Data protection

1) Introduction and contact details of the person responsible

1.1 We are pleased that you are visiting our website and thank you for your interest. Below, we inform you about how we handle your personal data when you use our website. Personal data refers to all data that can be used to identify you personally.

1.2 The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Kind Circles, Erkrather Strasse 401, 40231 Düsseldorf, Germany, email: themillennialsclub@outlook.de. The controller responsible for the processing of personal data is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data.

2) Data collection when visiting our website

2.1 If you use our website for informational purposes only, i.e., if you do not register or otherwise provide us with information, we only collect data that your browser transmits to the website server (so-called "server log files"). When you access our website, we collect the following data, which is technically necessary for us to display the website to you:

Our visited website
Date and time of access
Amount of data sent in bytes
Source/reference from which you came to the page
Browser used
Operating system used
IP address used (if applicable: in anonymized form)

Processing is carried out in accordance with Art. 6 (1) (f) GDPR based on our legitimate interest in improving the stability and functionality of our website. The data will not be shared or used for any other purpose. However, we reserve the right to subsequently review the server log files if there are concrete indications of illegal use.

2.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the character string "https://" and the lock symbol in your browser bar.

3) Hosting & Content Delivery Network

Shopify

For hosting our website and displaying the page content, we use the system of the following provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland (“Shopify”)

Data is also transferred to: Shopify Inc., 150 Elgin St, Ottawa, ON K2P 1L4, Canada, Shopify Data Processing (USA) Inc., Shopify Payments (USA) Inc. or Shopify (USA) Inc.

All data collected on our website is processed on the provider's servers. We have concluded a data processing agreement with the provider that ensures the protection of our website visitors' data and prohibits unauthorized disclosure to third parties.

When data is transferred to Canada, an appropriate level of data protection is guaranteed by an adequacy decision of the European Commission.

For the transfer of data to the USA, the provider relies on standard contractual clauses of the European Commission, which are intended to ensure compliance with the European level of data protection.

4) Cookies

To make visiting our website more attractive and enable the use of certain functions, we use cookies, i.e., small text files stored on your device. Some of these cookies are automatically deleted after closing your browser (so-called "session cookies"); others remain on your device for a longer period and allow you to save page settings (so-called "persistent cookies"). In the latter case, you can find out how long cookies are stored in your web browser's cookie settings overview.

If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 (1) (b) GDPR either to execute the contract, in accordance with Art. 6 (1) (a) GDPR in the event of consent being given, or in accordance with Art. 6 (1) (f) GDPR to protect our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the site visit.

You can set your browser so that you are informed about the setting of cookies and can decide individually whether to accept them or to exclude the acceptance of cookies in certain cases or in general.

Please note that if you do not accept cookies, the functionality of our website may be limited.

5) Contact

5.1

If you submit contact inquiries via email through our website, they will be stored and organized in our ticket system to enable chronological processing and improve the service experience. You can always view the current status of your request using the individually assigned ticket number.

For the organization and processing of inquiries, personal data is collected according to the extent of its provision, but in any case name, first name and email address, transmitted to the provider, stored there and read out.

The legal basis for the processing of this data is our legitimate interest in the efficient design of our customer service, in answering your request as quickly as possible and in optimising our service offering in accordance with Art. 6 (1) (f) GDPR.

We have concluded a data processing agreement with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

5.2 When you contact us (e.g. via contact form or email), personal data will be processed exclusively for the purpose of processing and answering your request and only to the extent necessary for this purpose.

The legal basis for processing this data is our legitimate interest in responding to your request in accordance with Art. 6 (1) (f) GDPR. If your contact is related to a contract, the additional legal basis for processing is Art. 6 (1) (b) GDPR. Your data will be deleted if the circumstances indicate that the matter in question has been conclusively resolved and provided there are no statutory retention periods to the contrary.

6) Data processing when opening a customer account

Pursuant to Art. 6 (1) (b) GDPR, personal data will continue to be collected and processed to the extent necessary if you provide it to us when opening a customer account. You can find out which data is required to open an account in the input mask of the corresponding form on our website.

You can delete your customer account at any time by sending a message to the controller's address above. After deleting your customer account, your data will be deleted, provided that all contracts concluded through it have been fully processed, there are no statutory retention periods that prevent this, and we have no legitimate interest in continuing to store it.

7) Data processing for order processing

7.1 To the extent necessary for the execution of the contract for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 (1) (b) GDPR.

If we owe you updates for goods with digital elements or for digital products based on a corresponding contract, we will process the contact information you provided when placing your order (name, address, email address) in order to inform you personally about upcoming updates within the legally stipulated period via a suitable communication channel (e.g., by post or email) within the scope of our statutory information obligations pursuant to Art. 6 (1) (c) GDPR. Your contact information will be used strictly for the purpose of notifying you about updates owed by us and will only be processed by us to the extent necessary for the respective information.

To process your order, we also work with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data will be transmitted to these service providers in accordance with the following information.

7.2 Use of payment service providers (payment services)

- Paypal

This website offers one or more online payment methods from the following provider: PayPal (Europe) Sarl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg

If you select a payment method from the provider that requires you to make an advance payment, the payment details you provided during the ordering process (including your name, address, bank and payment card information, currency, and transaction number), as well as information about the content of your order, will be passed on to the provider in accordance with Art. 6 (1) (b) GDPR. In this case, your data will be passed on exclusively for the purpose of processing the payment with the provider and only to the extent necessary for this purpose.

If you select a payment method for which we make advance payments, you will also be asked to provide certain personal information (first and last name, street, house number, postal code, city, date of birth, email address, telephone number, and, if applicable, details of an alternative payment method) during the ordering process.

In such cases, in order to protect our legitimate interest in determining your ability to pay, we will forward this data to the provider for the purpose of a credit check in accordance with Art. 6 (1) (f) GDPR. The provider will check, based on the personal data you provide and other data (such as shopping cart, invoice amount, order history, and payment experience), whether the payment option you have selected can be granted in view of payment and/or default risks.

The credit report may contain probability values (so-called scores). To the extent that scores are included in the credit report results, they are based on a scientifically recognized mathematical-statistical procedure. Address data, among other things, is used in the calculation of the scores.

You can object to this processing of your data at any time by sending us a message or contacting the provider. However, the provider may still be entitled to process your personal data if this is necessary for contractual payment processing.
- Shopify Payments

This website offers one or more online payment methods from the following provider: Shopify International Limited, Victoria Buildings, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland

If you select a payment method from the provider that requires you to make an advance payment (e.g., credit card payment), the payment details you provided during the ordering process (including your name, address, bank and payment card information, currency, and transaction number), as well as information about the content of your order, will be passed on to the provider in accordance with Art. 6 (1) (b) GDPR. In this case, your data will be passed on exclusively for the purpose of processing the payment with the provider and only to the extent necessary for this purpose.

8) Online marketing

Google AdSense

This website uses Google AdSense, a web advertising service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google AdSense uses cookies, which are text files placed on your computer, to help the website analyze how users use the site. Google AdSense also uses web beacons (small, invisible graphics) to collect information. These can be used to record, collect, and analyze simple actions such as visitor traffic. The information generated by the cookie and/or web beacon (including your IP address) about your use of the website is typically transferred to a Google server and stored there. This information may also be transferred to Google LLC servers in the USA.

Google uses the information obtained in this way to evaluate your usage behavior with regard to AdSense ads. The IP address transmitted by your browser as part of Google AdSense will not be merged with other Google data. The information collected by Google may be transferred to third parties if required by law and/or if third parties process this data on Google's behalf.
All processing described above, in particular the reading of information on the device used via cookies and/or web beacons, will only be carried out if you have given us your express consent in accordance with Art. 6 (1) (a) GDPR. Without this consent, Google AdSense will not be used during your visit to the site.

You can revoke your consent at any time with future effect by deactivating this service in the “Cookie Consent Tool” provided on the website.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision of the European Commission.

Google’s privacy policy can be viewed here: https://www.google.de/policies/privacy/

9) Web analysis services

Google Analytics 4

This website uses Google Analytics 4, a web analysis service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), which enables an analysis of your use of our website.

By default, Google Analytics 4 does not use cookies when you visit the website unless you explicitly consent to cookies. Instead, information about your usage behavior is collected and processed through so-called pings (small data packets sent to the host of a device). This information also includes your IP address, which Google truncates to prevent it from being directly linked to a person.

The information is transferred to Google servers and processed there. This may also involve transferring it to Google LLC, based in the USA.

Google uses the information collected on our behalf to evaluate your use of the website, compile reports on website activity for us, and provide other services related to website activity and internet usage. The IP address transmitted and abbreviated by your browser as part of Google Analytics will not be merged with other Google data. The data collected as part of the use of Google Analytics 4 will be stored for a period of two months and then deleted.

All processing described above, including data transmission via “pings” and the possible setting of Google Analytics cookies, will only take place if you have given us your express consent in accordance with Art. 6 (1) (a) GDPR.

Without your consent, Google Analytics 4 will not be used during your visit to the site. You can revoke your consent at any time with future effect. To exercise your right of revocation, please deactivate this service using the "Cookie Consent Tool" provided on the website.

We have concluded a data processing agreement with Google that ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.

Further legal information on Google Analytics 4 can be found at https://policies.google.com/privacy?hl=de&gl=de and under https://policies.google.com/technologies/partner-sites

Demographic characteristics
Google Analytics 4 uses the special "demographic characteristics" feature to create statistics that provide information about the age, gender, and interests of site visitors. This is done by analyzing advertising and information from third parties. This allows target groups to be identified for marketing activities. However, the collected data cannot be assigned to a specific person and is deleted after a storage period of two months.

Google Signals
As an extension to Google Analytics 4, Google Signals can be used on this website to generate cross-device reports. If you have enabled personalized ads and linked your devices to your Google Account, Google can analyze your usage behavior across devices and create database models, including those for cross-device conversions, subject to your consent to the use of Google Analytics in accordance with Art. 6 (1) (a) GDPR. We do not receive any personal data from Google, only statistics. If you would like to stop cross-device analysis, you can deactivate the "Personalized Advertising" function in your Google Account settings. To do so, follow the instructions on this page: https://support.google.com/ads/answer/2662922?hl=de For more information about Google Signals, please visit the following link: https://support.google.com/analytics/answer/7532985?hl=de

User IDs
As an extension to Google Analytics 4, the "User IDs" function can be used on this website. If you have consented to the use of Google Analytics 4 in accordance with Art. 6 (1) (a) GDPR, have set up an account on this website, and log in with this account on multiple devices, your activities, including conversions, can be analyzed across devices.

10) Retargeting/remarketing and conversion tracking

Facebook Pixel for creating custom audiences with advanced data matching (with cookie consent tool)

Within our online offering, we use the "Facebook Pixel" service from the following provider in the extended data matching mode: Meta Platforms Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland ("Facebook")

If a user clicks on an ad placed by us on Facebook, the URL of our linked page is expanded with a parameter using "Facebook Pixel." This URL parameter is then entered into the user's browser after redirection via a cookie set by our linked page itself. Furthermore, this cookie records specific customer data, such as the email address, which we collect on our website linked to the Facebook ad during transactions such as purchases, account registrations, or registrations (extended data matching). The cookie is then read and enables the transmission of the data, including the specific customer data, to Facebook.

We use "Facebook Pixel" with enhanced data matching to make our Facebook advertisements (so-called "Facebook Ads") more effective and to ensure that they correspond to the interests of users or have certain characteristics (e.g., interests in certain topics or products determined based on the websites visited) that we transmit to Facebook (so-called "Custom Audiences").

In addition, we analyze the effectiveness of our ads by tracking whether users were redirected to our website after clicking on an ad (conversion). Compared to the standard version of the "Facebook Pixel," the enhanced data matching feature helps us better measure the effectiveness of our advertising campaigns by tracking more attributed conversions.

All transmitted data is stored and processed by Facebook so that it can be assigned to the respective user profile and Facebook can use the data for its own advertising purposes in accordance with Facebook's data usage guidelines ( https://www.facebook.com/about/privacy/ ). The data may enable Facebook and its partners to place ads on and outside of Facebook.

All processing described above, in particular the setting of cookies for reading information on the device used, will only be carried out if you have given us your express consent in accordance with Art. 6 (1) (a) GDPR. You can revoke your consent at any time with future effect by deactivating this service in the "Cookie Consent Tool" provided on the website.

We have concluded a data processing agreement with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

The information generated by Facebook is usually transferred to a Facebook server and stored there; in this context, it may also be transferred to Meta Platforms Inc. servers in the USA.

11) Tools and Other

Cookie Consent Tool

This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users when they visit the website in the form of an interactive user interface, where consent for specific cookies and/or cookie-based applications can be granted by checking the boxes. By using the tool, all cookies/services that require consent are only loaded if the respective user grants the corresponding consent by checking the boxes. This ensures that such cookies are only placed on the user's device if consent has been granted.

The tool uses technically necessary cookies to save your cookie preferences. Personal user data is generally not processed.

If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.

A further legal basis for processing is Art. 6 (1) (c) GDPR. As the controller, we are legally obliged to make the use of technically unnecessary cookies dependent on the respective user's consent.

Where necessary, we have concluded a data processing agreement with the provider, which ensures the protection of the data of our site visitors and prohibits unauthorized disclosure to third parties.

Further information about the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.

12) Rights of the data subject

12.1 The applicable data protection law grants you the following data subject rights (rights of information and intervention) vis-à-vis the controller with regard to the processing of your personal data, whereby reference is made to the legal basis stated for the respective conditions for exercising these rights:

Right to information pursuant to Art. 15 GDPR;
Right to rectification pursuant to Art. 16 GDPR;
Right to erasure pursuant to Art. 17 GDPR;
Right to restriction of processing pursuant to Art. 18 GDPR;
Right to information pursuant to Art. 19 GDPR;
Right to data portability pursuant to Art. 20 GDPR;
Right to revoke consent given in accordance with Art. 7 (3) GDPR;
Right to lodge a complaint pursuant to Art. 77 GDPR.

12.2 RIGHT OF OBJECTION

IF WE PROCESS YOUR PERSONAL DATA BASED ON OUR OVERRIDING LEGITIMATE INTEREST AS PART OF A BALANCE OF INTERESTS, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME WITH FUTURE EFFECT FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION.

If you exercise your right to object, we will stop processing the data in question. However, we reserve the right to continue processing if we can demonstrate compelling legitimate grounds for the processing that override your interests, fundamental rights, and freedoms, or if the processing serves to assert, exercise, or defend legal claims.

If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing purposes. You can exercise your right of objection as described above.

IF YOU EXERCISE YOUR RIGHT OF OBJECTION, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

13) Duration of storage of personal data

The duration of storage of personal data is determined based on the respective legal basis, the purpose of the processing and – where applicable – also on the respective statutory retention period (e.g. retention periods under commercial and tax law).

When processing personal data on the basis of an express consent in accordance with Art. 6 (1) (a) GDPR, the data concerned will be stored until you revoke your consent.

If there are statutory retention periods for data that are processed within the framework of legal transactions or quasi-legal obligations on the basis of Art. 6 (1) (b) GDPR, these data will be routinely deleted after the retention periods have expired, provided that they are no longer required for the fulfilment or initiation of a contract and/or we no longer have a legitimate interest in continuing to store them.

When processing personal data on the basis of Art. 6 (1) (f) GDPR, these data will be stored until you exercise your right of objection in accordance with Art. 21 (1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

When processing personal data for the purpose of direct marketing on the basis of Art. 6 (1) (f) GDPR, these data will be stored until you exercise your right of objection in accordance with Art. 21 (2) GDPR.

Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data will be deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.