are administered via data storage, a database and generally the Shopify app. Shopify stores your data on a secure server behind a firewall.
If you pay by credit card, Shopify stores your credit card data. These are encrypted using the Payment Card Industry Data Security Standard (PCI-DSS). The data of your purchase will be stored only as necessary for the duration of your purchase. As soon as it is completed, your purchase data are erased. All direct payment portals are subject to the PCI-DSS standard and are administered by PCI Security Standard Council, a joint initiative by Visa, MasterCard, American Express and Discover. PCI-DSS conditions help to ensure secure payment transactions using your credit card information in our shop and at the service providers. More detailed information can be found in the terms of use (https://www.shopify.com/legal/terms) or privacy policies (https://www.shopify.com/legal/privacy) of Shopify.
(4) Aside from payment by credit card, we offer also other payment methods for the use of our cybershop and for this purpose avail ourselves of various other payment service providers with whom we have signed third-party data processing agreements. We disclose different data to the various payment service providers depending on which payment method you have chosen. The legal basis for the disclosure is Art. 6 paragraph 1 clause 1 points (a), (b), (f) GDPR.
Here are our payment service providers:
PayPal
If you pay for your purchases from us using PayPal, your personal data are disclosed to PayPal. If you have not yet opened a PayPal account, you will be asked by PayPal to do so in the course of the payment process. When using or opening a PayPal account, you must provide PayPal with, among other data, your name, address, telephone number and email address. The legal basis for the disclosure of the data is Article 6 paragraph 1 point (a) GDPR and Article 6 paragraph 1 clause 1 point (b) GDPR.
The operator of the PayPal payment service is:
PayPal (Europe) S.à r.l. et Cie, S.C.A.
22-24 Boulevard Royal
L-2449 Luxembourg
Email: impressum@PayPal.com
When choosing the PayPal payment option you consent to the disclosure of your personal data such as name, address, telephone number and email address to PayPal. PayPal's privacy policy will indicate what other data will be collected by PayPal. It can be found under: https://www.PayPal.com/de/webapps/mpp/ua/privacy-full
The General Data Protection Regulation within the meaning of Regulation (EU) 2016/679 ("GDPR") it is responsible for the storage and processing of your personal data collected from you in the context of its services as well as for compliance with the applicable rules and regulations.
6. Newsletter
(1) With your consent you may subscribe to our Newsletter in which we inform you about our current special offers. The promoted goods and services are described in the declaration of consent. The legal basis is Art. 6 paragraph 1 clause 1 point (a) GDPR.
(2) We use the so-called double-opt-in procedure for the application to our Newsletter, meaning that following your application we send you an email to the indicated email address in which we ask you to confirm that you requested subscription to the Newsletter. If you do not confirm your application within 24 hours, your information will be blocked and erased automatically after one month. In addition we store the IP addresses you used and the time of your application and confirmation. The purpose is to have proof of your application and if necessary to be able to clarify a possible misuse of your personal data.
(3) The only obligatory information for the subscription to our Newsletter is your email address. The provision of additional, separately marked data is voluntary and is used in addressing you personally. After your confirmation we store your email address for the purpose of sending you the Newsletter.
(4) You may withdraw your consent to the subscription of the Newsletter at any time and you may cancel the Newsletter at any time. You may confirm the withdrawal by clicking on the link provided in each e-mailed Newsletter or by sending a message to the contact data indicated in the imprint.
7. Use of external tools on our website
We have integrated various tools from different companies with our website which allow us to analyse user behaviour or establish links with other websites.
For this purpose we work with the following service providers:
Google Analytics
The third-party data processor has integrated the component Google Analytics on this website (with anonymity function).
Google Analytics is a website analysis service. Website analysis refers to the collection, recording and analysis of data regarding the behaviour of visitors to the website. A website analysis service records e.g. data showing from which website a data subject has come to a website (so-called referrer), which subpages of the website were accessed or how often and how long a subpage was viewed. Website analysis is used mainly for the optimisation of a website and for a cost-benefit analysis of Internet adverting.
Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA, is the operator of the Google Analytics component.
Google Analytics uses cookies. The information about your use of our website generated by the Google Analytics cookie is normally transmitted to a Google server in the USA and stored there. Google might disclose these personal data collected via the technical procedure to third parties.
However, when you activate IP anonymiity on our website, Google shortens your IP address within the Member States of the European Union or in other countries that are parties to the European Marketing Area Treaty. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. Google uses this information to analyse your use of the website in order to compile a report about your website activities and provide us with other services associated with your website and Internet use. The IP address of your browser transmitted by Google Analytics is not linked to any other Google data.
This website also uses the UserID functions of Analytics in order to be able to track interaction data. This User ID is also anonymised and encrypted and is not linked to other data.
You may prevent the storage of cookies by setting your browser software accordingly, but you might then not be able to fully use all functions of our website.
You may furthermore prevent the disclosure of the data generated by the cookie which refer to the use of the website (incl. your IP address) to Google as well as the processing of these data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
This browser add-on notifies Google Analytics via JavaScript that no data or information about website visitors may be transmitted to Google Analytics.
Besides, a cookie left behind by Google Analytics may be erased at any time via the Internet browser or other software programs.
Additional information and the applicable privacy policy of Google may be downloaded from https://policies.google.com/privacy?hl=de and from https://marketingplatform.google.com/about/analytics/terms/de/ . Google Analytics is explained in more detail under this link: https://marketingplatform.google.com/about/.
Our website also uses Google Analytics performance reports by demographic factors and interests as well as reports about impressions in the Google Display Network. You may deactivate Google Analytics for display advertising and set the displays in the Google Display Network by accessing the display settings under this link: https://www.google.de/ads/preferences?ac_tld=de&continue=aHR0cHM6Ly9hZHNzZXR0aW5ncy5nb29nbGUuZGUvYW5vbnltb3Vz.
8. Cookies
Our website uses cookies. Cookies are small text files placed on your computer and stored by your browser. They serve the purpose of making our offer more user-friendly, efficient, and secure. Cookies also make it possible for our systems to recognize your browser and offer you the best possible configuration.
We store this information for the duration of 12 months.
This data processing is based on the principles of Art. 6 paragraph 1 point (f) GDPR for the protection of our legitimate interests, i.e. the optimisation of our offer.
Here is a list of cookies that we use. We have listed them here so you can decide whether you would like to use cookies or not.
(1) session_id, proprietary token, session-related, allowing Shopify to store information about your session (referrer, target website, etc.).
(2) shopify_visit, no data storage, lasting for 30 minutes from your last visit, is used by the internal statistics tracker of our website provider to track the number of visitors.
(3) shopify_uniq, no data storage, expires at midnight (relative to the visitor) of the next day, counts the number of shop visits by individual customers.
(4) cart, proprietary token, lasting for 3 weeks, stores information about the content of your shopping cart.
(5) secure_session_id, proprietary token, session-related
(6) storefront_digest, proprietary token, unlimited duration, used if the shop has a password in order to determine whether the current customer has access.
Your privacy rights vis-à-vis HEBE Ltd
(1) Ability to withdraw your consent, Article 7 GDPR
Pursuant to Article 7 paragraph 3 GDPR you have the right to withdraw your consent to the processing of your data granted to us at any time for any reason. You may send your withdrawal notice in no particular format to the mailing address or email address shown at the beginning of this privacy policy. Withdrawal of the consent does not affect the legality of the data processed up to the withdrawal based on your consent (Article 7 paragraph 3 clause 2 GDPR).
(2) Right of access to information, Article 15 GDPR
Pursuant to Article 15 paragraph 1 GDPR you have the right to know whether we process your personal data. If we do, you have a right to additional information (Article 15 paragraph 2 GDPR).
(3) Right to rectification, erasure or restriction of processing, Article 16, 17 and 18 GDPR
Under Article 16 GDPR you have the right to demand the immediate rectification of inaccurate personal data and the completion of incomplete data, including by means of a supplementary statement.
In particular, pursuant to Article 17 GDPR you have the right to demand the erasure of personal data concerning yourself if the processing of your personal data is not or no longer permitted.
(4) Right to object, Article 21 GDPR
Under Article 6 paragraph 1 (e) or (f) GDPR you have the right to object at any time to the processing of your personal data on grounds relating to your particular situation; this applies also to any profiling based on these provisions. We will then no longer process your data unless we demonstrate compelling legitimate grounds for such processing which override your own interests, rights, and freedoms.
You may exercise the right to object at any time by contacting us via the contact options specified in the imprint.
(5) Right to lodge a complaint with a supervisory authority, Article 77 GDPR
Without prejudice of another administrative or judicial remedy, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your place of residence, your job or the place of the presumed violation if you believe that the processing of your respective personal data is unlawful. The data protection agency of the Republic of Austria provides forms for the exercise of your legal rights and for a complaint under https://www.dsb.gv.at/download-links/dokumente.html. For our European customers: Your competent supervisory authority is that of your residence. A list of all supervisory authorities can be found under https://edpb.europa.eu/about-edpb/about-edpb/members_en
For questions about the collection, processing or use of your personal data, or for information about, correction, restriction, or erasure of data as well as the withdrawal of a consent granted by you or an objection to a particular data use, please contact us directly using the contact data in our imprint.
Status of the privacy and data security policy: November 18, 2021