Privacy policy
Privacy Policy
1. Data Protection at a Glance
General Information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. Detailed information on the subject of data protection can be found in our privacy policy listed below this text.
Data Collection on This Website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find their contact details in the “Information about the controller” section of this privacy policy.
How do we collect your data?
Your data is collected, on the one hand, by you providing it to us. This may, for example, be data you enter into a contact form.
Other data is collected automatically, or after you give your consent, by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of page view). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyse your user behaviour. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other requests for services.
What rights do you have regarding your data?
You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request that the processing of your personal data be restricted. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You are welcome to contact us at any time regarding this and any other questions about data protection.
Analysis Tools and Tools from Third-Party Providers
When you visit this website, your surfing behaviour may be statistically evaluated. This is mainly done using what are known as analysis programs.
Detailed information on these analysis programs can be found in the following privacy policy.
2. Hosting
We host the contents of our website with the following provider:
External Hosting
This website is hosted externally. The personal data collected on this website is stored on the servers of the host provider(s). This may include, in particular, IP addresses, contact requests, meta and communication data, contract data, contact details, names, website access data and other data generated via a website.
External hosting is carried out for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 (1) (b) GDPR) and in the interest of a secure, fast and efficient provision of our online services by a professional provider (Art. 6 (1) (f) GDPR). If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and § 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.
Our host(s) will only process your data to the extent necessary to fulfil their contractual obligations and will follow our instructions with regard to this data.
We use the following host(s):
HOSTINGER operations, UAB
Švitrigailos str. 34, Vilnius 03230 Lithuania
Phone: +37064503378
Email: domains@hostinger.com
Data Processing Agreement
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures that this provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.
3. General Information and Mandatory Information
Data Protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.
When you use this website, various pieces of personal data are collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.
Please note that data transmitted via the internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.
Information about the Controller
The controller responsible for data processing on this website is:
Echthaardirekt eGbR
Ferhat Bulut & Özge Bulut
Phone: +49 152 23 00 22 46
Email: info@echthaardirekt.de
The controller is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).
Storage Duration
Unless a more specific storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for its processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion will take place after these reasons no longer apply.
General Information on the Legal Basis for Data Processing on This Website
If you have given your consent to data processing, we process your personal data on the basis of Art. 6 (1) lit. a GDPR and/or Art. 9 (2) lit. a GDPR, provided that special categories of data are processed pursuant to Art. 9 (1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also carried out on the basis of Art. 49 (1) lit. a GDPR. If you have consented to the storage of cookies or to the access of information in your end device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of § 25 (1) TDDDG. You may revoke your consent at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 (1) lit. b GDPR. Furthermore, we process your data if this is necessary for fulfilling a legal obligation, on the basis of Art. 6 (1) lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 (1) lit. f GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.
Recipients of personal data
As part of our business activities, we work together with various external parties. This sometimes also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary for the performance of a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest pursuant to Art. 6 (1) lit. f GDPR in passing on the data, or if another legal basis permits the data transfer. When using processors, we only pass on our customers’ personal data on the basis of a valid contract for data processing. In the case of joint processing, a joint controller agreement is concluded.
Revoking your consent to data processing
Many data processing operations are only possible with your express consent. You may revoke any consent you have already given at any time. The lawfulness of the data processing carried out prior to the revocation remains unaffected by the revocation.
Right to object to the collection of data in special cases and to direct advertising (Art. 21 GDPR)
IF THE DATA PROCESSING IS BASED ON ART. 6 (1) LIT. E OR F GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 (1) GDPR).
IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING, TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT ADVERTISING (OBJECTION PURSUANT TO ART. 21 (2) GDPR).
Right to lodge a complaint with the competent supervisory authority
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, place of work, or place of the alleged violation. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only take place if it is technically feasible.
Access, correction and deletion
Within the scope of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of the data processing and, if applicable, a right to correction or deletion of this data. If you have further questions on the subject of personal data, you may contact us at any time.
Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You may contact us at any time for this purpose. The right to restriction of processing exists in the following cases:
- If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data was/is unlawful, you may request the restriction of data processing instead of erasure.
- If we no longer need your personal data, but you need it to assert, exercise or defend legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
- If you have lodged an objection pursuant to Art. 21 (1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data may only be processed – with the exception of its storage – with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a member state.
SSL or TLS encryption
For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Encrypted payment transactions on this website
If, after the conclusion of a contract subject to charges, there is an obligation to send us your payment details (e.g. account number in the case of a direct debit authorization), this data is required to process payment.
Payment transactions using common means of payment (Visa/MasterCard, direct debit) are made exclusively via an encrypted SSL or TLS connection. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.
With encrypted communication, your payment details, which you transmit to us, cannot be read by third parties.
Objection to promotional emails
We hereby object to the use of contact data published within the scope of the legal notice obligation for the purpose of sending unsolicited advertising and information materials. The operators of this site expressly reserve the right to take legal action in the event of the unsolicited sending of advertising material, such as spam emails.
4. Data collection on this website
Cookies
Our website uses so-called “cookies”. Cookies are small data packets and do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or they are automatically deleted by your web browser.
Cookies may come from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g. cookies for processing payment services).
Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies can be used to evaluate user behaviour or for advertising purposes.
Cookies that are necessary for carrying out the electronic communication process, for providing certain functions you wish to use (e.g. for the shopping cart function) or for optimising the website (e.g. cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6 (1) (f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies to provide technically error-free and optimised services. If consent for the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG); consent can be revoked at any time.
You can set your browser so that you are informed about the setting of cookies and only allow cookies on a case-by-case basis, exclude the acceptance of cookies for certain cases or in general, and activate automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited.
You can find out which cookies and services are used on this website in this privacy policy.
Real Cookie Banner
Our website uses the consent technology of Real Cookie Banner to obtain your consent to the storage of certain cookies on your device or to the use of certain technologies, and to document this in compliance with data protection law. The provider of this technology is devowl.io GmbH, Tannet 12, 94539 Grafling (hereinafter “Real Cookie Banner”).
Real Cookie Banner is installed locally on our servers, so no connection to the servers of the Real Cookie Banner provider is established. Real Cookie Banner stores a cookie in your browser in order to be able to assign the consents given or their revocation to you. The data collected in this way is stored until you ask us to delete it, you delete the Real Cookie Banner cookie yourself, or the purpose for storing the data no longer applies. Mandatory statutory retention obligations remain unaffected.
Real Cookie Banner is used to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6 (1) (c) GDPR.
Server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
- IP address
This data is not combined with other data sources.
This data is collected on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – for this purpose, the server log files must be collected.
Use of AI on the website
We use AI-supported services and/or applications on our website.
We use Artificial Intelligence (AI) for the following functions on our website:
- AI colour simulator at: https://echthaardirekt.de/ki-farb-vorschau
- Tidio chatbot powered by LYRO AI AGENT
If you interact with or come into contact with elements on our website that use artificial intelligence (e.g. chatbot), your entries, including metadata, are processed in order to generate a suitable response or reaction.
The use of these AI-supported functions is based on Art. 6 (1) (f) GDPR. We have a legitimate interest in using modern technologies on our website in order to improve our offerings and services and to identify new potential from interaction with our customers. If consent is required, the processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. You can revoke your consent at any time.
You can find further information on the data processing of this tool or service at the relevant point in this privacy policy.
Contact form
If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We do not pass on this data without your consent.
This data is processed on the basis of Art. 6 (1) (b) GDPR, provided your enquiry is related to the fulfilment of a contract or is necessary for carrying out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR), provided this has been requested; consent can be revoked at any time.
The data you enter in the contact form remains with us until you ask us to delete it, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g. after your enquiry has been fully processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.
Enquiries by email, telephone or fax
If you contact us by email, telephone or fax, your enquiry, including all personal data arising from it (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.
This data is processed on the basis of Art. 6 (1) (b) GDPR, provided your enquiry is related to the fulfilment of a contract or is necessary for carrying out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR), provided this has been requested; consent can be revoked at any time.
The data you send us via enquiries remains with us until you ask us to delete it, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g. after your request has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
Communication via WhatsApp
For communication with our customers and other third parties, we use, among other things, the instant messaging service WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Communication takes place via end-to-end encryption (peer-to-peer), which prevents WhatsApp or other third parties from gaining access to the content of the communication. However, WhatsApp does gain access to metadata that is generated during the communication process (e.g. sender, recipient, and timestamp). We would also like to point out that, according to its own statements, WhatsApp shares personal data of its users with its US-based parent company, Meta. Further details on data processing can be found in WhatsApp’s privacy policy at: https://www.whatsapp.com/legal/#privacy-policy.
The use of WhatsApp is based on our legitimate interest in communicating as quickly and effectively as possible with customers, prospective customers, and other business and contractual partners (Art. 6 (1)(f) GDPR). If corresponding consent has been requested, data processing is carried out exclusively on the basis of this consent; this consent can be withdrawn at any time with effect for the future.
The communication content exchanged between you and us via WhatsApp remains with us until you ask us to delete it, withdraw your consent to storage, or the purpose for storing the data no longer applies (e.g. once your inquiry has been fully processed). This is without prejudice to any mandatory statutory provisions – in particular retention periods.
The company holds a certification under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA designed to ensure compliance with European data protection standards for data processing carried out in the USA. Every company certified under the DPF commits to complying with these data protection standards. Further information on this is available from the provider at the following link: https://www.dataprivacyframework.gov/participant/7735.
Communication via Telegram
For communication with customers and other third parties, we use, among other things, the instant messaging service Telegram. The provider is Telegram Messenger LLP, 71-75 Shelton Street, Covent Garden, London, United Kingdom.
When you communicate via Telegram, this takes place via encryption between the end device and the server. This prevents Telegram or other third parties from gaining access to the content of the communication.
Additionally, end-to-end encryption is possible, but this is only used for secret chats. In normal chats, therefore, no end-to-end encryption takes place as a rule.
When you use Telegram, Telegram gains access to metadata generated during use and in the course of the communication process (e.g. sender, recipient, time of messages, device used, operating system, IP address, usernames, etc.).
The use of Telegram is based on our legitimate interest in communicating as quickly and effectively as possible with customers, prospective customers, and other third parties (Art. 6 (1)(f) GDPR).
Further details on data processing can be found in Telegram’s privacy policy at: https://telegram.org/privacy/de.
Registration on this website
You can register on this website in order to use additional features on the site. We only use the data entered for this purpose to use the respective offer or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will refuse the registration.
For important changes, such as to the scope of our offering or technically necessary changes, we use the email address provided during registration to inform you in this way.
The data entered during registration is processed for the purpose of carrying out the usage relationship established by the registration and, if applicable, to initiate further contracts (Art. 6 (1)(b) GDPR).
The data collected during registration is stored by us for as long as you are registered on this website and is then deleted. Statutory retention periods remain unaffected.
5. Analytics tools and advertising
Google Analytics
This website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior of website visitors. In doing so, the website operator receives various usage data, such as page views, time spent on the site, operating systems used, and the user’s origin. This data is combined into a user ID and assigned to the respective end device of the website visitor.
Furthermore, with Google Analytics we can record, among other things, your mouse and scroll movements and clicks. Google Analytics also uses various modeling approaches to supplement the collected data sets and employs machine learning technologies in data analysis.
Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is generally transferred to a Google server in the USA and stored there.
This service is used on the basis of your consent pursuant to Art. 6 (1)(a) GDPR and Section 25 (1) TDDDG. Consent can be withdrawn at any time.
The transfer of data to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://business.safety.google/adscontrollerterms/sccs/.
The company holds a certification under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA designed to ensure compliance with European data protection standards for data processing carried out in the USA. Every company certified under the DPF commits to complying with these data protection standards. Further information on this is available from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.
IP anonymization
Google Analytics IP anonymization is activated on this website. This means your IP address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area prior to transmission to the USA. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, compile reports on website activity, and provide the website operator with other services relating to website and internet usage. The IP address transmitted by your browser as part of Google Analytics is not merged with other data held by Google.
Browser plugin
You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
For more information on how Google Analytics handles user data, please refer to Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.
Data processing agreement
We have concluded a data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Google Analytics e-commerce measurement
This website uses the “Enhanced Ecommerce” feature of Google Analytics. With the help of Enhanced Ecommerce, the website operator can analyse the purchasing behaviour of website visitors in order to improve their online marketing campaigns. Information such as orders placed, average order values, shipping costs and the time between viewing and purchasing a product is collected. Google can compile this data under a transaction ID assigned to the respective user or their device.
TikTok Pixel
We have integrated TikTok Pixel on this website. The provider is TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland (hereinafter TikTok).
With the help of TikTok Pixel, we can show website visitors who have viewed our offers interest-based advertising on TikTok (TikTok Ads). At the same time, we can use TikTok Pixel to determine how effective our TikTok advertising is. This allows the effectiveness of TikTok ads to be evaluated for statistical and market research purposes and optimised for future advertising measures. Various usage data is processed here, such as IP address, page views, time spent on page, operating systems used and the user’s origin, information about the ad a person clicked on TikTok, or an event that was triggered (timestamp). This data is compiled into a user ID and assigned to the respective end device of the website visitor.
This service is used on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. You may withdraw your consent at any time.
Data transfer to third countries is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.tiktok.com/legal/page/eea/privacy-policy/de-DE and https://ads.tiktok.com/i18n/official/policy/controller-to-controller.
6. Plugins and Tools
YouTube
This website embeds videos from the YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
When you visit one of our pages featuring YouTube content, a connection to YouTube’s servers is established. This informs the YouTube server which of our pages you have visited.
Furthermore, YouTube can store various cookies on your end device or use comparable technologies for recognition (e.g. device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to generate video statistics, improve user-friendliness and prevent fraud attempts. Furthermore, the collected data is processed within Google’s advertising network.
If you are logged into your YouTube account, you enable YouTube to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your YouTube account.
The use of YouTube is in the interest of presenting our online offerings in an appealing manner. This constitutes a legitimate interest within the meaning of Art. 6 (1) (f) GDPR. Where appropriate consent has been obtained, processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG, insofar as the consent covers the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. You may withdraw your consent at any time.
Further information on how user data is handled can be found in YouTube’s privacy policy at: https://policies.google.com/privacy?hl=de.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that aims to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to complying with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.
Google Fonts (local hosting)
This site uses so-called Google Fonts, provided by Google, for the uniform display of fonts. The Google Fonts are installed locally. No connection to Google’s servers is established in the process.
Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=de.
Tidio
To handle user enquiries via our support channels or live chat systems, we use Tidio (hereinafter “Tidio”). The provider is Tidio LLC, 180 Steuart St, CA 94119, San Francisco, California, USA.
Messages you send to us may be stored in Tidio’s ticketing system or answered by our staff via live chat. When you communicate with us via Tidio, all data you entered before starting the chat (e.g. name or chat ID, address and phone number) as well as your IP address, country of origin, browser used, end device, the webpage accessed and the messages exchanged are compiled into a profile and stored on Tidio’s servers.
Messages addressed to us remain with us until you ask us to delete them or the purpose for storing the data no longer applies (e.g. once your enquiry has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
Tidio is used on the basis of Art. 6 (1) (f) GDPR. We have a legitimate interest in handling your enquiries as quickly, reliably and efficiently as possible. Where appropriate consent has been obtained, processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG, insofar as the consent covers the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. You may withdraw your consent at any time.
Further information can be found in Tidio’s privacy policy: https://www.tidio.com/privacy-policy/.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that aims to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to complying with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/6312.
AI Colour Simulator (OpenAI Image API)
AI-powered hair colour simulation with OpenAI
On our website, we offer a feature for creating a digital hair colour simulation at https://echthaardirekt.de/ki-farb-vorschau. To use this feature, you can upload your own photo, which is then processed using an AI model from OpenAI.
Type of data processed
The following data is processed when using this feature:
- the photo uploaded by the user (portrait image),
- technical metadata (e.g. IP address, time of request),
- the hair colours selected in the form and configuration data.
Since a portrait photo is an identifiable image of a person, the data may be classified as biometric data within the meaning of Art. 9 GDPR.
Purpose of processing
The photo is used exclusively to generate a hair colour simulation.
The face, skin and background are not analysed or altered; processing is technically limited to the hair areas.
Processing procedure
- After upload, the photo is temporarily stored on our server.
- It is then transmitted via a secure connection to the OpenAI Image Edit API (OpenAI, 3180 18th St, San Francisco, CA 94110, USA).
- OpenAI generates a simulation based on the photo and the selected settings.
- The resulting image is stored on our server for approx. 10 minutes and then automatically deleted.
- The original photo is also deleted after processing and is not stored permanently.
Processing by OpenAI
Processing is carried out via the OpenAI API.
According to OpenAI’s official privacy policy, API data is not used to train AI models unless this is explicitly enabled. We have disabled the use of data for training purposes.
Further information: https://openai.com/policies/privacy-policy
Legal basis
Since biometric data is processed and transferred to a third country, processing is carried out exclusively on the basis of your explicit consent in accordance with:
- Art. 6(1)(a) GDPR
- Art. 9(2)(a) GDPR
Consent is obtained as a mandatory field in the form and can be withdrawn at any time with effect for the future.
Transfer to third countries
The transfer to OpenAI takes place in the USA.
OpenAI is certified under the EU-US Data Privacy Framework, ensuring an adequate level of data protection.
Where necessary, the Standard Contractual Clauses (SCC) approved by the EU Commission are additionally used.
Storage period
- The uploaded photo is only needed for the duration of processing and is then deleted.
- The generated result image is stored for approx. 10 minutes in order to display it to you, and is then automatically removed.
- No permanent storage or archiving takes place.
Recipients
- OpenAI (USA) – processing of the image to create the simulation
- Our hosting provider – technical provision of the website
Obligation to provide data
Providing a photo is voluntary. However, the hair colour simulation cannot be used without your consent and a photo.
7. eCommerce and payment providers
Processing customer and contract data
We collect, process and use personal customer and contract data for the establishment, content and modification of our contractual relationships. We only collect, process and use personal data relating to the use of this website (usage data) to the extent necessary to enable the user to use the service or to bill for it. The legal basis for this is Art. 6(1)(b) GDPR.
The customer data collected is deleted upon completion of the order or termination of the business relationship and the expiry of any applicable statutory retention periods. Statutory retention periods remain unaffected.
Data transfer upon conclusion of contract for online shops, retailers and shipping of goods
If you order goods from us, we pass on your personal data to the transport company commissioned with delivery as well as to the payment service provider commissioned with processing payments. Only the data that the respective service provider needs to fulfil its task is disclosed. The legal basis for this is Art. 6(1)(b) GDPR, which permits the processing of data for the performance of a contract or pre-contractual measures. If you have given corresponding consent in accordance with Art. 6(1)(a) GDPR, we will pass on your email address to the transport company commissioned with delivery so that it can inform you by email about the shipping status of your order; you can withdraw this consent at any time.
Credit checks
When purchasing on account or using another payment method where we provide advance performance, we may carry out a credit check procedure (scoring). For this purpose, we transmit the data you entered (e.g. name, address, age or bank details) to a credit agency. The probability of payment default is determined on the basis of this data. In the event of an excessive risk of payment default, we may refuse the payment method in question.
The credit check is carried out on the basis of contract performance (Art. 6(1)(b) GDPR) as well as to prevent payment defaults (legitimate interest pursuant to Art. 6(1)(f) GDPR). If consent has been obtained, the credit check is carried out on the basis of this consent (Art. 6(1)(a) GDPR); consent can be withdrawn at any time.
Payment services
We integrate payment services from third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank details, credit card number) is processed by the payment service provider for the purpose of payment processing. The respective terms and conditions and privacy policies of the respective providers apply to these transactions. The use of payment service providers is based on Art. 6(1)(b) GDPR (contract performance) as well as in the interest of the smoothest, most convenient and secure payment process possible (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for the data processing; consent can be withdrawn at any time with effect for the future.
We use the following payment services / payment service providers within the scope of this website:
PayPal
The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).
The transfer of data to the USA is based on the Standard Contractual Clauses of the EU Commission. Details can be found here: https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full.
For details, please see PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Apple Pay
The provider of this payment service is Apple Inc., Infinite Loop, Cupertino, CA 95014, USA. Apple’s privacy policy can be found at: https://www.apple.com/legal/privacy/de-ww/.
Google Pay
The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google’s privacy policy can be found here: https://policies.google.com/privacy.
Klarna
The provider is Klarna AB, Sveavägen 46, 111 34 Stockholm, Sweden (hereinafter “Klarna”). Klarna offers various payment options (e.g. instalment purchase). If you choose to pay with Klarna (Klarna checkout solution), Klarna will collect various personal data from you. Klarna uses cookies to optimise the use of the Klarna checkout solution. Details on the use of Klarna cookies can be found at the following link: https://cdn.klarna.com/1.0/shared/content/policy/cookie/de_de/checkout.pdf.
You can find details on this in Klarna’s privacy policy at the following link: https://www.klarna.com/de/datenschutz/.
Sofortüberweisung
The provider of this payment service is Sofort GmbH, Theresienhöhe 12, 80339 Munich (hereinafter “Sofort GmbH”). With the help of the “Sofortüberweisung” procedure, we receive payment confirmation from Sofort GmbH in real time and can begin fulfilling our obligations immediately. If you have chosen “Sofortüberweisung” as your payment method, you transmit your PIN and a valid TAN to Sofort GmbH, which it can use to log in to your online banking account. After logging in, Sofort GmbH automatically checks your account balance and carries out the transfer to us using the TAN you provided. It then immediately sends us a transaction confirmation. After logging in, your transactions, the credit limit of your overdraft facility, and the existence of other accounts as well as their balances are also checked automatically. In addition to the PIN and TAN, the payment data you entered as well as data about you are transmitted to Sofort GmbH. The data about you includes first and last name, address, telephone number(s), email address, IP address, and, if applicable, other data required for payment processing. The transmission of this data is necessary to establish your identity beyond doubt and to prevent attempted fraud. Details on payment with Sofortüberweisung can be found at the following link: https://www.klarna.com/sofort/.
Mollie
The provider of this payment service is Mollie B.V., Keizersgracht 126, 1015CW Amsterdam, Netherlands (hereinafter “Mollie”). With the help of Mollie, we can integrate various payment methods on our website. Details can be found in Mollie’s privacy policy: https://www.mollie.com/de/privacy.
American Express
The provider of this payment service is American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany (hereinafter “American Express”).
American Express may transfer data to its parent company in the USA. The data transfer to the USA is based on the Binding Corporate Rules. Details can be found here: https://www.americanexpress.com/en-cz/company/legal/privacy-centre/binding-corporate-rules/.
For further information, please refer to American Express’s privacy policy: https://www.americanexpress.com/de-de/firma/legal/datenschutz-center/online-datenschutzerklarung/.
Mastercard
The provider of this payment service is Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium (hereinafter “Mastercard”).
Mastercard may transfer data to its parent company in the USA. The data transfer to the USA is based on Mastercard’s Binding Corporate Rules. Details can be found here: https://www.mastercard.de/de-de/datenschutz.html and https://www.mastercard.us/content/dam/mccom/global/documents/mastercard-bcrs.pdf.
VISA
The provider of this payment service is Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, United Kingdom (hereinafter “VISA”).
The United Kingdom is considered a safe third country under data protection law. This means that the United Kingdom has a level of data protection that corresponds to the level of data protection in the European Union.
VISA may transfer data to its parent company in the USA. The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.visa.de/nutzungsbedingungen/visa-globale-datenschutzmitteilung/mitteilung-zu-zustandigkeitsfragen-fur-den-ewr.html.
For further information, please refer to VISA’s privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
TikTok Shops
We sell goods and/or services via TikTok Shops. The provider of the shop system is TikTok Technology Limited, The Sorting Office, Ropemaker Place, Dublin 2, D02 HD23, Ireland, or another contracting group company of TikTok – depending on the respective logistical handling (hereinafter “TikTok Shops”). The sale takes place directly on the TikTok platform.
TikTok Shops enables us, as a provider, to handle the sale of products directly via the TikTok platform. Through TikTok Shops, we can provide product information, manage orders, receive payments, and carry out shipping and communication processes with our customers. In doing so, we and TikTok receive and process various personal data via the platform that are necessary for processing the purchase, including profile information (e.g. name, username, profile picture), information provided by you (e.g. order data, support requests), messages between buyer and seller, business content such as product descriptions and customer reviews, payment information (e.g. credit card details, PayPal details), as well as TikTok account information such as user ID and technical device information. This data processing serves to fulfil the contract, process payments, coordinate shipping, and communicate with customers.
When using TikTok Shops, personal data is transmitted to TikTok, which is necessary for the provision and handling of the service. TikTok stores user data in data centres within the EU as well as outside the European Union or the European Economic Area – in particular in third countries. It cannot therefore be ruled out that, in certain cases, government authorities outside the EU, particularly in third countries that are not considered safe under data protection law, may gain access to personal data.
The processing of personal data is carried out for the purpose of contract fulfilment in accordance with Art. 6 (1) (b) GDPR.
The data transfer to third countries is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.tiktok.com/legal/page/global/partner-privacy-policy/en#eea and at https://ads.tiktok.com/i18n/official/policy/controller-to-controller.
For more information on how user data is handled in TikTok Shops, please refer to TikTok’s privacy policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de and https://www.tiktok.com/legal/page/global/tiktok-shop-creator-privacy-policy/de.
Shopping Cart Reminder (Incomplete Orders)
If you enter your email address during the checkout process and do not complete the order, we save this email address together with the items in your shopping cart on our own server in order to automatically remind you of your cart by email. We use the plugin CartBounty – Save and recover abandoned carts for WooCommerce for this purpose, which runs entirely locally on our server. No data is transmitted to third parties. The reminder is only sent if you have expressly consented to it at checkout (legal basis: Art. 6 (1) (a) GDPR). You can withdraw your consent at any time via the unsubscribe link in every reminder email. The data is automatically deleted after 60 days at the latest.
The legal basis for this processing is your consent (Art. 6 (1) (a) GDPR), which you give during the checkout process via a corresponding checkbox, as well as our legitimate interest in resuming abandoned checkout processes (Art. 6 (1) (f) GDPR). You can object to receiving further cart reminder emails at any time — every one of these emails contains an unsubscribe link at the bottom. Alternatively, an informal message to info@echthaardirekt.de is sufficient.